Benefits of shipping:
Resilience for natural disasters or emergencies.
Ships carry hazardous / dangerous cargo more safely than road, rail and air.
15% of New Zealand's inter-regional freight is carried by sea
Ships can handle oversized, heavy and bulky cargo that road, rail and air can't.
Freight volumes are forecast to increase 50% by 2040.
It won't all fit onto our roads!
New Zealand’s total freight task: 278.7 million tonnes.
Coastal shipping carries approx 10 million tonnes (3.5%).
1.15m people are transported across the Cook Strait every year
The volume of domestic freight moved by shipping has increased 50% over the last 10 years.
Approx $28 billion road and rail freight is shipped between the North and South Islands each year
1 standard container Auckland to Christchurch:
road: $2200-$3000
rail: $1300 - $1900
ship: $850 - $1300
418,470 containers are moved around the NZ coast per annum
Shipping: one-eighth the emissions of road per tonne of freight moved
Benefits of shipping:
Lower emissions per tonne of freight moved.
Increasing total freight carried by ship by just 2% would reduce total transport emissions by 16%.
Benefits of shipping:
Greater control over our domestic supply chains.
Shipping: 60% the emissions of rail per tonne of freight moved
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Submission to the Ministry of Transport on the Clear Heads consultation (2015)

The New Zealand Shipping Federation is the key representative body for New Zealand’s coastal shippers. Members of the Federation are:

Coastal Bulk Shipping

Golden Bay Cement




Pacifica Shipping

Silver Fern Shipping

Strait Shipping

Coastal shipping is a vital part of New Zealand’s transport infrastructure. It also plays a role in civil defence. It is important for New Zealand economic, environmental and social welfare that the coastal network operates efficiently and effectively. It is a truly strategic asset.

Central and local government decisions can optimise the way that the coastal network performs. These decisions can also drive unnecessary costs into shipping operations.

The Federation is committed to working with decision-makers to ensure that the best policy settings are in place for the benefit of all New Zealanders. We are happy to work proactively to bring sector knowledge to support the policy-making process.

The Federation and its members are committed to the health and safety of staff and passengers on their ships. As sector experts, we want to work with policy makers and other stakeholders to ensure everyone gets home safely. Sound drug and alcohol policies in the maritime sector are a part of this.

In common with most people in the maritime sector, we believe that seafarers should be drug free and sober. Members of the Federation generally have strong and comprehensive policies in respect of intoxication and drug-related impairment on board their ships. This forms part of their employment agreements. Where these are not in place as separate documents, this issue is covered by the general provisions of the employment agreements and work is in progress to create separate policies.

We are concerned that the initial discussion document does not distinguish between the various types of commercial maritime operation. This raise two different problems.

Firstly, coastal shipping is very different to many of the other commercial maritime operations. Coastal ships are part of large business operations, in some cases part of international organisations. They have significant in-house capability to implement drug and alcohol policies. They are subject to international rules such as staff certification requirements and their staff value their qualifications and certification. Accepted best practice also impact on members of the Federation, by way of example, the United States Coast Guard requires urine testing and this is accepted and followed by the significant shippers of oil as the standard wherever they operate around the world.

Coastal shippers have to meet the requirements and expectations of their investors as well as their insurers. They are in the sector for the long term and value their reputations.

Secondly, lumping all commercial maritime operators together disguises the level of problem in some parts of the sector and unfairly implicates operators who have a sound safety record. By way of example, Table 1 refers to Maritime Commercial operations as having 63 fatalities in the 2010-11 year with 8% (5 deaths) due to impairment. We believe none of these happened in coastal shipping. We recommend that all statistics be at least separated as to:

  • International-going ships
  • Coastal ships
  • Fishing vessels
  • Recreational (non-adventure) operators
  • Adventure tourism operators.

You may also think that a breakdown by size of organisation and type of governance structure may give a better indication of the types of rules that need to be in place and policed by government.

In the sector, the wording of company drug and alcohol policies is not standard across member organisations but the effect is the same: zero tolerance. Enforcement and policing of these policies is done by the companies and may cover any or all of the following elements for staff and contractors:

  • pre-employment D&A testing
  • re-employment testing, following extended leave over and above normal leave
  • post incident/accident D&A testing
  • reasonable/just cause D&A testing
  • unannounced drug testing at least annually
  • random testing of all land based staff

We believe that points of contention within the sector (including but not limited to the ship operators, staff and unions) are:

  • to what extent are black line test numbers are a proxy for actual impairment. While black line numbers are accepted as a proxy for gauging impairment in respect of alcohol, whereas testing for drug impairment appears to be treated differently, partly because of the many and changing drugs in use in the population.
  • the effects of residual drugs in the seafarer’s system and the impact on safety. Is there any acceptable level of legal or illegal drugs consumed whilst on leave but still discernible in testing on return to the ship? Members believe that any use of illegal and performance-inhibiting narcotics is of concern so there should be zero-tolerance of any residue of illegal drugs.
  • the efficacy of saliva testing as against observed urine testing.
    • Saliva testing is considerably less invasive and it is most useful post-incident to identify substances that are active in a person’s body. It does not require specialist equipment to collect and analyse so can be done by on-board staff when an external agency is not available at short notice.
    • Urine testing gives a more reliable indication of performance-affecting drugs and/or alcohol that are either active or residual in the body of the person tested. Urine testing is considered best practice internationally but in the absence of support from legislation it remains a matter for employment negotiation.
  • the fairness of random testing for alcohol or drugs. Federation members believe that random testing is an essential part of a zero tolerance policy to achieve safety at sea.
  • the need for the test to deliver an immediate result so that it serves the purpose of identifying persons at/causing risk at the particular time enabling their removal from the workplace.

We believe that member companies are doing a good job of setting and maintaining sound and comprehensive drug and alcohol policies. We believe that it would be beneficial to have support for these policies by way of:

  • Government requiring that employers have drug and alcohol policies as part of their employment relationships
  • Government requiring that drug and alcohol policies are enforced by the employer, that is, they are not shams
  • So as to avoid this issue being part of an employment negotiation, legislative minimum requirements in respect of:
    • pre-employment D&A testing
    • re-employment testing, following extended leave over and above normal leave
    • post incident/accident D&A testing
    • reasonable/just cause D&A testing
    • unannounced at-work drug testing.

The Federation supports the development of a New Zealand Standard backed by legislation in respect of appropriate testing for alcohol and drugs. This issue should not be left to be part of pre-employment negotiation.

In answer to your explicit questions and in respect of the coastal shipping sector, Federation members support:

  • We support zero tolerance on board our ships for staff and contractors.
  • Ship operators should be responsible for having and policing drug and alcohol policies. Thus the government role would be to require evidence the policies are in place and that they are not a sham.
  • All staff and contractors on board ship should be subject to the same drug and alcohol regime.
  • We believe that the minimum requirements and standards in place for coastal ships should also apply to international ships unless they are complying with more stringent international standards.
  • The penalties for breaching company policies should lie with the companies.
  • Enforcement agencies should continue to have the power to test any person who is involved in an accident but it would be expected that this is initially the responsibility of the company.

If you wish to discuss this submission in more detail, the first point of contact for the Federation is Annabel Young, Executive Director.