6 ISF is concerned about the enormous length of the draft SMCP. We have been advised by English language training experts that long lists of phrases can in fact be harmful to understanding if they are used by seafarers that do not fully understand the context in which the phrases are being employed and do not already have a relatively detailed knowledge of English. Within the profession of teaching English as foreign language we understand that it is not usual practice to use long series of occupational phrases as teaching tool.
7 A List such as the current draft SMCP is unlikely to be a reliable teaching resource since it could give teachers the false impression that it is the definitive lexicon for effective communication. The effect of this could be that teachers will be encouraged to approach the subject in terms of learning by rote rather than the development of a syllabus that involves the practice of genuine English language communication. We are therefore very doubtful of the practical benefits of using the SMCP, in its current form, as a key teaching material in maritime training institutions. If the SMCP is to be adopted, it should be made clear that the purpose of the majority of the phrases is only to serve as reference material which may be used by English language teachers to supplement their teaching of general English language.
8 We also have a number of detailed criticisms of the English used. For example:
・inconsistent deletion in individual phrases of articles or verbs (presumably for the purpose of brevity) which can result in ambiguity in the meaning of phrases;
・inconsistent deletion of indefinite or definite articles ("a/an" and "the") which can cause confusion amongst non English speakers;
・repetition of similar phrases that may cause students to overlook important vocabulary because they may view the phrases as being almost identical;
・plus other inaccuracies which will probably best be addressed by discussion in a working group.
9 In view of the above, we feel that it is very important that the draft SMCP are not adopted without very detailed consideration by IMO. THE need for careful consideration of the SMCP is particularly important given that references to the SMCP already exist in STCW 95.
10 In summary therefore, ISF suggests the following:
11 The draft SMCP should be restructured so that there is a clear distinction (i.e. entirely separate sections) between vocabulary to be used for external communications and those phrases which may be useful for internal communications between seafarers (and with passengers) on board.
