11 June 2009
The new Home Office polices on the entry of non EEA nationals to the UK threatens to cause chaos in those parts of the UK fleet that are now heavily dependent on skilled fishermen from the Philippines.
The Federation has written to the Chairman of the Migration Advisory Committee, which advises the Home Office and the UK Borders Agency, in the following terms:
Fishing Industry Labour Requirements: Shortage Occupation List
I write to alert the Migration Advisory Committee to the serious crewing difficulties faced by UK registered fishing vessels as a result of the Home Office and Border Agency’s tightening of their policies towards the migration to the UK of nationals from non-EEA countries.
Over a number of years, significant portions of the UK fishing industry have become dependent on crews from the Philippines to address a serious shortage of skilled fishermen. At base this shortage of crew has arisen from the fact that fishing is an arduous occupation, prosecuted in difficult physical conditions with extremely unsocial hours. To attract crew in these circumstances, it has always been necessary for fishing remuneration to offer a premium over what is on offer from broadly equivalent land based occupations. Over the last 15 years or so it has been increasingly difficult to provide this premium for a variety of factors of which the principal is the constraint on vessel earnings resulting from EU conservation measures, including limits on the quantities of fish each vessel is permitted to land. The result has been that vessels have faced severe crewing shortages to the extent that some vessels have been unable to go to sea, resulting in an overall loss of employment and reduction in economic activity.
Eastern European and Filipino crewmen have filled this gap and parts of the fishing industry are now highly dependent on this source of labour. It is important to appreciate that although they might not meet conventional standards of skill, in fact the majority of the Filipino crews employed are highly skilled fishermen.
The effect of tightening entry controls on this type of skilled labour will be to jeopardise the economic and operational viability of many vessels in the UK fleet.
Against this background we would make the following points:
- The criteria for categorising “skill” utilised by the Migration Advisory Committee is unjustifiably rigid and are not appropriate for the fishing industry where a different and in many ways unique, set of skills is recognised. This rigidity penalises the fishing industry which cannot function safely or economically without a full complement of crew who know what they are doing on board a fishing vessel.
- The Border Agency’s differentiation of the UK fleet into “inshore” and “deep-sea” categories fails to take into account the realities of fishing where many vessels operate on both sides of the 12 mile limit depending on season or where the best caches of fish can be located.
- The economic status of many parts of the fishing industry is fragile in the extreme. The fleet is particularly vulnerable to rising fuel costs because most fish is sold through the auction system and therefore increased costs cannot simply be passed on to the consumer. The recession has impacted seriously on the price of first hand sales of fish.
- As far as we can see, the employment of Filipino crews has had no displacement effect for indigenous labour. The fishing industry has suffered from a serious shortage of crew for a considerable period of time now and there is no sign that this has been changed by the recession.
- Although the conventional definitions of “skill” are problematic when applied to the fishing industry, there is a strong case for including fishing on the shortage occupation lists for the United Kingdom.
Against this background we would ask that you examine more deeply the impact of current Home Office rules on immigration of Filipino fishermen to the UK to work on UK registered fishing vessels of all types. We hope that it will be possible to put some kind of dispensation into effect before irreparable harm in done to important parts of the UK fleet.