Marine Advisory: 02/2010 - UK MCA Warns of Action Regarding Unsafe Manning Levels

March 19, 2010

MARINE ADVISORY NOTE 02-2010

Subj: UK MCA Warns of Action Regarding Unsafe Manning Levels

Re:

1. UK MCA Press Notice 054-10
2. STCW Section A-VIII/1
3. Part 10 of the Articles of Agreement (See 10.320 of the Liberian Maritime Regulations)
4. Marine Notice MAN-001 – Manning of Vessels and Principles of Watchkeeping
5. Marine Notice MAN-003 – Certification, Training, and Rest Periods
6. IMO MSC/Circ.1014 – Guidance on Fatigue Mitigation and Management

To: Shipowners/Operators and Master’s

Dear Owner/Operator/Master:

In its press release issued on 26 February 2010, the UK MCA has warned that they will begin targeting vessels for compliance with rest hour requirements during Port State Control inspections.

UK MCA inspectors will check on board schedules and work records and compare them to the operating pattern of the ship to verify their accuracy. Inspectors will also be checking for compliance with the requirement for a dedicated lookout at night. In addition, inspectors will be looking for evidence of internal audits of rest hour records.

Shipowners, operators, and Masters should ensure that rest hour requirements are being adhered to and that all records of rest hours are accurate and up to date and as noted in ref (e), the Master shall ensure the hours of work and/or rest periods of each navigational and engine room watchstander are recorded and available for inspection. Any internal review of rest hour policies, procedures, and records should be documented as an internal audit under the vessels safety management system.

References (b) to (e) describe the rest hour requirements for watch keepers which shall be followed:

1. All persons who are assigned duty as officer in charge of a watch or as a rating forming part of a watch shall be provided a minimum of 10 hours of rest in any 24-hour period.
2. The hours of rest may be divided into no more than two periods, one of which shall be at least 6 hours in length.
3. The requirements for rest periods laid down in paragraphs 1 and 2 need not be maintained in the case of an emergency or drill or in other overriding operational conditions.
4. Notwithstanding paragraphs 1 and 2, the minimum period of ten hours may be reduced to not less than 6 consecutive hours provided that any such reduction shall not extend beyond two days and not less than 70 hours of rest are provided each seven-day period.

The watch schedule shall be posted.

IMO MSC Circular1014 contains detailed guidance on fatigue mitigation and management, including a model format for Table of Shipboard Working Arrangements and a model format for Records of Hours of Work or Hours of Rest of Seafarers which can be found in appendixes 2 and 3 of the circular (copies attached). Additionally, ISF has available a computer software package called “ISF Watchkeeper” for use on board ships, to maintain records of seafarers’ hours of work and rest, and allow ships and their crews to demonstrate compliance with international work hour rules. Information on the “ISF Watchkeeper” software is available at http://www.marisec.org/watchkeeper/index.htm.

For questions regarding this note please contact Sean Brett at telephone +1 703-251-2434, email: Safety@liscr.com.

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