The regulations for hours of work and rest
Pursuant to the Maritime Labour Convention (MLC) 2006, which came into force on 20th August 2013, the standards for
(A) maximum hours of work and (B) minimum hours of rest, under Title 2, are:
A.no more than 14 hours in any 24 hour period and no more than 72 hours in any 7 day period; or
B.at least 10 hours in any 24 hour period; and at least 77 hours in any 7 day period.
The regulations for hours of work and rest
Pursuant to the Maritime Labour Convention (MLC) 2006, which came into force on 20th August 2013, the standards for
(A) maximum hours of work and (B) minimum hours of rest, under Title 2, are:
A.no more than 14 hours in any 24 hour period and no more than 72 hours in any 7 day period; or
B.at least 10 hours in any 24 hour period; and at least 77 hours in any 7 day period.
There are only limited exceptions, and generally it would be a matter of the vessel’s immediate safety with respect to a justified overrun of working hours. A seafarer cannot be asked to exceed his mandated rest/work hours, nor can he be enticed to do so against payment of overtime.
The MLC standards are very similar to the requirements under STCW following the 2010 Manila amendments.
What is really needed?
The MLC and STCW discuss the issue in terms of hours of work and ‘rest’, but rest does not mean the same as sleep.
Studies have shown that it is not merely rest that the human body requires, but the key is sleep. And again, it is not just any form of sleep over a period of time that counts. The seafarer, like everyone else, needs proper, continuous and uninterrupted sleep for 7 to 8 hours in order to be properly rested.
Being off work for 2 hours, but not taking or being given the opportunity to enjoy a sound and uninterrupted period of sleep will still see a build-up of fatigue over time which ultimately can lead to serious consequences.
It is not uncommon, particularly in short-sea trades, for seafarers to follow a 6 hours on, 6 hours off watch routine, often for several days or weeks in succession. With respect to the regulations, this system leaves very little margin for error and research has shown that seafarers following this routine are more likely to be in breach of the regulations than those following the traditional 4 hours on, 8 hours off system, in particular the requirement for a minimum of 10 hours’ rest in any 24 hour period.
From a more practical point of view, allowing a seafarer just 6 consecutive hours of rest prevents them from achieving the recommended 7 to 8 hours of continuous sleep. Indeed, when following the traditional 4 hours on/off watch routine, seafarers should endeavour to achieve as much sleep as possible during one rest period, leaving a requirement for a short nap during the other, rather than splitting sleep evenly between the two.
It is, therefore, important to ensure that, during training before service, when inducted into service and continuously thereafter, both officers and crew are well educated as to how they should take care of themselves and each other. This should be done in conjunction with good shore-based support that ensures vessels maintain the necessary standards and operate safely.
Practical reality
Of course, it is the practical reality on board a vessel and its trading pattern that really determine whether seafarers get the rest they need. Vessels with frequent port calls will have a much more intensive work pattern than a vessel that undertakes long-haul passages and makes only periodic port calls. It is very different to work on a Capesize ship doing Brazil to China voyages as against being on a small container feeder or chemical tanker making frequent short voyages with repeat and fast cargo operations.
It is, therefore, not the case that ‘one size fits all’ when it comes to putting the MLC requirements into practice. Careful bespoke planning has to be undertaken for every vessel, including proper passage planning, preparations for cargo operations, repairs and other activities, so that the crew get the rest they need, fatigue is prevented and accidents are avoided.
Shipboard and shore-based managers should also bear in mind that compliance with the regulations will not always ensure a seafarer is well rested. Aside from the difference between rest and sleep, a seafarer working 6 hours off, 6 hours on for extended periods, while complying with the regulations, is likely to develop symptoms of fatigue over time. In a recent study of deck officers employed on UK based ferries, 41% of respondents who remained compliant with the regulations over a 28-day period also reported experiencing elevated levels of fatigue.
With proper care and attention, seafarers can enjoy a safe and rewarding working environment which means accidents are avoided, crew remain healthy and crew come back to ships, and ultimately that benefits all interests in the industry.
Top 5 Dos And Don’ts For Preventing Fatigue
Do ensure all concerned are aware of the dangers of fatigue and best practices for preventing it.
Do promote flexible watch routines and working practices to accommodate over- burdened seafarers.
Do encourage seafarers to take ownership of their own hours of rest and raise potential incidences of non- compliance with onboard management BEFORE they occur.
Don’t tolerate falsification of records of rest hours or officers who flagrantly disregard the regulations.
Do endeavour to provide comfortable sleeping quarters to assist seafarers in achieving the best possible rest.
*Concluded
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