Black Sea MoU has published the detailed results of its 2024 Concentrated Inspection Campaign (CIC) on Crew Wages and Seafarer Employment Agreement.
From 1 September 2024 to 30 November 2024, the Black Sea MoU carried out a Concentrated Inspection Campaign (CIC) on Crew Wages and Seafarer Employment Agreement under the Maritime Labour Convention (MLC, 2006). The campaign involved member Authorities of the Black Sea MoU that have ratified the MLC, 2006.
At a glance
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A total of 28 questionnaires had at least one non-compliant response, which resulted in 5.06 per cent of CIC inspections not conforming to the requirements set out in the questionnaire. The overall average per cent of non-compliant responses to total applicable responses was 0.74.
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During the campaign, a total of 53 vessels were detained. 45 of these detentions were the result of inspections with CIC Questionnaires and 4 of them were detained as a direct result of the campaign (7.5%). The overall detention rate regarding CIC topic related detentions was 0.72%.
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All detained ships with CIC-related deficiencies in the Region (4 ships) were general cargo/multipurpose ships.
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A total of 31 flags covering 24.77% of the total CIC inspections (137 inspections) had no non-compliant responses.
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The detained ships with CIC-related deficiencies in the Region were flying the flags of Belize, Cameroon, Saint Kitts and Nevis, and Vanuatu.
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By ship age, there were no non-compliant CIC inspections for new ships aged 0-5, and no detentions were observed among ships younger than 15 years old.
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Older ships, particularly those 30 years and older, are reported to have the least favourable results. They comprised half of the CIC-related detentions.
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A very high level of compliance was observed for the majority of questions, except Q1 and Q6, with over 99% ‘YES’ answers. Questions 2, 3, and 7 showed the highest compliance rates.
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There were 6 instances that resulted in recorded detainable deficiencies, including the absence of signed SEA, non-compliance with SEA coverage as specified in the MLC, 2006, and delays in wage or salary payments exceeding monthly intervals.
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The most unfavourable results were recorded in responses to Questions 1 and 6, which asked:
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Question 1: Is the seafarer given a SEA signed by both the seafarer and the shipowner or a representative of the shipowner? (42.2%)
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Question 6: Are wage or salary payments made to the seafarer at no greater than monthly intervals? (24.4%).
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Scope and inspection details
This CIC applied to all ships and a ship was subjected to only one CIC inspection during the campaign period. Over the course of the campaign, a total of 635 inspections were carried out by the member Authorities of the BS MoU which are a party to MLC, 2006, covering 626 individual ships. Among these, 553 inspections were carried out with the CIC questionnaire. During the CIC, 53 ships were detained in total. Of which, 45 detentions were the result of inspections with CIC questionnaires and 4 of them were detained directly attributed to CIC-related deficiencies.
Non-compliance statistics
A total of 28 questionnaires had at least one non-compliance to any of the requirements, resulting in 5.06 per cent of CIC inspections. The overall average per cent of nonconformities was 0.74 which means that the “unsatisfactory” answer was given to any question under this CIC.
Common deficiencies
The most common non-compliances were related to the absence of signed Seafarer Employment Agreements (SEA) (42.2%) and delays in wage or salary payments exceeding monthly intervals (24.4%).
Vessel types inspected
The majority of CIC inspections were bulk carriers with 206 inspections (37.3%), followed by general cargo/multi-purpose ships with 149 inspections (26.9%), oil tankers with 74 inspections (13.4%) and oil/chemical tankers with 69 inspections (12.5%), which comprises 498 total CIC inspections with a rate of 90.1%. All detained 4 ships with CIC-related deficiencies in the Region were general cargo/multipurpose ships.
Flag state statistics
During the campaign, vessels registered under the flags of 44 different States were inspected under the CIC scope. Vessels flagged by Panama with 138 inspections (25.0%), Liberia with 77 inspections (13.9%) and the Marshall Islands with 39 inspections (7.1%) underwent the highest number of inspections. Detentions linked to CIC-related deficiencies involved vessels flagged by Belize, Cameroon, Saint Kitts and Nevis, and Vanuatu.
Age of vessels and detention trends
Notably, older ships, particularly those 25 years and older, comprised the three-fourths of detentions, while no detentions were observed among ships younger than 15 years old and no non-compliant CIC inspections were recorded for new ships aged 0-5.
The overall detention rate regarding CIC-topic related detentions is 0.72%. Non-compliant responses of “Seafarer’s employment agreement SEA,” “Wages,” and “Non-payment of wages” had the largest number of deficiencies. CIC detentions, as a result of CIC-topic related detainable deficiency/deficiencies, are mostly related to the absence of signed SEA (Q1) and delays in wage or salary payments (Q6).
Recommendations
Although the overall results of the CIC were satisfactory in general, in order to enhance seafarers’ employment conditions, including their working and living conditions, health, safety, and welfare on board ships, attention should be paid to:
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Seafarers must have a signed original version or copy of their seafarers’ employment agreement; and
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Wages or salaries must be paid no later than monthly, in accordance with their employment agreements.
It is also recommended that PSCOs should continue to pay close attention to Crew Wages and Seafarer Employment Agreement related matters when performing PSC inspections.
