Namely, IMO regulations within STCW, set minimum rest period which should not be less than 10-h in any 24-h period and 77-h in any 7 day period. The rest period can be divided into no more than two period, one of which shall be at least 6 hours in length. Same working & rest hours provisions have been included in ILO, Maritime Labour Convention, 2006 which came into force in 2013.
Why Fatigue is considered as a key risk concern
Fatigue has become a key concern within shipping because the operational aspects associated with the industry are more complex than those associated with other industries. For example, variety of ship types, the pattern and length of sea passage, the number of port visits and the non-standardized port stay, all present unique combinations of potential causes of fatigue.
Ship owners and operators are obliged to seek economic efficiencies as a result to reduce the number of shipboard crew that means more demanding working conditions for seafarers. Seafarers have to work long and irregular hours for long periods of time and are frequently subjected to restricted and interrupted sleep, high workload, poor eating habits, poor sleeping conditions, social isolation and no clear separation between work and recreation.
Last year, Australia collaboratively with other interested parties to the IMO, initiated a process for reviewing and updating the international Guidelines of Fatigue. Initial submissions concerning a proposed approach and the way forward for new guidelines was discussed. Finally, during its landmark 100th session, the IMO's Maritime Safety Committee (MSC 100) approved the development of comprehensive Guidance on fatigue mitigation and management (MSC/Circ.1014), which was issued in 2001. In particular, it was agreed that there is need for a revision and update of these guidelines with a view to consider a more holistic approach to managing the risk of fatigue at sea.
Fatigue Management Framework
Figure 1 demonstrates a framework to mitigate the risk of fatigue within the maritime industry. The framework includes multiple layers of defences and associated control measures, primarily based on the “defences in depth” model.
The framework is composed of two important processes which are critical for its success:
- Fatigue Risk Management (FRM) Controls
- FRM Safety Assurance
The FRM Controls effectively deal with the first two layers which are the principle mitigation strategies required to control and manage fatigue related risks.
- The first layer requires effective company support and commitment for managing and controlling the risks of fatigue.
- The second layer requires that seafarers are provided with adequate opportunity for sleep. This ensures that both duration and quality of sleep are considered.
The FRM Safety Assurance provides the data driven feedback (assessment and evaluation) through monitoring, to assure that the FRM controls are working effectively.
- The third layer ensures that any issues affecting seafarers’ duration and quality of sleep, even though adequate opportunities of sleep have been provided, are being effectively captured. This entails monitoring and assessing sleep obtained and provides for the implementation of risk mitigation controls when issues are identified.
- The fourth layer ensures that seafarers obtain what is considered, on average, sufficient sleep and are able to maintain adequate alertness and performance while performing their duties. This entails monitoring and assessing levels of fatigue and fitness for duty.
- The fifth layer ensures that formal processes are in place for identifying and assessing fatigue related events or incidents. This layer relies and having an effective safety reporting culture.
A combination of FRM controls and FRM safety assurance allows for continuous improvement within the maritime fatigue risk management framework (Figure 2). If the controls perform to an acceptable standard, they become part of normal operations and are monitored evaluated by the FRM safety assurance. If the controls do not perform to an acceptable standard, then it will be necessary to re-evaluate the controls at the appropriate step. As the organization’s understanding of its own fatigue risk grows through experience, the organization becomes able to adjust and use the feedback driven by the safety assurance to improve the fatigue risk management processes and subsequently better manage fatigue.
One of the challenges for effective fatigue risk management systems is the need for regulators and the maritime industry in general, to have a sufficient knowledge and understanding of the cause and consequences of fatigue that enable them to meet their responsibilities in this regards. As indicated, the industry needs more defensive layers than the hours of work and rest regulations to manage the risks of fatigue at sea.
Although the hours of work and rest regulation are here to stay the implementation of a maritime fatigue risk management system as proposed in this paper, will ensure effective management of the risks of seafarer fatigue with minimal impact on cost and operational flexibility.
It is now widely accepted that fatigue can no longer be viewed as part of a labour issue but as described, should be part of the ship’s safety management system and International Safety Management (ISM) code. Recognizing that there will be challenges in global wide, an effective fatigue risk management in shipping should bring the industry one step closer towards, ensuring better health, wellbeing and safety for seafarers.