According to the Marshall Islands, Port State Control (PSC) deficiencies are being issued, mostly in Belgium, over cadet working hours. Namely, most training agreements do not include overtime, however some inspections have showed that cadets are often working excessive overtime hours.
Cadets are seafarers and must be covered under a seafarers’ employment agreement (SEA) or a training agreement in lieu of a SEA.
Most training agreements include a monthly lumpsum payment and do not include overtime as standard SEAs do. So, cadets have to work normal hours, which in port and at sea mean eight hours per day.
However, during flag State inspections it was found that cadets are often working excessive overtime hours. This fact is also being picked up by PSC who are issuing Code 17s and require that outstanding accumulated overtime is paid.
The Marshall Islands suggested that cadets must either be covered under a SEA that includes overtime or comply with normal working hours under a training agreement where overtime is not specified. Onboard records and documentation must also reflect this.