Specifically, the letter addresses the short time frame for applications, a general lack of awareness of the scheme, the failure to provide information in appropriate languages, and considerable costs related to the required certification by a solicitor.

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Moreover, according to AWS, once a fisher's work permit is given, workers are eligible to work for only that employer, effectively tying migrant fishermen, their livelihood and immigration status to such employer and allegedly giving excessive power to potentially abusive employers over workers.

In addition, UN officials noted that they believe that those workers that could not convince their employers to apply for the AWS scheme have no choice but to remain undocumented.

Undocumented workers fear of loosing their jobs and are always in the risk of deportation. Therefore, they don't fill a form of complaint against their abusive employer.

The letter also notes that according to data 80.7% of respondents reported working more than 60 hours per week and 65.3% more than 100 hours per week, while the employment contract for the permit applied a standard 39 hour work per week.

Similarly

  • 40% of migrant fishermen reported not feeling safe at work;
  • 36.6% of them reported having either personally sustained injuries or witnessed others injured at work;
  • 1 in 4 workers interviewed experienced verbal and/or physical abuse;
  • 1 in 5 experienced discrimination, which included unequal pay or unfair share of the catch compared to other European fishermen.

ITF supports Rapporteurs' criticism commenting that the AWS exacerbates the problem of systemic exploitation of foreign workers in the Irish fishing industry.

ITF coordinator for the U.K. and Ireland Ken Fleming noted

This is another vindication of what the ITF’s been saying since this doomed scheme was brought in. The U.N. joins the U.S. State Department and the Council of Europe in this deafening chorus of criticism of the Atypical Work Schem. And yet still the Irish government won’t listen, so workers continue to suffer and Ireland’s global reputation is dragged through the mud.

Finally, the letter is signed by Felipe González Morales, Special Rapporteur on the human rights of migrants, E. Tendayi Achiume, Special Rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance, Urmila Bhoola, Special Rapporteur on contemporary forms of slavery, including its causes and consequences, and Maria Grazia Giammarinaro, Special Rapporteur on trafficking in persons, especially women and children.