Paris MoU has published the 2024 Concentrated Inspection Campain (CIC) on Crew Wages and Seafarer Employment Agreements (SEAs) report, where a total of 30 ships out of the total of 3863 ships (0,78%) were detained for at least one CIC-related topic detainable deficiency.
A Concentrated Inspection Campaign (CIC) on compliance with some MLC, 2006 provisions was carried out jointly by the Paris MoU and Tokyo MOU during the period 1st September 2024 to 30th November 2024.
Furthermore, the Tokyo MoU, in collaboration with the Paris MoU, developed a CIC Questionnaire and accompanying guidance. This questionnaire comprised 10 key questions to be answered by Port State Control Officers (PSCOs) during Port State Control (PSC) inspections conducted within the CIC period.
A total of 3,863 ships completed the questionnaire, as the CIC covered all targeted ships within the Paris MoU Region during the specified timeframe. However, in cases of multiple inspections on the same vessel, only one CIC report was required per ship.
The 10 questions of the CIC questionnaire
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Is the seafarer given a SEA signed by both the seafarer and the shipowner or a representative of the shipowner?
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Is the seafarer able to access information regarding their employment conditions on board?
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Are standard form of seafarers’ employment agreements and parts of any applicable collective bargaining agreements subject to port State control under Reg.5.2, available in English?
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Does the seafarers’ employment agreement include all the required elements specified in the MLC, 2006?
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Do particulars included in the seafarers’ employment agreement comply with the MLC, 2006 requirements?
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Are wage or salary payments made to the seafarer at no greater than monthly intervals?
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Have seafarers been given a status of accounts and wages paid on at least a monthly basis?
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Are wage or salary payments in accordance with any applicable CBA or SEA?
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If payments made to a seafarer include deductions, are they in accordance to the MLC, 2006?
10A. Is a certificate or documentary evidence of financial security, issued by the financial security provider, available on board in the event of compensation for death and long-term disability?
10B. Is a certificate or documentary evidence of financial security, issued by the financial security provider, available on board in the event of the repatriation?
Key points of the CIC:
- The highest compliance was observed in relation to Question 6 of the CIC Questionnaire, relating to whether the wage or salary payments were made to the seafarer at no greater than monthly intervals, where 99.7% responded ‘yes’. The second highest compliance was relating to Question 7 on whether the seafarers have been given a status of accounts and wages paid on at least a monthly basis, where 99.3% responded ‘yes’. Notably, even if the compliance for both questions was high it resulted in 7 detentions.
- There was a high compliance rate averaging 98.7% in general.
- The least compliance was noted concerning Question 4, whether the seafarers’ employment agreement include all the required elements specified in the MLC, 2006, where 2.8% responded ‘no’. The second least compliance was relating to Question 2 on whether the seafarer is able to access information regarding their employment conditions on board, where 2.7% responded ‘no’.
- The overall detention rate based on total CIC inspections was 0.78%.
- 30 vessels with deficiencies marked as grounds for detention were in the Standard Risk category.
- By ship type, as in previous years, General cargo/multipurpose ships has highest CIC-topic detention rate (57.1%) followed by bulk carrier (19%) and oil tanker (9.5%).
- Similar to previous CICs, ship age <6 years had 0% detention rate for CIC-topic detentions, while the highest rate was for ships 25-30 years (26.8%).
- The flag State with highest number of CIC related deficiencies was Liberia (81 corresponding to 14,9% of the total number of deficiencies) followed by Marshall Islands (74 / 13,6%), Panama (68 / 12,5%) and Malta (54 / 9,9%).
- Ships with CIC related grounds for detention, the highest number of detentions, by flag State, was Panama (7 corresponding to 23,3% of the total number of detentions) followed closely by Tanzania, United Republic of (6 / 20%), Liberia and Malta with (5 / 16,7%) each.
- The Flag administrations which had CIC topic detentions were a mix of White, Grey, Black and not listed in the Paris MOU WGB list. Therefore no trend could be discerned.
- Only one CIC related deficiency was recorded as RO related on Certificate or Documentary evidence of financial security relating to shipowners’ liability on a Tanzanian General cargo/multipurpose of more than 37 years old. Due to this small number and in order to make the report more readable, the columns on RO related have been deleted in every table.
Analysis of answers to questionnaire in relation to detention
- Question 1 – Is the seafarer given a SEA signed by both the seafarer and the shipowner or a representative of the shipowner, had the third highest number of “no” answers (72) although highest number of detentions (6).
- Question 4 – Does the seafarers’ employment agreement include all the required elements specified in the MLC, 2006, had the highest number of “no” answers (107) and also had a high number of detentions (4).
- Question 6 – Are wage or salary payments made to the seafarer at no greater than monthly intervals, show a high compliance of 99.7%, however it results to 4 detentions.
Analysis of CIC-topic related deficiencies, including ISM related deficiencies
The data extract for this report did not specify which deficiencies were ISM related. The focus on the particular areas of the CIC results into an increase of number of deficiencies recorded against MLC, 2006 requirements for all areas covered by the questionnaire compared to the same period in 2023.
One possible cause of that result is that verification of SEAs compliance to MLC, 2006 provisions is not required during an initial inspection, but if clear grounds are established, during a more detailed inspection and systematically during an expanded inspection.
Number of inspected ships and detentions per ship type
General Cargo/multipurpose ships had the highest number of CIC related deficiencies and CIC related deficiencies recorded as grounds for detention (252/24) followed by bulk carriers (177/8).
Inspections and detentions per Flag State
The flag State with highest number of CIC related deficiencies was Liberia (81 corresponding to 14,9% of the total number of deficiencies) followed by Marshall Islands (74 / 13,6%), Panama (68 / 12,5%) and Malta (54 / 9,9%). Ships with CIC related grounds for detention highest numbers were Panama (7 corresponding to 23,3% of the total number of detentions) followed by Tanzania (6 / 13,6%), Liberia and Malta with (5 / 16,7%) each.
No trend could be discerned for the Flag State performance which had CIC related deficiencies or detentions as they were made up of a combination of White, Grey, Black on the PMOU WGB list. Nor could any trend be discerned as to whether or not the MLC, 2006 has been ratified or not by the Flag State.
Ship age overview
Based on the CIC’s related deficiencies the ship age group with the highest number of deficiencies was 13-18 years.
According to the Paris MoU, the results show a good level of compliance in general. However, the significant difference on number of deficiencies between 2023 and 2024 for almost every question and particularly for those related to SEAs should be taken into consideration.
It is therefore recommended that the industry pay greater attention to compliance with the requirements of the MLC, 2006 when establishing seafarers’ employment contracts.
