Here for simplicity reasons a summary is presented to outline the issue as follows:
Key Problems on Work and Rest Hours as follows :
- Inconsistency between work & Rest Hours in MLC and STCW : despite regulations permitting a 91 hour work week, MLC states max 72 hours of work ! What happens with the 19 hour of remaining balance ?
- Master's Overriding Authority included in identical statements in MLC and STCW need implementation guidance (e.g. when this may be implemented, record keeping, implications etc.)
- STCW Exceptions are NOT properly defined for implementation (STCW A-VIII/1, para 9, 77 to 70 hours and Max 2 rest periods to 3 rest periods namely)
Best Practices that may be used to overcome these problems as follows:
- Ensure proper working and living conditions onboard with adequate manning of the vessels to ensure workloads are properly met and implemented.
- Set, Define and strictly register Officially REST or WORK hours ONLY !
- Ensure proper guidance is provided with respect to record keeping and ensure that ALL crew is NOT working MORE than 91 hours in any given 7-day or week to make it more simple
- Ensure Seafarer Employment Agreements do NOT violate the max of 91 hours per week work and that the total work and overtime provided by the crew is in line with that
- Employ Software to monitor Rest hours and ask copies of completed records for review at the office and provide tips and feedback to the vessels
- Provide guidance for the implementation of Master's Overriding Authority (relevant entry should be made in the ship's log book, conditions to be defined etc.). In any such case office to be notified of all such cases and provide feedback to vessels
- Regarding STCW exceptions check if vessel's flag allows for the 77 hours to shift to 70 hours and provide exact guidance and worked examples for recordkeeping
- Suggest Masters to make an entry into log book for the split of rest periods to 3 MAX per 24 hours a minimum of 24 hours in advance of a scheduled drill period. This will minimise the technical deficiencies observed in the rest hours record keeping at the date of the drill (normally Saturday) including the full 72 hour period including the days before and after the drill.
The KPIs that may be set, used and monitored proactively may include any of the following:
- Weekly REST Hours (Best above 77 per week)
- Weekly WORK Hours (Best below 91 hours per week)
- Average Manning of vessels of same Size (set by vessel size)
- Monitor Number of Violations of Rest Hours Regulations (min/max allowed, brakes etc.) (Best above 1-2 cases per month per vessel).
Required KPI range may depend on a number of issues, examples are provided above. Furthermore analysis and benchmarking of each KPI may be presented fleet and company wide on a routine quarterly and annual period basis.
As we progress towards MLC implementation it will become evident that the option to implement a KPI set will be a one way street towards continual improvement and Safety and Environmental Excellence!
By Apostolos Belokas, Managing Editor, SAFETY4SEA
About Apostolos Belokas
Apostolos is a Maritime Safety, Quality & Environmental Expert, Consultant, Trainer and Project Manager with more than a 20-year background in shipping as Technical, Marine, Safety & Training Superintendent and Consultant. He entered the industry back in early 90’s as Engineering Superintendent with a leading ship manager operating a mixed fleet of bulk and oil/chemical tankers. He then shifted to regulatory compliance and QHSE as superintendent and later as a Consultant and Trainer. Apostolos has successfully completed a wide range of QHSE projects including 250+ management system projects (ISM/ISO 9001-14001-18001/TMSA/MLC), 500 vessel and office audits to various standards and he has trained more than 8,000 people in a wide variety of QHSE subjects. He has also presented and chaired to more than 40 conferences. He holds Mechanical Engineering Bachelor and Master’s specialising in Energy & Environment and Master’s Degree in Maritime Business and Business Administration (MBA), all of them awarded with distinction. Apostolos is the Managing Director of SQE MARINE, SQE ACADEMY and Managing Editor of SAFETY4SEA.