Hours of Work and Rest – 01 May 2022 to 17 June 2022
AMSA conducted an Hours of Work and Rest Focused Inspection Campaign (FIC) over the period 01 May 2022 to 17 June 2022.
The campaign focused on:
a. the level of compliance with the maximum hours of work/minimum hours of rest for seafarers in accordance with the requirements of International Conventions, and
b. the familiarity of the master and officers with implementing the provisions when working onboard ships.
In conjunction with a standard port State control (PSC) and flag State control (FSC) inspection, specific questions relating to Hours to Work and Rest were asked by the AMSA inspectors. These questions, and a Marine Notice announcing the campaign, were promulgated on AMSA’s website prior to commencement of the FIC.
The campaign was conducted as a core part of AMSA’s Compliance Plan for 2021/22. The FIC was scheduled for two months commencing on 1 May 2022. AMSA ceased the campaign on 17 June 2022 as the target inspection level of 200 inspections was reached. During the inspection period a total of 282 inspections were recorded (22 inspections were recorded after 17 June 2022).
Results
The FIC results showed general compliance with the work/rest requirements. The results were as follows:
a. 281 ships were inspected during the FIC (one ship having the FIC carried out twice in this period);
b. From those initial inspections, 27 ships were detained during the period of the FIC campaign, two of which were directly attributed to this FIC. This shows 7.4% of all detentions during the FIC campaign related to the Hours of Work and Rest FIC topic
Key results of the FIC included:
a. A vast majority of inspections conducted during this FIC resulted in no deficiencies related to this FIC;
b. Even though the COVID-19 pandemic is well into its third year, ship owners are still making seafarers stay on board for more than 11 months (continuous service), as evidenced by 13 affirmative answers to question 4 - Do any seafarers have periods of shipboard employment exceeding 11 months?
c. The most compliant results were found for:
d. The majority of ships conducting drills in a manner as to not fatigue crew, and
e. Nearly all ships are posting their table of shipboard arrangements
The most positive results were:
a. Table of shipboard working arrangement available (99%), and
b. Drills have been conducted in a manner that minimizes the disturbance of rest periods and does not induce fatigue? (98%).
Our continued focus
AMSA has promulgated educational guidance and a marine notice relating to Hours or Work and Rest and fatigue management. Ship operators, Masters and crew are strongly encouraged to review these documents and take steps to improve compliance with resting hours. This information can be found on the AMSA Website:
- Maritime Safety Awareness Bulletin Issue 15 – hours of work and rest
- Marine Notice 14/2017 - Fitness for Duty
- Marine Notice 17/2016 - Maximum period of shipboard service for seafarers
(Effective implementation of MLC (2006) requirements, with regards to working hours, may help to reduce fatigue amongst seafarers. AMSA will continue to focus on fatigue and working records when ships visit Australian ports).
As a result of this campaign, AMSA intends to:
- Continue to focus attention on rest hours, and,
- Continue our focus crew who have served on board continuously for more than 11 months
Hours of Work and Rest FIC Results
| Question | Yes | Yes% | No | No% | N/A | N/A% |
|---|---|---|---|---|---|---|
| Is a table of shipboard working arrangements posted for seafarers accessible? | 281 | 99% | 0 | 0% | 1 | 1% |
| Does the table of shipboard working arrangements ensure that the first watch at the commencement of the voyage and subsequent relieving watches are sufficiently rested and otherwise fit for duty? | 278 | 98% | 2 | 1% | 2 | 1% |
| Do records of the daily hours of work or rest show compliance with the actual hours of work and rest hours, including the requirements for rest breaks? | 253 | 90% | 26 | 9% | 3 | 1% |
| Do any seafarers have periods of shipboard employment exceeding 11 months? | 13 | 5% | 267 | 94% | 2 | 1% |
| Has adequate compensatory rest been given to seafarers who have had their rest disturbed by callouts to work? (e.g. such as when a machinery space is unattended) | 218 | 77% | 3 | 1% | 61 | 22% |
| Has the master suspended the schedule of hours of work or hours of rest, with in the last 3 months, and required any seafarer to perform any hours of work necessary until the normal situation has been restored? | 11 | 4% | 200 | 71% | 71 | 25% |
| Have musters, firefighting and lifeboat drills, and drills prescribed by national laws and regulations and by international instruments, been conducted in a manner that minimizes the disturbance of rest periods and does not induce fatigue? | 279 | 98% | 1 | 1% | 2 | 1% |
| Where non-compliance with the work and rest hours has been recorded, has the Safety Management System corrective action process (ISMC 9) been used to rectify non-conformance by determining the cause and preventing recurrence? | 22 | 8% | 15 | 5% | 245 | 87% |
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