10 hours rest in each 24-hour period
Proposal for consideration: All masters and crew working on domestic commercial vessels (DCVs) to have at least 10 hours rest in each 24-hour period.
Changing hours of rest isn't part of the current list of proposed changes to MO504. We want more input from industry to understand current arrangements and the benefits and challenges of expanding existing rest requirements.
Currently MO504 requires the master and each crew member to have at least 10 hours rest in each 24-hour period if the vessel is operating with minimum crewing.
We are now seeking your views on expanding this requirement to all masters and crew.
Operators can decide whether the minimum of 10 hours rest in each 24-hour period is:
- continuous (10 hours straight) (AMSA's recommendation)
- cumulative (made up of a number of shorter rest periods).
'Rest' is defined as a period of time when a person is, except in the case of emergency, free of all duties and functions (definition in the current version of MO504).
Why are we seeking your views?
Survey findings and feedback from industry have indicated that more needs to be done to address the risks of master and crew fatigue in the DCV industry.
In 2022, AMSA published the results of a 2019 survey on fatigue awareness in the DCV industry.
Findings from the survey:
- 40% of respondents got less than 6 hours sleep in any 24-hour period when out at sea
- 25% of respondents stated they experienced fatigue ‘very often’ or ‘most of the time’ either ‘immediately before’ or ‘during’ their time at sea
- 50% of respondents indicated that they had either ‘not received’ any fatigue management training or guidance or they were ‘unsure’.
We also received feedback during the last MO504 consultation in 2022-23 that AMSA should consider further strengthening requirements to address the risk of fatigue. This feedback aligns with more recent calls for action from DCV operators, masters, crew, industry unions and peak bodies.
Have your say
In particular, we would like to know:
- How do you ensure adequate rest for your masters and crew?
- If you provide each master and crew member with less than 10 hours of rest in each 24-hour period, why is this? What barriers do you face in providing the additional hours of rest?
What happens next?
We will review the feedback received to inform future policy decisions.