SAFETY4SEA SEAFiT - Issue 01

13 ISSUE 01 | Q1 2023 READY FOR YOUR INBOX Using a mobile-friendly format we make sure that we leave no subscriber out of the communication loop, by reviewing all available sources worldwide and delivering to our audience what is of real value. Join our 35,000 subscribers! s a f e t y 4 s e a . c o m / s u b s c r i b e Subscribe to our newsletters SUBSCRIBE • Noon Report (daily) • Morning Fix (daily) • Regulatory Update (monthly) • Safety Roundup (monthly) • Green Roundup (monthly) • Smart Roundup (monthly) • Events, Surveys & Projects STAY SAFE STAY UPDATED A R T I C L E with the work period issue that accord- ing to a 77 hours rest week leaving 91 hours work week (7x24 - 77 = 91). Another problem is that Master’s Over- riding Authority, included in identical statements in MLC and STCW, needs implementation guidance (eg when this may be implemented, record keeping, implications etc.) and STCW Excep- tions are not properly defined for imple - mentation (STCW A-VIII/1, para 9, 77 to 70 hours and Max 2 rest periods to 3 rest periods namely). The consequences of non-compli- ance with MLC, 2006 are evident from the number of inspections and deten- tions recorded authorized by port state controls (PSC) regarding deficiencies related to MLC, 2006. The most com- mon grounds for detention are: ●● Records of rest (STCW) ●● Seafarers’ Employment Agreement (SEA) ●● Fitness for duty – work and rest hours ●● Manning specified by the minimum safe manning document (STCW) Best Practices for wise calculations 1. Ensure proper working and living conditions onboard with adequate manning of the vessels to ensure workloads are properly met. 2. Set, define and strictly register of - ficially rest or work hours only (rest hours are suggested). 3. Ensure proper guidance is provided with respect to record keeping and that all crew is not working more than 91 hours in any given 7-day to make it more simple. 4. Ensure Seafarer Employment Agreements (SEAs) 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. 5. Employ software to monitor rest hours, ask copies of completed records for review at the office and provide tips and feedback to the vessels. 6. Provide guidance for the implemen- tation of Master’s Overriding Author- ity (relevant entry should be made in the ship’s log book, conditions to be defined etc.). In any such case, office should be notified and provide feedback to vessels. 7. Regarding STCW exceptions, check if vessel’s flag allows for the 77 hours work to shift to 70 hours and provide exact guidance and exam- ples for recordkeeping. 8. 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 minimize the technical deficiencies observed in the rest hours record keeping at the date of the drill. Key considerations to move forward Accident statistics show a strong association with factors that increase the risk of fatigue, such as under manning and long working hours. Seafarers fatigue is an occupational health and safety issue that is com- mon and widespread. The MARTHA Fatigue Report revealed that fatigue has safety and long-term physical and mental health implications and long tours of duty (over 6 months) may lead to increased sleepiness, loss of sleep quality, reduced motivation which could contribute to ‘near-misses’ and ac- cidents onboard. According to the report, night watch keepers are most at risk from falling asleep on duty, while captains feel stressed and fatigued at the end of their tours of duty and need recovery time. Simple operational solutions can ensure sleep is easier for those on- board through an effective fatigue risk management.