United Kingdom Issues New Regulations on Minimum Safe Manning
The U.K. Maritime and Coastguard Agency (MCA) has released new regulations aimed at bringing U.K.-registered ships and all vessels operating in British territorial waters into compliance with IMO regulations on manning levels. The new MCA regulations, released in the form of a Merchant Shipping Notice (MSN), reiterate the safe manning requirements in the STCW Convention and Code, as well as in the STCW regulations that entered into force at the beginning of 2015. The new STCW regulations incorporate IMO Resolution A1047 (27) on the Principles of Safe Manning.
Under its new regulations, the MCA now requires all U.K. seagoing vessels of 500 GT or more to hold a Safe Manning Document specifying minimum manning levels. In preparing a proposal for the minimum safe manning level of a ship, the owner or operator must:
— assess the tasks, duties and responsibilities of the ship’s crew required for safe operation, protection of the marine environment and dealing with emergency situations, including the evacuation of passengers where applicable;
— assess the numbers and grades and/or abilities of crew required for safe manning;
— ensure that the manning level is adequate at all times;
— submit a new proposal in case of changes in trading area(s), operations, construction, machinery, equipment or operation and maintenance.
In conjunction with these factors, the owner or operator must ensure that personnel do not work more hours than is safe by:
— identifying all the functions to be undertaken onboard during a representative voyage or operational period, including determination of the number of personnel required to undertake the relevant tasks and duties under both peak and routine workload conditions;
— identifying functions that constitute normal operations and determining the minimum number of personnel required to undertake concurrent tasks and duties safely;
— identifying the skills and experience required to perform those functions;
— ensuring working arrangements allow for sufficient rest periods to avoid fatigue, drawing up work schedules accordingly.
Under the new MCA regulations, changes must not be made to the schedule unless they can be justified by substantially altered work patterns made necessary, for example, by a change in trading pattern, operation or other significant factor.
The schedule and safe manning level must also take into consideration the number of qualified and other personnel required to meet peak workload situations and conditions, with regards to the number of hours of shipboard duties and rest periods.
Once agreed, the owner or operator is obliged to ensure that, as far as is reasonably practicable, the minimum safe manning level is maintained and that operations are in compliance with the Hours of Work Regulations.
A copy of the agreed schedule must be displayed prominently in the crew accommodation onboard the vessel. Records of seafarers’ daily hours of rest must be maintained. This record must be in an appropriate place and available for MCA inspection.
If, on inspection, the records or other evidence indicates that manning levels are so low as to require the working of hours which exceed the permitted levels or the taking of insufficient hours of rest, the MCA will require that manning levels be adjusted so that the ship can be operated safely within the permitted hours available.
Checking of a ship’s documentation will be carried out by the MCA as part of the normal routine of inspecting vessels and will include a check that records are being maintained and that the appropriate schedules are posted. Following examination, the records will be endorsed as part of the examination process.
“Fatigue and manning are clearly interrelated,” says MM&P Pilots Group Vice President George Quick, who serves as the MM&P representative to the International Transport Workers’ Federation (ITF) delegation to the IMO.
“The key to implementation and enforcement lies in having a transparent methodology to establish manning levels, along with the requirement that documentation of that methodology and the factors taken into account be carried aboard ship for port state control monitoring and enforcement.”
The three organizations that represent officers aboard U.S.-flag ships—MM&P, MEBA and AMO—jointly sent a letter to the Coast Guard in January calling the agency’s attention to the fact that new IMO regulations changing the methodology for establishing manning levels had gone into effect and asking for a meeting to discuss steps needed to conform U.S. regulations to the new IMO requirements. As yet, there has been no meeting scheduled by the USCG to discuss this important issue.