STCW Code - Crew Fitness for Duty

The Australian Maritime Safety Authority (AMSA) has recently published Marine Notice No. 18 of 2010 concerning “Fitness for Duty”. The notice has been issued following a period of enhanced focus by Port State Control Officers (PSCOs) on compliance with the hours of rest requirements set out in the Standards of Training, Certification and Watchkeeping (STCW) Code. PSCOs in Australia have been checking vessels’ hours of work/rest records and other documentation to determine whether or not they are accurate. The exercise has resulted in the identification of deficiencies due to unsatisfactory record-keeping, and in some cases vessels have been detained. Masters are therefore reminded of their obligations to ensure that the watchkeeping arrangements on board and hours of work/rest records comply with statutory requirements at all times.

The STCW Code allows for rest periods to be reduced to below the specified minimum in certain circumstances; in an emergency, when conducting emergency drills and for “overriding operational conditions”. It appears that some operators and Masters have been interpreting “overriding operational conditions” incorrectly, applying this provision to any operation resulting in hours of rest being reduced to below the statutory minimum. AMSA’s notice states that it does not consider “overriding operational conditions” to include activities associated with the normal activities of a vessel, such as arriving and departing port and cargo operations.

AMSA is not the only governmental agency concerned with crew members not receiving their required hours of rest. Earlier this year the United Kingdom (UK) Maritime and Coastguard Agency (MCA) issued a press release drawing attention to MCA action regarding unsafe manning levels. Vessels operating on intensive schedules with small crews are being singled out for particularly close scrutiny. PSCOs in the UK are examining posted watchkeeping schedules and are checking hours of work/rest records against trading patterns to verify their accuracy. Checks are also being made to ascertain whether vessels are posting a dedicated lookout on the bridge during the hours of darkness. Breaches of regulatory requirements will result in deficiencies being raised and, depending on the severity of the offence, may lead to a detention. Significant violations may result in prosecution. The MCA is also checking that companies operating UK flag vessels are monitoring the work/rest records of their fleet when carrying out ISM Code audits ashore.

In order to be certain that crew members are suitably rested and operations comply with the requirements of the STCW and ISM Codes, Members are advised to ensure that:

• Watchkeeping schedules are posted and reflect the actual watchkeeping arrangements onboard.
• Records of hours of work and rest are completed accurately.
• Crew members are adequately rested prior to departure and first watch following a port call.
• Records of hours of work and rest are examined during internal audits to confirm that the personnel onboard are receiving sufficient rest in accordance with STCW Code requirements.
• Hours of rest are not being reduced to below the statutory minimum by applying the “overriding operational conditions” provision to routine operations.

 Members requiring any further information should contact the Loss Prevention Department.