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Unsatisfactory compliance with hours of rest

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Richard Schiferli

Richard Schiferli

Preliminary results from the Concentrated Inspection Campaign (CIC) on STCW Hours of Rest, carried out between 1 September 2014 and 30 November 2014 in the Paris MoU region show that:

16 ships (14% of detentions during CIC) were detained over the 3 month
period as a direct result of the CIC for deficiencies related to hours of rest.
Main areas of concern are hours of rest not being recorded properly and
watchkeeping personnel without sufficient rest.

In recent years there has been a growing concern regarding hours of rest for
watchkeeping personnel. Supported by PSC inspection results and a number of
incidents, the Paris and Tokyo MoU, as well as other MoUs, decided to organize a joint campaign to verify a list of 10 selected items against the STCW requirements.

The CIC questionnaire was completed during 4, 041 inspections. A total of 912
CIC-related deficiencies were recorded and 16 ships (14% of the detentions) were
detained as a direct result of the CIC during the 3 month period.
Secretary General Richard Schiferli expressed serious concerns: “Insufficient rest
of watchkeeping personnel has already caused several incidents over the past
years. It may be the cause of fatigue, which can have major consequences for
safety and the environment. 2 watch systems are particularly vulnerable in this

During the campaign most inspections concerned general cargo/multi-purpose
ships with 1, 207 (30%) inspections, followed by bulk carriers with 948 (23%)
inspections, container ships with 407 (11%) inspections, chemical tankers with 375
(9%) inspections and oil tankers with 325 (8%) inspections.
11 (70%) of the detained ships were general cargo/multipurpose ships, 3 (19%)
were bulk carriers, 1 container ship and 1 other ship type.

Analysis of the recorded deficiencies shows that most deficiencies relate to hours of rest not being recorded correctly in 449 cases (11%), watchkeeping personnel did not have sufficient rest in 203 cases (5%) and bridge lookout not maintained in

101 cases (3%). A total of 21 inspections revealed that the manning level was not
in accordance with the Minimum Safe Manning Document.
The flag with the highest number of CIC-topic related detentions was Moldova with
3 CIC-topic related detentions.
The inspections showed that a total of 1268 ships were operating with a 2 watch
system for the navigational watch and 13 of these ships were detained..

The CIC was a joint campaign with the Tokyo MoU. Others co-operating MoUs
have followed the same routine during the campaign.
The detailed results of the campaign will be further analysed and findings will be
presented to the 48th meeting of the Port State Control Committee in May 2015,
after which the report will be submitted to the International Maritime Organization.

Regional Port State Control was initiated in 1982 when fourteen European countries agreed to coordinate
their port State inspection effort under a voluntary agreement known as the Paris
Memorandum of Understanding on Port State Control (Paris MOU). Currently 27 countries are
member of the Paris MOU. The European Commission, although not a signatory to the Paris MOU,
is also a member of the Committee.

The Paris MoU is supported by a central database THETIS hosted and operated by the European
Maritime Safety Agency in Lisbon. Inspection results are available for search and daily updating by
MoU Members. Inspection results can be consulted on the Paris MoU public website and are
published on the Equasis public website.
The Secretariat of the MoU is provided by the Netherlands Ministry of Infrastructure and the
Environment and located in The Hague.

Port State Control is a check on visiting foreign ships to verify their compliance with international
rules on safety, pollution prevention and seafarers living and working conditions. It is a means of
enforcing compliance in cases where the owner and flag State have failed in their responsibility to
implement or ensure compliance. The port State can require defects to be put right, and detain the
ship for this purpose if necessary. It is therefore also a port State’s defence against visiting
substandard shipping

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