Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
M2163
Initial Report
A shore-based contractor who often embarks on ships for sea trials contacted CHIRP with concerns that their working routines were leading to them becoming fatigued, and they were anxious that this could result in a safety incident or accident. At sea they regularly worked 12-hour days, sometimes switching between day and night shifts mid-trial. Sea trials typically lasted for 2-3 weeks with no rest days (except when they switched from day to night shift), and fatigue has been a factor.
The reporter asked CHIRP to advise on safe working limits in such circumstances, so that they could have an informed conversation with their employer.
CHIRP Comment
The Maritime Labour Convention defines a seafarer as:
“Any person, including a master, who is employed, or engaged, or works in any capacity on board a ship and whose normal place of work is on a ship.”
Under the Convention, seafarers are entitled to a minimum of 77 hours of rest in any 7-day period and at least 10 hours of rest within any 24-hour period. The schedule of working hours must be recorded and posted for all seafarers to see.
If a personās normal workplace is ashore, they are categorised as a ‘worker’ and their working hours are regulated by the vesselās Flag State or local regulations. These commonly (but not always) limit the working week to an average of 48 hours, with the working day an average of 8 hours, with one day a week as a rest day.
The contractorsā employer is responsible for the health, safety and wellbeing of their employees and should set working limits accordingly. However it is good practice for masters to ask for copies of the contractorsā fatigue management plans so that they can satisfy themselves that their working routines have properly taken fatigue into account. Ultimately, masters are responsible for the safety of all persons on board and have the authority to grant additional rest periods to ensure that the hazard of fatigue has been controlled to a level that is āas low as reasonably practicableā.
Other practical steps include the buddy-buddy system where pairs of workers monitor each other for signs of fatigue and bring this to their partnerās attention. Scheduled rest days at regular intervals and shorter shifts can also help mitigate fatigue-related risks.
CHIRP is pleased to report that in this case, the employer listened to the reporterās concerns and took action to address their fatigue concerns.
Key Issues relating to this report
Alerting- Alerting the company to high workloads is an essential first step in solving fatigue issues for shore contractors. Does your company empower you to report fatigue concerns, and are you aware of their reporting procedure?
Culture– Employers of shore contractors should have wellbeing policies and fatigue management plans. Masters are strongly encouraged to ask for sight of these when embarking contractors.
Local practices- The buddy-buddy system is a useful tool to spot the early signs of fatigue. This is most beneficial when crew and workers are empowered to report such concerns, and there are well-understood procedures in place to do so.