Letter Text:

Your editorial to issue No. 25 on the topic of “Fatigue” was interesting.¬† Not in only its content but more importantly in what it did not include.

I refer to the minimum manning certificate issued by flag state. This needs urgent attention.

As an example, a particular coastal vessel has a minimum manning certificate requiring 1, Master; 1 Officer of the Watch (OOW), 1 Engineer, 2 AB’s and 1 cook/AB.¬† Total: 6 crew members.

The Master and OOW work six hours on, six hours off.¬†¬† The engineer works day work, (providing all is well on board). ¬†The two AB’s allegedly keep a watch during the hours of darkness and as much day work as possible, not forgetting deck work¬† for arrival, sailing and cargo work in port.

The two AB’s are assisted by the cook/AB when he is not on duty cooking and running the catering side of the ship.

On this class of ship, most Masters and Officers of the Watch are required to hold pilotage exemptions for the main ports that they trade to.

All in all, one has to ask the question “Is it any wonder that ships watch keepers fall asleep?”

Flag state and local port state control have to be held responsible for such ludicrous manning compositions.  Can Port state control step in and hold a ship in detention if they consider that the manning composition is considered unsafe?  I would argue, yes they can. If the manning composition is such that fatigue is the end result of the level of manning, then the ship is unsafe and can and should be detained.  The ship should, in my opinion, also be detained if it is shown that the records of rest hours have been falsely recorded.


In the Editorials, we are constrained by space on how deeply and widely we can address issues.  In the Editorial in the previous issue of Maritime FEEDBACK, we did not attempt to cover the subject of manning levels.  Nevertheless, there is indeed an issue with manning levels, particularly on small cargo vessels trading in Europe on which the navigation watches are shared between the Master and one Mate.  The Marine Accident Investigation Branch has flagged this, and the Maritime and Coastguard Agency has raised the issue at the International Maritime Organisation.  However, there was strong resistance from a number of states to changing the convention requirements.

Scrutiny of records of hours of rest after some accidents with these vessels have demonstrated that there may well have been non-compliance with the regulations. In February 2010, the MCA announced a clamp-down on ships that are flouting hours of rest requirements.¬† Ships operating busy schedules with small crews will be targeted.¬† As well as hours of rest, surveyors will also be checking for compliance with the requirement for a dedicated look-out at night.¬† The MCA will also be looking for evidence of the company’s audit of records.¬† More information on this can be found on the MCA website in the February Press Releases.

We will be following with keen interest the progress of Project Horizon, a 30 months project which started in June 2009. It is researching the effects of fatigue on the cognitive performance of maritime watch-keepers under different watch patterns, using ship’s bridge, engine and liquid cargo handling simulators. Further information can be found on www.project-horizon.eu .

In the CHIRP Editorial, we encouraged mariners to report any concerns regarding fatigue. If you wish to report a concern in absolute confidence, please do contact us. We will discuss with you how best to progress the matter without your identity being disclosed.