Confidential Human Factors

Incident Reporting Programme

M2740

Single Column View
Health and sanitation concerns on board

Concerns have been raised regarding health and sanitation conditions on board the vessel. The Ship Sanitation Control Exemption Certificate was recently renewed; however, it is understood that only the certificate was issued, with no accompanying inspection details or supporting documentation made available.

An apparent infestation has been observed on board. Photographic evidence is available, although it cannot be shared through this reporting channel.

During the last port call, this matter was reportedly recorded as a deficiency by Port State Control. However, it appears that the issue was not addressed at that time and was instead deferred to the next port, which involves an approximate three-week passage. The Designated Person Ashore (DPA) is understood to be aware of the situation.

In addition, the water used for cooking and daily consumption has been observed to be discoloured (yellowish), which may raise concerns regarding its suitability for use. Supporting evidence relating to the water condition is available.

These conditions may be having an adverse impact on the health and well-being of those on board.

This report identifies serious deficiencies that fall within the scope of the International Labour Organisation Maritime Labour Convention (MLC, 2006), specifically Title 3 Accommodation, Recreational Facilities, Food and Catering. The conditions described represent not only potential non-compliance with MLC requirements but also a broader failure in the effective implementation of safety and health protections on board.

The Standard requires that seafarer accommodation be maintained in a safe, decent, and sanitary condition. The presence of an onboard infestation is a clear indicator that basic hygiene management and pest control measures have not been effectively implemented or sustained. This cannot reasonably be attributed to isolated oversight and instead points to deficiencies in both onboard management and shore-based support systems.

The Standard also requires the provision of safe and adequate drinking water. Reports of discoloured (yellow) water being used for cooking and daily consumption represent a direct and unacceptable risk to crew health. Such conditions suggest failures in water storage, treatment, monitoring, and verification processes. The continued use of this water indicates that either the risk was not properly assessed or the identified concerns were not acted upon with the required urgency.

A key concern raised by this report is the apparent gap between identifying deficiencies and effectively resolving them. Recording deficiencies and then closing them without verified corrective action undermines the integrity of safety management systems. It creates a false illusion of compliance while allowing hazardous conditions to persist. This reflects a systemic weakness in which procedural completion is prioritised over the elimination of actual risk.

More critically, this case demonstrates a failure to act on a known hazard. Credible concerns regarding infestation and potable water quality do not appear to have triggered timely or effective intervention by the shipowner/operator. Nor is there evidence of robust follow-up through Flag State oversight or Port State Control. Allowing a vessel to continue operating under such conditions represents a significant breakdown across multiple layers of assurance and enforcement.

The report also raises concerns regarding crew confidence in reporting mechanisms. Perceived lack of confidentiality and fear of exposure can discourage the reporting of health and safety issues, delaying intervention and increasing risk. Over time, this contributes to the normalisation of substandard conditions, where issues such as infestation may come to be viewed as routine rather than unacceptable. Such normalisation is often reinforced by commercial pressures and concerns over potential repercussions, and it poses a direct threat to safety culture.

Within this context, the role of the Designated Person Ashore (DPA) is central. The ISM Code requires the DPA to function as an effective and independent link between ship and shore, with the authority to ensure that safety concerns are addressed. In this case, the absence of effective intervention raises serious questions about whether the DPA role is being exercised as intended. A DPA function that does not result in timely escalation and corrective action risks becoming administrative rather than operational, undermining the purpose of the safety management system.

Where credible reports of infestation and unsafe potable water exist, escalation to the Flag State administration and, where appropriate, Port State Control should be immediate. These mechanisms exist to provide independent verification and enforcement, and failure to engage them in a timely manner allows unacceptable conditions to persist unchecked.

While the issues identified are serious, the act of reporting itself is a positive indicator. Increased willingness among crew to raise such concerns suggests a gradual shift towards greater transparency. However, this progress will only be sustained if reporting leads to visible, effective, and timely corrective action. Without this, there is a risk that confidence in reporting systems will erode, reinforcing the very conditions that allowed these deficiencies to develop.

 

Factors relating to this report

Communication – is evident in the gap between identifying the problem and resolving it. Although the issue was known (PSC and DPA), the lack of inspection detail and corrective action indicates that critical safety information was not effectively shared or acted upon.

Complacency – may be present in the continued operation despite known infestation and water concerns. Deferring action suggests acceptance of degraded conditions, possibly influenced by past experience of operating without immediate consequences.

Lack of assertiveness – is suggested by the persistence of the issue. While escalation was reported, it may not have been sufficient to prompt timely intervention, particularly given the health risks.

Pressure – likely operational or commercial, appears to have influenced decisions. Deferring rectification to a later port suggests that schedule or cost considerations outweighed immediate risk mitigation.

Lack of resources – may have contributed to the failure to address the issues at the time of identification, including limitations in time, equipment, or access to contractors.

Lack of leadership – is indicated by the absence of effective action despite shore-side awareness, suggesting insufficient prioritisation or follow-through on a known welfare issue.

Lack of awareness – may also be a factor, particularly regarding the health risks of prolonged exposure to contaminated water and infestation, which may not have been fully appreciated.

Norms – appear relevant, as deferring defects and continuing operations in degraded conditions may reflect an accepted but informal practice.

Key Takeaways

Regulators – “If you don’t verify it, you don’t control it.” When certification is treated as a formality rather than a verification process, assurance is weakened, and risk is displaced rather than controlled.

Managers – “What you allow today becomes the standard tomorrow.” Deferring known health hazards to maintain the schedule can unintentionally signal that safety is negotiable, reinforcing normalisation of degraded conditions across the system.

Seafarers – “Raising it once is reporting—seeing it through is safeguarding.”
Reporting concerns is essential, but persistent follow-up and escalation are equally important when conditions continue to pose a risk to health and safety.