07 December 2017 |  C17051

To simplify the correct application of MLC Regulation 2.3 on work and rest hours and in order to prevent any non-conformities raised on board Cook Islands vessels, a new MLC Work Rest Tool (WR Tool) has been issued by the Administration that allows ship owners to monitor the application of the regulation.

NOTICE TO
Ship Owners / Managers / Operators | Surveyors

For the application of MLC standards, you shall take into consideration the danger posed by the fatigue of seafarers, especially those carrying out duties that involve navigational safety as well as the safe and secure operation of the vessel. For these reasons, it is in the common interest of all the parties involved, that the limits fixed by MLC Regulation 2.3 are strictly observed and implemented.

What the Regulation requires?

You need to comply with Regulation 2.3 regarding the work and rest hours of your crew. The table below outlines requirements that shall help in identifying possible gaps to comply with MLC Regulation 2.3.

The use of the MLC Work Rest Tool

The WR Tool allows you to correctly monitor the work on board and will enable users to see immediately any detrimental variation from the limits fixed by the Convention.  The WR Tool refers to year 2017 and is protected by a password that will guarantee the avoidance of any mistakes in the filling. Information completed in the first worksheet, seafarer and vessel name will automatically populate all sheets in the workbook.

A “sample” sheet is available here, as a guideline of how to complete the table.

The hours shall be indicated with the following letters:

“w” means working hours

“r” means rest hours

“n” means neutral hours

The letter “n” shall:

  • Be used in case of more than two rest periods in one day, in application of the rule 2.3.6 “hours of rest may be divided into no more than two periods, one of which shall be at least six hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours”).
  • In case of more than two rest periods, indicate the shorter period.
Requirement Yes No Corrective Action
Do the normal hours of work satisfy the following requirements: 8-hour day with one day of rest per week and rest on public holidays and they are not more than 14 hours in any 24-hour period or 72 hours in any 7-day period?
Do the normal hours of work satisfy the following requirements: 8-hour day with one day of rest per week and rest on public holidays and they are not more than 14 hours in any 24-hour period or 72 hours in any 7-day period?
Do the hours of rest comply with the requirement that they may be divided into no more than two periods, one of which shall be at least 6 hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours?
Are musters, fire-fighting and lifeboat drills (and drills prescribed by the national law) conducted in such a manner so as to minimize the disturbance of rest periods and not to induce fatigue?
Is compensatory rest provided for call-outs during the normal hours of rest?
Is a table containing the following information for every position on board the ship provided in English and the working language of the ship and displayed in an accessible place: (a) the schedule of service at sea and service in port and (b) the maximum hours of work or the minimum hours of rest?
Are such records maintained in a standardized format as established by the competent authority and in English and the working language of the ship, and show the seafarers’ daily hours of work or their daily hours of rest and other information as required in A2.3.5 – A2.3.11 inclusive?
Are such records maintained in a standardized format as established by the competent authority and in English and the working language of the ship, and show the seafarers’ daily hours of work or their daily hours of rest and other information as required in A2.3.5 – A2.3.11 inclusive?
Do seafarers receive a copy of their records referred above?
Does the Flag State have any exemptions against the requirements of the limits of hours of work and the hours of rest as specified above and are these being complied with? (see the ship’s DMLC Part I)
Do the hours of work and rest of young seafarers under 18 satisfy the minimum standard – 8 hours per day; 40 hours per week; overtime allowed in exceptional circumstances (Exemption applies if the provisions mentioned above are impracticable for young seafarers in deck, engine room and catering departments assigned to watch keeping duties or working on a restored shift work system and if it is part of an effective training programme?

Act now

Ship Owners/ Managers/ Operators of vessels flying Cook Islands flag should utilize this tool in order to ensure compliance.  MLC Inspectors are requested to confirm at upcoming inspections (irrespective of scope) that Cook Island ships have utilized this tool and if this is not the case report alternative methods to comply.

For further information please contact Mr Fivos Apollonas Kontos: apollonas@dromon.com

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