A letter on fatigue

This has been floating around the email threads of a few industry insiders:

The article makes particular reference to a ship grounding and a collision, the casualties are not specified as to ship’s names, managers and or Owners, although there is one reference to a “German flag cargo ship”. One of the primary causes of the casualties is reported to be fatigue and in the case of the collision, the investigators have deemed the two watch system to be ‘inadequate’. Brilliant deduction that, everyone who has been at sea knows that the two watch system is inadequate, mind numbing and leads to sleep deprivation and exhaustion and even more so when coupled with cargo work on coastal ships. The question of the reams of required paperwork by the navigation department during these periods has not even been considered at this stage with regards the abovementioned casualty. The investigators further found that they were unable to exclude the possibility of the watchkeeper being affected by fatigue, this in spite of evidence indicating excessive working hours. It is always a mystery why Owners will spend some USD 50 million + on a ship and then place a reduced manning crew on board. Of course investigators will never admit to fatigue being the main cause of a casualty as this would suggest complicity in agreeing with the Flag States’ Minimum Safe Manning requirements which allow for reduced manning levels, which result in excessive working hours. Bear in mind also, that ‘flags of convenience’ also include flags that allow registry for commercial reasons. The fact that someone may have the capacity to work long hours and still be effective is rubbish, there can be no deviation from the standard, as how long is long hours and who will be the judge of how long is long. The rules state X number of hours regardless of who the individual is and these hours should be adhered to.

The article refers to a certain cautiousness in the conclusion that while fatigue has been acknowledged as a potential risk it remains difficult to measure. That is why you have standards and fixed allowable working hours. No deviations, no exemptions, work is work and while physical work may affect individuals in different ways, when combined with mental effort this may produce error-inducing fatigue. One standard has been defined. Completing a coastal voyage on the US east coast or the rivers and ports of Europe will soon explain vividly to the investigators how working hours can soon mount up, how sleep becomes the most important aspect of ship life and how fatigue can affect judgement. Caffeine, nicotine and energy drinks will only enhance wakefulness for a short time. Of course, it is always the Master and OOW who is at fault when there is a casualty involving navigation, notwithstanding the pressures placed on the ship and crew by various bodies and the fact that Owners can get away with reduced manning levels.

The rest of us are fortunate in that we can point fingers at the officers and crew and apportion blame from our desks after the casualty.

It is always about the blame, investigators appear to be timid when it comes to recommendations apart from increasing paperwork and inspections when the solution is so simple. Apart from the blame game, solutions should be investigated to prevent a similar occurrence and acted on, flag states have the authority to deal with this problem. Do flag states not talk to each other? Flag states and statutory bodies appear to reduce manning but increase workloads without any apparent thought to the consequences.

What happens then, is that the ship’s staff, under the weight of more and more regulations, increasing paperwork, fear of detentions spend more time on completing the required documents without concentrating on the real work which is SAFE navigation of the ship. In order to combat the excessive working hours and rest periods which are required in terms of STCW, one statutory authority has taken a unilateral stance “to ensure safety of shipping and the environment”.
In terms of their mandate, this is what they are supposed to be doing and one has to only read their mission statement to see that they should be carrying out these duties anyway. The irony seems to be lost on this statutory authority that while examining records and correlating them with other records on board a ship to check on WORKING HOURS, they may be keeping a second mate awake who should be RESTING. It is easy to sit in an air conditioned office, carry out an investigation remembering that generally statutory casualty investigators go home at night. Their biggest problem may be that they will be late for the train. How many commercial surveyors have been on board a ship and found the chief officer has been awake for 2 days, he is dog tired, unshaven and overdosed on coffee and cigarettes and still has to deal with agents, cargo planners who keep changing stowage plans, ensuring that the ship ispatrolled properly, the gangway is manned at all times and has to accommodate flag state and PSC surveyors’ demands, never mind the fact that the ship was subjected to a PSI at the last port one month ago in the same memorandum of understanding zone! All this with a reduced manning crew of 17 persons.
How many ships have been boarded by commercial surveyors when the ship is in the Mediterranean Sea [and other zones] and found that she has been subjected to four or five PSI in the last two months. The ship trades to West Africa and is again boarded in every port by PSC surveyors. Ships are subjected to Port State surveys, P&I Condition surveys, H&M surveys, cargo suitability surveys, vetting surveys, flag state surveys, the list goes on and all of these surveys take time and contribute to working hours. Of course, all of the above surveys are necessary at some stage. The Master and Chief Officer’s dream is to do them all at once, preferably after dry docking before the ship starts trading again. Whether you are on watch at sea, on deck during cargo work, in the office doing paperwork, these are all classed as working hours. Regardless of the current duty, stress levels, which do in fact lead to fatigue do not really change when serving on a hard working ship due to deadlines. Similarly, the Master is bombarded by telephone calls from Managers, Owners and charterers by Sat or mobile phone, who seem to forget at times that they and the ship are on opposite sides of the world. Broken sleep is a contributory factor to sleep deprivation. Sleep deprivation leads to poor health. Officers and crew are sometimes stuck in aircraft for 20 hours flying to join a ship, board on arrival with the ship sailing immediately. There is another classic contributory example of fatigue. Unfortunately, Masters, Chief Engineers, ship’s officers and crews are sometimes treated as criminals these days and are targets for various bodies that see the ships as milk cows and are easy targets when things go wrong, people who should know better hiding behind ‘we complied with legislation so we are not to blame’. Then change the legislation!
The report continues in the vein that ‘smartcaps’ are under experiment at a number of universities and academies. These ‘smartcaps’ are also under experiment in the airline industry and on long haul road transport. The latter two industries are markedly different from shipping in that large airliners fly close to mach 1 and are flying on the limit of defined aerodynamics, one small mistake and the aircraft is history. Large trucks operate in close proximity to other road users and at speeds approaching 50 mph + and reactions must be instantaneous. There are numerous incidents involving aircrew when a flight cannot depart because the aircrew have exceeded their hours. Passengers then all wait, the airline informs everyone that there is no aircrew, and there will be no deviation from the rules, tough, deal with it. 12 hours later when the aircrew are refreshed, the flight departs.
Imagine the howls from Owners, Managers and Charterers if the Master reports that all the officers and crew have reached the maximum working hours and therefore cannot sail for 12 hours so that everyone can rest. Under pressure the ship sails, the watchkeeper can hardly keep his/her eyes open, is so fatigued that he/she falls asleep on his/her feet and the ship becomes a casualty. The working hours schedule should not be related to how many hours in the week, but how many hours in the DAY! We do not need ‘smartcaps’ or biomathematical models to work out what the problem is here. The ship’s staff and in particular the navigation department are TIRED and will make mistakes when they are fatigued. Due to workload, excessive hours, stress and constant demands from Owners etc, they are relying on the electronic navigator and trying to keep up with the demands of the last port, paperwork, future cargo plans, passage plans, chart corrections and the like that they forget to look out of the window. There are always reports on why there is such a shortage of qualified sea going staff to man ships. One of the reasons is not hard to find.

The solution is simple:
Place additional watchkeepers and crew on board the ship to spread the work load. Ban ‘two-watch’ systems, stop increasing the paperwork load on ship’s crews, the current ISM systems are adequate in that they contain all the requirements to run a ship safely, efficiently and with due regard to the environment protection. ISM and operational procedures should be trimmed not increased but of course the opposite is true because of the adverse effects of lowering of STCW certificates of competency standards but that is a subject for another review in time! Owners invest large amounts of money in ships, do the same for your crews!

Signed: DAVID MICHAEL FIDDLER Consulting Marine Engineer

What, you don’t love working 6 and 6?