Apparently in 2006 the ILO created the MLC. One of the key parts is a restriction on working hours. 72 hours in a seven day period. No more than 14 in a day. It also says that you should receive no less than 77 hours of rest in a week. There are a bunch of other things in there as well. I work in the Gulf of Mexico on OSVs on a 12 hour shift. Most people I know on the rigs do the same thing.
My question is has anyone heard about how this is being planned for in the US merchant flee? It will be in force as of august 2013. The way I see the GOM specifically is going to need approximation 50% more people over the next year. Any input would be great
Also for you deck guys think about where 50% more DPOs will come from. Wage war anyone?
dream on kickass…the USCG will implement and enforce IMO regulations only when convenient for the companies. There is no way in hell the Coast Guard is going to go to the industry and tell everyone to upman every maritime position just because some Organization in the UK says they should. Just looking at how the USCG has implemented the STCW in the US should tell you everything. We’re the US for Christ’s sake and even though we are signatories to the conventions doesn’t mean we have to follow them!
We’re already enforcing this on the deepwater ship’s I’ve been on. On our coastwise runs, there is no way we can get around work/rest violations for some crew members (C/M and 1 A/E are the worst violators.) As C/M on a coastwise container ship, I was in violation of work/rest hours about 66% of the time. The only option is to move the C/M and 1 A/E to dayworkers, and bring on additional thirds. Not sure how this is going to play out in the coming months with the unions and the companies. I know even our ships on the foreign runs will run into violations when on the coastal legs of the loop.
We have been using this software, and it makes tracking work hours and planning work schedules for your crew members a whole lot easier. It’s not easy to track the rules without some sort of software once you start looking at multiple days and the rolling 24 hour period (it’s not midnight to midnight).
First ILO is UN not UK.
Second both ABS and our company internal auditors are saying that this is going to impact us quite a but.
Third even if The US doesnt implement it it is going to be used the same way as STCW SOLAS and MARPOL. US vessels will still be subject to Flag Sate inspections in any port of any country that has ratified it. 30 countries have. Those flags contain approximately 60% of the world gross tonnage.
One way or the other this will impact the US fleet.
Amen to that Seasick. It’s here on some tugs too. The vettors are starting to hold even lowly tugboats to this crap now. Uggh. Although I like the enforcement of the hours and the 72 hrs per week, the additional data entry is BS.
And KAS. When you do 6 and 6 you can’t do repetitive 14 hour days, as you wouldn’t have the requisite time off to go back on 6 and 6.
The 14 hour is taken directly from the text of the MLC. I agree if you work 14 hours one day you have to work less the next to make it all even.
6 on 6 off also goes over the 72 hour week
It’s been implemented at the 2 tug companies I work for also.
Captains hate the paperwork.
At one company the cap keeps the log, it’s just BS. It WILL add up correctly.
At the other company, each crewmember keeps their own log and tracks actual hours worked.
That company has gone to 4 & 8 for all positions (at least on the tug I have been on).
There were even 3 tankermen on the barge.
That company was also recently flagged by the CG for improper manning and licensing.
They are concerned about covering their ass.
There is a lot more than just work hours in the MLC for companies to hate. Accommodation size, single rooms for everyone, on board recreation facilities, food requirements and an on-board complaint procedure.
[QUOTE=KPEngineer;83552]There is a lot more than just work hours in the MLC for companies to hate. Accommodation size, single rooms for everyone, on board recreation facilities, food requirements and an on-board complaint procedure.[/QUOTE]
Is there a tonnage/trading requirement for the implementation? I could see this as killing some towing companies.
Vetters may be looking hard at this but is the USCG? I’ve never had them scrutinize the records…they just wanted to see that we had something with a signature and most of it was meaningless. Just like everything else, you can get away with a lot unless something goes wrong and then you can’t get away with anything!
[QUOTE=cmakin;83554]Is there a tonnage/trading requirement for the implementation? I could see this as killing some towing companies.[/QUOTE]
Complicated question. The US hasn’t ratified it yet so none of it really applies to us … yet.
The convention applies to “all seafarers” and “all ships”. The “competent authority” can determine that it would not be reasonable or practical to apply the convention to certain ships or categories of ships, but only ships “less than 200 gross tons not engaged in international voyages”. Its not clear reading the convention exactly which parts they can or cannot make that determination for.
I don’t expect the US to ever ratify it. Too much money will be thrown at congress in order to prevent it.
Vetters may be looking hard at this but is the USCG? I’ve never had them scrutinize the records…they just wanted to see that we had something with a signature and most of it was meaningless. Just like everything else, you can get away with a lot unless something goes wrong and then you can’t get away with anything!
I had a USCG uninspection and they were falling all over themselves to say nothing of meaning regarding crew rest. It was on their checklist so they had to bring it up, but pretty much as long as the company said “yes, we realize you can’t force seamen to work 24 hours a day” they were going to get a pass.
[QUOTE=c.captain;83555]Vetters may be looking hard at this but is the USCG? I’ve never had them scrutinize the records…they just wanted to see that we had something with a signature and most of it was meaningless. Just like everything else, you can get away with a lot unless something goes wrong and then you can’t get away with anything![/QUOTE]
Ships that go foreign will undoubtedly fall under the scrutiny of Port State control somewhere. Usually those guys are on top of the regulations, and someone will get slapped.
The other place I see this being an issue is if someone is injured. If you get injured, and you are in violation of your STCW work/rest hours, and it’s your companies policy to follow these hours, then there is the potential for a huge lawsuit. With all the ambulance chasing lawyers, and the mentality of many a sailor today, it’s bound to happen. That’s why we cover our ass and enforce this.
This issue is why US vessels are on the hot list in many foreign countries. It does not help when the uninspectors (nice) have no training on the issue nor know what to ask.
I brought this up before on here somewhere and was told it did not apply yet in USA. I also heard recently that it has now been ratified by the requisite number of countries and so will be in effect worldwide. I can;t remember the exact date. My question I had earlier was how was this going to work for us here in the USA when almost all vessels work on a 12 hour day. These new rules will not allow continuous 12 hour days, you will be over the allowed hours.
Again, the IMO might have good intentions but since they are not mariners they have no real idea of what its like to work out here and how to make things better. They just write up rules and then when they make things worse for us out here, they write more rules. It never really helps much, if at all IMHO.
Thanks for the link Kickasssailor.
You may have to go to a 6 & 6 watch standing schedule to get around the 2 hour minimum rest that you don’t get with 12 straight.
I see these rules as a benefit to all of us. There have been plenty of times in the far east I’ve stood 6 hour watches after finishing up cargo, sailing through pilot waters, and minimal rest. It’s the name of the game, but it’s not always safe. How many accidents have there been in the last few years where fatigue was a major player in the accident?
Most of the bitching I’ve witnessed is that from people concerned about losing $$$ due to less OT. I think it’s a good system that makes sense, and I’ve spent way too much time learning the new code. Hopefully it will bring more jobs to our industry.
Although I personally like 6 & 6, I agree with Sea Sick in that more jobs for Mariners is a good thing.
If all the customers demanded a 3 watch system, it would happen overnight,
no matter what the IMO, AWO or USCG said.
Now if everybody went to 4 & 8 hour watches, how long would it be before the companies lowered our pay by 1/3rd?
My daily rate is based on 12 hour days, not 8.
[QUOTE=JP;83635]I brought this up before on here somewhere and was told it did not apply yet in USA. I also heard recently that it has now been ratified by the requisite number of countries and so will be in effect worldwide. I can;t remember the exact date. My question I had earlier was how was this going to work for us here in the USA when almost all vessels work on a 12 hour day. These new rules will not allow continuous 12 hour days, you will be over the allowed hours. [/QUOTE]
It will not affect US seamen domestically since the US has not ratified it and even if we did it would probably take decades to be implemented. It will only affect ships calling at a port in one of the 30 countries that ratified it.
14 hours is the max day under MLC.
It’s the ILO, not IMO and it goes in to force in Aug, 2013