I have been in command of ULCC and VLCC’s for many years, when tankers were manned by Exxon there was a total crew of 42. After lay up in Norway, the same tankers sailed in more congested waters and I had a total crew of 21 included me. After completion of partial crude oil discharge in LOOP we had many ship to ship oil discharge in the Gulf and working hours where much in excess of requirements but we had no options because commercial requirements were very demanding despite we were time chartered to Exxon. When I left active duty on ships I started to do vetting and periodical inspection mainly on tankers. During inspections I found out that in many occasions working hours records were fake. At a certain point I left my vetting job because I found out useless to check paper works on ships. On my view it’s very simple: if on a VLCC total amount of crew is 21 and you take the worst cases I.e. navigating in the channel during heavy traffic conditions, deep draft ,fog and continuos communications traffic you simply realize that a total crew, Master included, of 21 is simply not sufficient and rue.s can’t be complied with. In addition to this officers have to spend ti e in filling up forms and/or software to show that rules are complied with. In the most of cases I inspected and irrespective of any watch and/or working hours it resulted that simply the total crew was insufficient. And in the most of cases the minimum safe manning. was absolutely unpractical . In my view the working load on board , including useless paper work, should be : the minimum safe manning certificate should take into account the commercial pattern of the ship taking into account the worst conditions encountered during voyage I.e. traffic,fog,etc. Many years ago officers were composed by Captain, senior Chief officer, chief officer , second and third mate and two cadets with two AB EVERY WATCH. Only in this condition he Master can be temporary relied by a competent officer and therefore comply with duty-rest regulations.