Maritime risk prevention firm Prevention at Sea (PaSea) has raised concerns at the varying interpretations being applied to MLC 2006 Regulation 2.3, “Hours of Work and Hours of Rest”, paragraphs 5(b) and 6, specifically with regards to the phrase ‘in any 24-hour period’, which is used when calculating crew work schedules to ensure that sufficient rest periods were taken.
PaSea CEO Petros Achtypis said that the matter had been brought by PaSea to the attention of the ILO Labour Standards Department, requesting clarification on whether the interpretation provided by his team were correct.
The issue revolves around checks ‘in any 24-hour period’ and whether such checks should commence during a seafarer’s rest period. Achtypis said that PaSea’s stance was that this should be avoided, based on the fact that by not taking into consideration a part of the seafarer’s undisrupted rest period, irregularities might occur which could result in a violation of the regulations.
PaSea has recommended that, when scheduling work patterns for crew, the ‘in any 24-hour period’ should commence at the start of any period of work by moving backwards 24 hours, which would indicate clearly whether the seafarer had received adequate rest in accordance with the regulation.
PaSea said it understood that the ILO’s Labour Standards Department shared the same interpretation as PaSea.