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Hours of work & rest

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  • Hours of work & rest

    Hello

    I am over 18 and working on a UK registered ship. There is a debate of what the MLC/STCW hours of work and/or rest are under UK law. Just wanted to keep this anonymous unless the staff wish to post this question themselves somewhere else?

    MSN 1842 and MGN 566 clearly state the MINIMUM requirements for REST as 10 hours in a 24 hour period & 77 hours in a 7 day period.

    MLC talks about MAXIMUM hours of WORK as 14 hours in a 24 hour period & 72 hours in a 7 day period. See MSN 1842 annex Aii.

    The big question is on a UK ship are you allowed to work 6 hours on 6 hours off for 7 days or more?

    That would be 84 hours of work that week and you would therefore get 84 hours of 84 hours of rest - minimum rest is ok. However that would also be 7 hours OVER the 7 day maximum of 77 hours.

    Somebody read somewhere that the flag state decides whether they will adopt the minimum hours of rest or maximum hours of work and that the MCA does comply with MINIMUM hours of REST only and DON'T adopt the MAXIMUM hours of WORK.

    But there seems to be some confusion over this area. Exceptions exist but it's all rather hazy. Any thoughts?

  • #2
    Essentially MLC allows for one OR the other. So, yes in theory 6 on/6 off is possible. However, some port and flag states don't believe that 6 on / 6 off will allow you to comply with the a minimum of 6 hours uninterrupted rest due to handovers etc and so many companies require something like 8 on / 4 off, 12 on / 12 off, 4 on / 4 of / 6 on / 10 off, or some variant thereof.

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    • #3
      Originally posted by YoungMariner View Post
      . However, some port and flag states don't believe that 6 on / 6 off will allow you to comply with the a minimum of 6 hours uninterrupted rest due to handovers etc
      They'd be right. Should be illegal.

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      • #4
        Thanks useful to hear. I understand the UK enforces the minimum hours of rest.

        According to one officer, an MCA surveyor recently said that the maximum hours of work also apply to UK ships and therefore you are not allowed to work more than 72 hours a week (therefore 6 on/6 off would be illegal in the UK but then so would 12 on/12 off). Is this maximum limit for UK ships correct and where is it written down? The M notices are unclear.

        If he's correct in the maximum work limit, there must be many breaches of this as that limits you to working just over 10 hours per day each week.

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        • #5
          Pretty much all the north sea supply boats work 6 on/6 off (as far as I'm aware - I obviously can't speak for all companies and individual boats) but that's only when they are on location/doing cargo.
          It changes once in port especially for the officers so occasionally it's less than 7 days or less than 2 consecutive weeks.

          Wouldn't this be where 566 applies, it's an operational requirement, approved and agreed and is permissable as they do time for time 28on/28off??

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          • #6
            A considerable number of coastal ships in Europe operating throughout UK waters operate with just a Master and Chief Officer on the deck side, so they have no choice but to work 12 hours per day each (and clearly work more). Personally I think a big crack down is needed, but the MCA and governments wouldn't want to upset the ship owners so it won't happen anytime soon sadly.

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            • #7
              You have to consider that it is actually the Flag States that issue and approve the Safe Manning Documents...

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