Do drills count towards hours of rest?

[pignutpilot]

Do drills count towards hours of rest?

I'm sure I heard someone mention that the manila amendments were going to change it so that they didn't count towards the hours of rest, but not sure if that happened.

[size4riggerboots]

Not sure I quite get what you're asking here... If you're asking if time spent doing drills somehow doesn't count as working time and therefore is classed as part of your hours of rest, then no! Your hours of rest are supposed to be exactly that, time spent resting, ok it's not all sleep, as we need to eat, relax, work out etc, but I don't see how anyone could justfy saying that drill don't count as "work time"!

[Chiefy]

Drills are working time, not resting time, and need to be logged as such, depending on your company system.

China PSC recently wrote a ship up when they found that a drill had been had on a Sunday BUT a couple of crew members had been resting al day according to the HoR records.

[YoungMariner]

Also note that the authoritative document for Hours of Rest is now the Maritime Labour Convention rather then STCW.

[Clanky]

Drills should be recorded on the hours of rest sheet as time worked, however......

The requirements for a minimum of ten hours rest in any 24 hour period, split into not more than 2 separate periods, with one period of at least 6 hours, does NOT include statutory emergency drills. So if your rest period is interrupted by drills then the vessel is not in breach of the regulations.

This has nothing to do with the Manilla ammendments to STCW or the MLC, it has always been the case.

[Pilot Chris]

I was thinking alongside the same view as Clanky.

[Randomist]

http://www.ilo.org/dyn/normlex/en/f?...C076,/Document

It's in the revision to the MLC convention.

Revision to the 'Hours of Work and Manning (Sea) Convention.

Article 18. Para. 2 part C:

2. Time spent in the following work shall not be included in normal hours of work or be regarded as overtime for the purpose of this Part of this Convention:
(c) musters, fire, lifeboat and similar drills of the kind prescribed by the International Convention for the Safety of Life at Sea for the time being in force

So drills aren't to be recorded as work or overtime.

However, the 'Seafarers Hours of Work and Manning of Ships Convention' says that Drills should be conducted in a way that they cause minimal disturbance to rest periods and do not induce fatigue.

[Chiefy]

But it's about the recording, they dont count for violations but you still have to record that you went to the drill for the time you where there, however it can be recorded with a code as such...should a potential deviation / violation occur.

Hmmm maybe I am not explaining this so well....... As far as the courses I've done suggest, it's all about planning, and there should be no unplanned deviations, as such you know when a drill is and that you will be working it, as such you plan your rest hours accordingly as you do for stand-by's etc, however if a deviation is seen or caused by the drill then you can use a code (6?) which explains it is a planned deviation from the rest hours regulations for the attendance to/of training and drills (might be wrong code) The aim is to plan the work/ rest periods, so far have seen 4 PSC teams on here looking at this all are happy that we are planning rest / port calls / drills etc, of courseall planning for drills should be as un-disruptive as possible

I for one arent going to argue with Chinese PSC Inspectors

I think that makes sense though I am happy to stand corrected

[YoungMariner]

http://www.ilo.org/dyn/normlex/en/f?...C076,/Document

It's in the revision to the MLC convention.

Revision to the 'Hours of Work and Manning (Sea) Convention.

Article 18. Para. 2 part C:

2. Time spent in the following work shall not be included in normal hours of work or be regarded as overtime for the purpose of this Part of this Convention:
(c) musters, fire, lifeboat and similar drills of the kind prescribed by the International Convention for the Safety of Life at Sea for the time being in force

So drills aren't to be recorded as work or overtime.

However, the 'Seafarers Hours of Work and Manning of Ships Convention' says that Drills should be conducted in a way that they cause minimal disturbance to rest periods and do not induce fatigue.

I don't interpret that as referring to that statutory hours of rest, rather that it's not classed as planned work and overtime should,not be payable for those duties.

But I'm not a lawyer.

[VISHWANATH]

Also please note that it is mandatory that drills be conducted in a manner which does not unduly disturbs crew member(that is proper rest planning should be given a thought when planning drills)

[Lewis]

Drills should also be realistic as possible. Real emergencies wont wait till everyone is well rested.

[Clanky]

Let me use an example:

2nd mate working 12-6

drill at 0900-1000 (because of new crew embarkation, so a mandatory requirement before sailing)

so he works 00-06, 09-10, 12-18

In that 24 hours he does not meet the minimum of 10 hours rest in 2 separate periods, he should record the hours that he actually worked on his hours of work / rest sheet with a comment in the comments section to say that he attended a statutory drill from 0900 - 1000.

If it is not recorded as hours worked then it will cause problems with PSC, but if there is note to explain why he didn't meet the requirement then he is not in violation of the rules.

[Steve]

Drills should also be realistic as possible. Real emergencies wont wait till everyone is well rested.

And by tiring key watchkeepers with poorly timed drills, we can increase the likelihood of fatigue precipitating a real emergency! :-)

[YoungMariner]

I truly believe that 6on/off needs to banned, as most of the ships that practice it are incredibly busy and no seafarer can truly remain legal doing it. Most of the ships doing 6on/off are undermanned and operating busy small feeder container ships and shuttle tankers around Northern Europe and similar... I hated doing 6on/off particularly because once you've added standby's, PSC inspections, safety jobs, audits, drills and all the other crap you end up so knackered, particularly if your somewhere like Rotterdam or Antwerp and have to change berth several times, then you have the long pilotages then into the North Sea/English Channel then into another European Port... nah I never want to do that crap again.

[YoungMariner]

Drills should also be realistic as possible. Real emergencies wont wait till everyone is well rested.

Drills are a process, that you have to judge and build up with a team. You don't make the drills to advanced to start until you've built the guys up to the right standard... The full on realistic drills take about 3 hours or more and are knackering, well on passenger ships anyway.