It may well be that there has been no apparent reduction in the number of accidents in which a sleeping watchkeeper has featured as an important contributor, despite severe messages by accident investigators. It might also be a fact that this sort of accident is a universal problem, with tired watchkeepers found in both eastern and western hemisphere. But regardless of the reasons, an announcement by both the Paris and Tokyo MoU on Port State Control that they are to jointly undertake a concentrated inspection campaign specifically focusing on hours of rest perhaps ought to alert everyone to this perennial issue.

Helpfully summarised as a Risk Alert by the Steamship Mutual P&I Club, the industry is informed that the two biggest MoUs on PSC will together intensify their inspection on this important matter for a three month period starting 1 September. It is anticipated that the two regional inspectorates will carry out about 10,000 inspections during the period, looking at the rest hours of both deck and engine room watchkeepers as they conduct their regular inspections. The Club also warns its members that the six member authorities of the Black Sea MoU on Port State Control are also to coincide their concentrated inspection campaign during the same period.

The focus on rest periods, as specified by STCW 78 (as amended) might seem to be an obvious reaction by the authorities to studies such as the UK Marine Accident Investigation Branch Bridge Watchkeeping Safety Study, which concluded that one third of the groundings this one organisation investigated involved a fatigued officer alone on the bridge at night. It has also been reported that Port State Control Inspectors have not infrequently come upon cases where there have been attempts to falsify hours of rest reports (in some cases with forms being completed in advance of the event!). It has also been noted that many of the incidents have occurred on ships operating a navigational watch with just two watchkeeping officers.

The Club emphasises the importance of punctilious record-keeping, noting the availability of useful tools to assist in this task, but it also, with the assistance of the Paris MoU, provides a list of questions which will be asked by the visiting inspectors during the CIC period. Unsatisfactory answers to these questions may well lead to the vessel being detained.

The questions are phrased to enable the inspector to gauge whether the STCW Hours of Rest requirements are being properly implemented. They relate to the posting of the watch schedule, the manning documents, the records of daily hours of rest for each watchkeeper and their proper endorsement by an appropriate person. They seek to establish that rest periods, including the weekly requirements, are being properly complied with, that watchkeepers on the first and subsequent watch after departure have sufficient time to rest and that there are arrangements to provide compensatory rest periods if they are disturbed by call-outs to work during their rest periods. Significantly, the inspectors will wish to establish that a bridge lookout is being maintained.

Additional questions, which are for information only and will not in themselves result in a detention, include an inquiry into whether a two-watch system, including the Master, is in place and details of the engine room manning arrangements.

This CIC is perhaps an indication of the seriousness with which the authorities are now taking the issues revolving around rest hours, and fatigue.

Author: the Watchkeeper                     Source:  BIMCO.