WMU STUDY ON SEAFARERS’ WORK AND REST HOURS ONBOARD SHIPS
This study confirms previous findings that underreporting of working hours or “adjustment” of work/rest hour records is a widespread practice in the maritime industry, forming what is referred to as a “culture of adjustment.”
Root Cause
The study identifies insufficient manning levels as the root cause of work/rest hour violations and the adjustment of records. The process for determining minimum safe manning often fails to fully comply with IMO principles (Resolution A.1047(27)), and competition among flag States contributes to persistently low manning levels. This issue is further exacerbated under high workload conditions, such as port operations or special activities.
Regulatory Shortcomings
Many stakeholders (excluding some shipowners’ associations) criticize the current regulatory limits (MLC 2006, STCW), arguing that they lack a solid scientific basis and are ineffective in preventing fatigue. The 6-on/6-off watch system is particularly condemned as incompatible with proper rest requirements and a major contributor to severe fatigue.
Record-Keeping Practices
Work/rest hour recording is often treated as a mere paperwork formality aimed at compliance rather than an accurate reflection of reality. Record-keeping software is sometimes designed in ways that “encourage” crew members to adjust data to remain in compliance. This adjustment behavior extends beyond work/rest records to other logs, such as Planned Maintenance System (PMS) records, drills, oil record books, and checklists.
Motivations Behind Adjustments
Crew members adjust records mainly out of fear of reprimand or dismissal by management companies, concern over failing third-party inspections (e.g., PSC, SIRE), pressure to meet KPIs, or financial incentives (overtime pay, bonuses). They tend to prioritize the ship’s performance and avoid disruptions to operations, resulting in cognitive dissonance between reality and reporting.
The Role of the Company
Many companies appear to ignore crew feedback regarding work/rest concerns, revealing weaknesses in their Safety Management Systems (SMS) in capturing and responding to onboard issues. Systemic adjustment of records raises questions about the effectiveness of flag State audits and ISM Code implementation. A culture of mistrust, blame, and bureaucratized safety further widens the ship–shore gap and discourages honest reporting.
Compliance Monitoring and Enforcement (CME)
Port State Control (PSC) inspections are often limited in scope (typically only examining the work/rest schedule and records) and constrained by time, making it difficult to verify the accuracy of reported data. Port State Control Officers (PSCOs) rarely cross-check information or conduct deeper investigations due to limited resources, time, and the challenge of finding clear evidence for non-compliance. Inconsistent enforcement and inadequate penalties contribute to the normalization of falsified records.
A Systemic Failure
The industry-wide failure to address record violations and adjustments highlights a systemic failure. All stakeholders (seafarers, companies, flag States, port States) are aware of the issue but seem to accept it, creating an environment lacking true motivation for compliance.
Recommendations for Shipowners and Crew Management Companies
Based on the study’s findings, companies should consider the following actions:
1. Address Manning and Workload
- Acknowledge and respond to feedback from ships regarding excessive workload, work/rest violations, or reasonable requests for additional crew.
- Regularly reassess vessel manning levels using actual crew feedback and operational profiles.
- Proactively assign temporary crew reinforcements for high workload scenarios such as canal transits, major repairs, or intense port activity.
2. Raise Awareness and Safety Culture
- Train shore-based management and decision-makers on the importance of human factors and the negative impact of fatigue on maritime safety and crew well-being.
- Foster a “just culture” that encourages the reporting of safety issues and violations without fear of punishment or blame, strengthening the feedback and reporting system.
- Empower the Designated Person Ashore (DPA) to facilitate meaningful change and ensure reliable feedback from ships is acted upon.
3. Improve Management Systems and Record-Keeping
- Launch fatigue management programmes that include verification mechanisms for work/rest hour data.
- Research, pilot, and implement innovative, tamper-resistant, and ethically acceptable work/rest hour recording methods that also respect crew privacy. Share best practices with industry partners.
- Revise internal audit guidelines to make them genuine safety assessments beyond routine paperwork checks.
- Investigate the impact of bureaucratization in shipboard operations on safety and working conditions.
4. Build Better Relationships and Working Conditions
- Develop genuine ship–shore connections, working towards trust and engagement with crew members.
- Provide more stable employment terms in seafarer contracts, moving towards long-term agreements to reduce job insecurity.
5. Strengthen Human Element Programmes
- Initiate and enhance human element training for both seafarers and shore management (including DPAs), highlighting the importance of accurate work/rest record-keeping and the use of feedback for improvement.
The study emphasizes that addressing the “culture of adjustment” requires coordinated efforts from all stakeholders and systemic changes, particularly ensuring adequate manning and cultivating a work environment built on trust and transparency.
Translated and compiled by the Seafarer Club Team using Gemini AI.
You can access the full reports here:
- 2020: https://commons.wmu.se/lib_reports/66/
- 2024 update: https://commons.wmu.se/lib_reports/80/
