UNSATISFACTORY COMPLIANCE WITH HOURS OF REST

Fatigue leads to human error. Every transportation mode, aviation, trucking, railroads, and maritime, have laws and regulations dealing with how many hours of rest an individual must have before continuing with their job.  Scientific studies indicate that the human body needs 7-8 hours of uninterrupted sleep to ensure that an individual is rested sufficiently to carry out their job. In the maritime industry, watches were developed to help address these issues long before science quantified these requirements.  However, today individuals on vessels typically have to fill out paperwork and file reports when they are not “on watch” – taking away from the hours in which they can sleep.

The International Maritime Organization developed standards that shipowners must comply with when scheduling their personnel.  The Japanese MOU just issued a study based on their enforcement of these IMO requirements.  Between September 1, 2014 and November 30, 2014 Japan conducted 6,392 inspections in which they had a questionnaire for the crew to examine hours of rest.  They found that there were 1,589 deficiencies where the crew did not comply with IMO requirements. Some of these may have been failure to keep track of the hours that mariners were working.  During that time 16 ships were detained because the violations were serious.

The Japanese press release stated “Analysis of the recorded deficiencies shows that most deficiencies relate to hours of rest not being recorded correctly in 997 cases (63%), vessel manning not in accordance with the minimum safe manning document 241(15%) and shipboard working arrangements 232 (15%).”

There are similar concerns about hours of rest in the U.S. domestic fleet. Section 8904(c) of title 46, United States Code, authorizes the Coast Guard to establish maximum hours of service on towing vessels. This provision was enacted in 2004 but the Coast Guard has not yet established those standards.

The Japan MOU press release on this study can be found at this link.

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