Large Yacht Code — MLC Equivalence Practice Questions

A. MLC 2006 "SUBSTANTIAL EQUIVALENCE" FOR YACHT ACCOMMODATION — WHY IT EXISTS: When MLC 2006 came into force, its accommodation standards (cabin floor area, headroom, sanitary space etc.) were developed primarily with conventional merchant ship layouts in mind. Applying those standards literally to a yacht's hull form and internal layout — which prioritises guest space differently and has a fundamentally different design envelope, especially below 500GT — would have been impractical or impossible for many existing and planned yacht designs. INDUSTRY RESPONSE: the MCA worked with industry bodies (MYBA, Nautilus International, the Superyacht Builders Association, and flag states) to develop standards of SUBSTANTIAL EQUIVALENCE to MLC 2006's crew accommodation Code, introduced into LY3 from when it came into force (20 August 2013) and carried forward into the REG Yacht Code. SLIDING SCALE: this equivalence is applied on a sliding scale by tonnage — a documented industry approach moves from around 70% compliance with MLC dimensional standards at the 200GT threshold, rising to around 90% just under 500GT, with FULL (100%) MLC compliance required at and above 500GT. WHY THIS MATTERS TO THE CREW MEMBER: a cabin that looks smaller than a literal MLC figure is not automatically non-compliant — it may be correctly built to the vessel's applicable equivalence percentage for its GT band, which is a real, documented, and legitimate regulatory pathway, not an excuse for skipping the standard.

B. MLC 2006 does not apply to yachts at all, so any crew accommodation standard the owner chooses is acceptable regardless of vessel tonnage.

C. The sliding-scale equivalence approach applies equally to all yachts regardless of tonnage, so a 200GT yacht and a 600GT yacht have identical crew accommodation compliance requirements.

D. Equivalence standards are an unofficial industry custom with no basis in the Code itself, and crew accommodation on yachts is entirely unregulated.

A. SEAFARER EMPLOYMENT AGREEMENT — WHY A VERBAL ARRANGEMENT IS NOT SUFFICIENT: MLC 2006 (as applied to coded yachts via the same equivalence framework that governs crew accommodation) requires every seafarer to have a written Seafarer Employment Agreement (SEA) before, or at the point of, joining the vessel, signed by both the seafarer and the shipowner/their representative, setting out terms including pay, leave, repatriation rights, notice periods and duties. A VERBAL ARRANGEMENT IS A COMPLIANCE GAP BECAUSE: (1) The crew member has no enforceable documented record of their agreed terms if a dispute arises (pay, hours, repatriation); (2) Port State Control inspections specifically check for valid, signed SEAs as a routine MLC compliance item — a missing or informally-handled SEA is a detainable deficiency; (3) The vessel's "evidence of financial security" obligations (for repatriation, abandonment, unpaid wages) are tied to the SEA framework — without a proper SEA the underlying financial security protections may not clearly apply to that crew member; (4) The Master/managing company bears responsibility for ensuring SEAs are in place for every crew member on board, not just senior officers — this affects ratings and junior crew exactly as much as licensed officers. ACTION REQUIRED: ensure no crew member works beyond a short administrative grace period without a properly signed SEA, and escalate to vessel management immediately if the issue is more than a one-off oversight.

B. A verbal agreement on pay and role is sufficient under MLC 2006 as long as the crew member is satisfied with the arrangement and raises no objection.

C. SEAs are only required for officers holding a Certificate of Competency; ratings and junior crew may be employed without a written agreement.

D. SEA requirements apply only to crew on vessels over 500GT; smaller coded yachts are exempt from the SEA requirement entirely.

A. HOURS OF REST ON CHARTER YACHTS — WHY PAPER COMPLIANCE CAN MASK REAL FATIGUE: Charter yacht operations often involve fragmented rest periods (split between guest activity windows — e.g. early morning watersports setup, late evening service, then again early the next morning) rather than the more predictable watch-on/watch-off pattern of a trading ship. MLC 2006 and STCW hours-of-rest rules can be technically satisfied on paper (the minimum number of rest hours within the relevant 24/7-day windows is recorded) while genuine recovery quality is poor due to fragmentation, noise, short notice changes to guest plans, and the inherently variable, guest-driven schedule of a charter. AS MASTER, THE CORRECT RESPONSE IS: (1) Do not treat "the paperwork is compliant" as proof that fatigue is not a real risk — recognise that recorded compliance and actual fitness for duty are different things, exactly as already established in this product's existing Master <200GT content on fatigue; (2) Review and actively adjust the watch/work/guest-activity schedule to reduce fragmentation where possible, not just to keep recorded hours technically above the legal minimum; (3) If genuine compliance is structurally difficult given the charter schedule and crew complement, escalate to the management company — this may indicate a manning or itinerary-planning issue requiring a structural fix, not just better record-keeping; (4) Be prepared to push back on guest/owner-driven scheduling demands that are creating unsafe fatigue levels, using the same Master's safety authority already established for departure/weather decisions.

B. If the hours-of-rest paperwork shows compliance, fatigue is not the Master's concern and no further action is required regardless of how crew appear.

C. Fragmented rest periods are not relevant to fatigue under MLC 2006; only the total number of rest hours in 24 hours matters, regardless of how broken up they are.

D. Charter yacht schedules are exempt from MLC 2006 hours-of-rest requirements due to the guest-driven and unpredictable nature of charter operations.