Question 1

Under the Maritime Labour Convention (MLC 2006), what is the difference between Part I and Part II of the Declaration of Maritime Labour Compliance (DMLC)?

Accepted Answer

Part I is drawn up by the flag state administration and lists the national requirements implementing MLC that must be met; Part II is drawn up by the shipowner/operator and describes the measures adopted to ensure ongoing compliance with those requirements between inspections The Declaration of Maritime Labour Compliance is attached to a ship's Maritime Labour Certificate. Part I is prepared by the flag state and references the relevant national legal provisions implementing the MLC requirements (covering areas such as minimum age, hours of work and rest, accommodation, food, health and safety, etc.). Part II is prepared by the shipowner/operator and sets out the specific measures the company has put in place to ensure ongoing compliance with those national requirements between inspections, including who is responsible for ensuring compliance. Without a valid DMLC attached, the Maritime Labour Certificate is not valid, and a ship cannot lawfully sail.

Question 2

Under the Maritime Labour Convention 2006 (MLC), what are the standard minimum rest requirements for seafarers, and why do they matter?

Accepted Answer

Seafarers must receive a minimum of 10 hours of rest in any 24-hour period and 77 hours in any 7-day period (the alternative being a maximum of 14 hours work in 24 hours and 72 hours in 7 days); rest may be divided into no more than two periods, one of which must be at least 6 hours, and the interval between consecutive rest periods must not exceed 14 hours — these limits exist because fatigue is a major contributing factor in maritime accidents and affects judgement, reaction time, and health These figures mirror the STCW rest hour requirements and are a cornerstone of MLC because fatigue-related incidents (collisions, groundings, injuries) are consistently linked to inadequate rest, particularly cumulative fatigue from repeated short rest periods rather than a single bad night. The "no more than two periods, one at least 6 hours" rule specifically targets the practice of breaking rest into many short, ineffective periods that do not allow proper recovery sleep.

Question 3

As the officer responsible for maintaining the hours of rest records for your watch team, you notice that one rating's actual rest pattern over the past week does not match what is recorded, because they were called out for unscheduled work that was not logged. What should you do?

Accepted Answer

Correct the record to reflect the actual hours worked and rested, ensure the rating (and you, if also affected) acknowledge/sign the corrected record, and if the corrected figures show a breach of the rest hour limits, this should be reported in line with the ship's SMS so the cause (e.g. recurring unscheduled callouts) can be addressed rather than simply documented and repeated MLC requires that hours of rest records reflect actual hours worked/rested and that seafarers (or their representative) acknowledge the record — falsifying records to show compliance is a serious matter, both because it removes the company's ability to identify and address a genuine fatigue risk and because falsified records are themselves a significant finding if discovered during a port state control or flag state inspection. Recurring unscheduled callouts that push a crew member below the minimum should be addressed at source (e.g. by adjusting work planning or staffing), not by adjusting the paperwork.