Rest hours, commercial pressure and the PSC inspection
MV Coromandel is on day 4 of a five-day cargo operation at a berth where the terminal rewards early completion. The chief officer's port watch bill puts an able seafarer, Ravi, on watch 06:00–12:00 and 18:00–24:00 each day, plus 12:30–14:30 for hold cleaning and lashing checks. On day 4 he is also rostered 02:00–05:00 to assist the duty engineer with a ballast transfer because the usual tankerman is ashore for a medical case. Ravi's signed rest-hour records show 10 hours' rest on each of days 1 to 3. On day 4 the second mate notes that Ravi worked 17 of the 24 hours, with breaks of 00:00–02:00, 05:00–06:00, 12:00–12:30 and 14:30–18:00. The company's SMS requires a fatigue risk assessment whenever anyone works more than 12 hours in 24. A port state control officer is due on board at 09:00 on day 5, and the master wants cargo finished by 22:00 on day 4 so the berth can be released for a performance bonus.
1. Test Ravi's day 4 against the STCW/MLC rest requirements, and then test the seven-day total on the assumption that days 5 to 7 return to 10 hours' rest.
Read the worked answer
Day 4 rest. 2.0 + 1.0 + 0.5 + 3.5 = 7 hours' rest in 24, against a minimum of 10. Three separate failures: the total is 3 hours short; the rest is split into four periods when no more than two are permitted; and the longest single period is 3.5 hours, short of the required uninterrupted 6-hour block. The interval rule (no more than 14 hours between consecutive rest periods) is also breached between the 02:00 and 05:00 breaks.
Seven-day total. Days 1–3 give 30 hours, day 4 gives 7, and days 5–7 at 10 hours each give 30: 67 hours against a required 77 hours in any seven days. So the breach is not confined to the single bad day; the weekly minimum fails as well.
The work limit is also relevant: 17 hours in 24 exceeds the 14-hour maximum in the MLC standard.
2. Propose a watch bill for day 5 that keeps the cargo work on schedule while being compliant, showing the rest periods and the arithmetic.
Read the worked answer
Take Ravi off the hold cleaning and the ballast transfer and give him a straight two-watch day: 06:00–12:00 and 18:00–22:00, i.e. 10 hours' work.
Rest: 22:00–06:00 = 8 hours (satisfies the 6-hour uninterrupted block) and 12:00–18:00 = 6 hours. Total = 14 hours' rest, comfortably over 10 in 24; two periods only; longest period 8 hours; the gap between the end of one rest period (06:00) and the start of the next (12:00) is 6 hours, within the 14-hour interval rule.
Cover. Hold cleaning 12:30–14:30 goes to the day worker or the second officer; the ballast transfer is run by the duty engineer with a different rating. Cargo can still finish by 22:00 if the chief officer re-sequences the last two holds rather than adding hours to one person. Give Ravi a full 10-hour rest on day 5 and log the compensatory arrangement.
3. The master proposes keeping day 4 as rostered, recording it as an emergency and taking the bonus. How should this be handled, and what are the consequences at the PSC inspection?
Read the worked answer
The exception for rest hours exists for genuine emergencies affecting safety of life or the ship, not for commercial bonuses. A routine ballast transfer with a man ashore is a manning problem, not an emergency, so recording it as one would be a false entry in an official record - a serious matter in itself.
Handling. The master should direct a compliant bill, complete a fatigue risk assessment under the SMS, and ensure compensatory rest is given where any genuine deviation occurred. The rest-hour records must show what actually happened, and they must be signed by the seafarer and the master.
At the inspection. The officer will compare the records with the watch bill and the cargo logs; a 7-hour day alongside a 10-hour claim elsewhere is exactly the pattern that invites a deficiency, a detention, or a complaint under MLC. The master's overriding authority on safety does not extend to signing away rest hours, and the bonus is irrelevant to the legal position. If the crew believe they are being pressed, they have a right to raise it, and the ship should be able to show that it acted on the concern.