Issue date 19/11/2014
We would like to advise our Members that several changes to the ISM Code will come into force on 01/01/2015; however one change, concerning manning levels, is of particular interest.
Amended paragraph 6.2 states:
“The Company should ensure that each ship is:
- manned with qualified, certificated and medically fit seafarers in accordance with national and international requirements; and
- appropriately manned in order to encompass all aspects of maintaining safe operations on board”
Companies are asked to refer to the “Principles of Minimum Safe Manning”, adopted by the Organisation by resolution A.1047 (27):
The flag State may require the company responsible for the operation of the ship to prepare and submit its proposal for the minimum safe manning of a ship taking into account all operational requirements and circumstances. Having received the proposal from the company, the flag State may approve it depending on whether the ship’s complement is established in accordance with principles, recommendations and guidelines set out, and is adequate in all respects for the safe operation and security of the ship and for the protection of the marine environment.
This amendment, which complements Regulation 2.7 (Manning levels) of the Maritime Labour Convention 2006, means that compliance with minimum safe manning may no longer be sufficient when taking into account the operational requirements of the ship and thus it is the responsibility of the company to ensure that the vessel is manned in excess of its Minimum Safe Manning Document to comply with hours of rest rules and other requirements that may arise due to the operation of the ship. If additional manning is repeatedly required to comply with requirements, then the company may have to apply for a new Minimum Safe Manning Document.
The onus of assessment of safe manning for any vessel is on the company who operate it as it it privy to the actual facts of the prevailing operation. Therefore the company would be liable for not having made a proper assessment or for not re-assessing a change in circumstance of the vessel.
We would like to take this opportunity to remind our Members to actively review the manning levels on their vessels in relation to the operational practices on board and take necessary actions, as required.