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Understanding the work and rest hours requirements on ships

Fatigue is seen as significant contributory factor to many incidents in shipping industry. And the aim of the rest hour requirements is to avoid or minimise fatigue. But compliance with rest hours requirements has become the seafarer's worst nightmare these days. Not only you and your ship staff need to be well rested each day but you also need to prove it to the authorities. Worst, when authorities compare the rest hours records with other documents like drill records Enclosed space entry permits Bunkering operation timings Tank cleaning records port arrival and departure times Bridge watch levels And countless other records. Mind you, regular non-compliance with the work and rest hours requirements can be the reason enough for the detention of the vessel by port state controls. The best way to avoid this nightmare is by understanding the rest hours requirements. What complicates it further is that we had multiple regulations stating the same requirements but in the slightly different way. These are ILO/MLC 2006 requirements for work and rest hours STCW 2010 requirements for work and rest hours OPA-90 requirements for work and rest hours. Thankfully after Manila amendments to STCW code, the STCW 2010 requirements are made in line with the MLC req...

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Comments (49)

Comment.

Satyajit Dilip January 2, 2018

Excellently explained. Appreciate the slides you have made to explain it. So much easier to understand. In the class we were told that after you have taken 2 weeks consecutive exemptions, then before you get into the next exemption, you have to take permission from Flag state. Wanted to confirm with you if this is so?? Also if a PSCO boards vessel just after vessel has berthed and ask for the work and rest hours in the last 24 hours of the crew member who was at the gangway and if it does not comply, then can we apply the not more than 2 exceptions per week in this scenario to get away with this observation??

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Rajeev Jassal January 9, 2018

If 2 exceptions have been used, next exception can be after 4 weeks. In this case, there is no need to take permission from flag state. We cannot take permission from the flag if we want to have the exception before 4 weeks in this case. There is no provision that allows violating the rest hours requirements with flag state permission. If we see that rest hours may not comply today or next day, we need to stop (anchor) the ship. Role of the Flag state would only come if some violation has already happened and it was realized later after it had happened. The company can inform the flag state of preventive actions taken to avoid issues with any PSC. regarding the second query, yes we can apply the allowed exceptions.

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Ercan Altay January 2, 2018

Thank you i read all your topics and i realy appriciate you as i found many answers on your writings

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Rajeev Jassal January 9, 2018

Thanks, Ercan...

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MOHAMMAD MOKTARUZZAMAN January 4, 2018

DEAR SIR,GOOD DAY.VERY EFFECTIVE EXPLANATIONS.I LIKE TO READ YOUR WRITING TO ENRICH MY KNOWLEDGE. COULD YOU PLEASE EXPLAIN ME HOW TO MAINTAIN WORK AND REST HOUR IF CREW WORKING SIXES(6 ON AND 6 OFF). SAY IF PORT STAY FOR 7 DAYS THEN WORK HOUR EQUAL 84 HRS HENCE EXCEED 72 HRS.HAND OVER AND TAKE OVER WATCH 15 MINUTES BEFORE HENCE LESS THAN MINIMUM PERIOD OF 6 HOURS.HOPE YOUR GOOD HEALTH.

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Rajeev Jassal January 9, 2018

6 Hours on/off will not comply with rest hours requirements if we take into account hand over period. That is the reason many companies are shifting to 7 hours +5 Hours working arrangements. But of course when we use 6 on/Off, we do not take into account the hand over period while recording rest hours.

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MOHAMMAD MOKTARUZZAMAN January 9, 2018

HI,CAPTAIN.THANKS LOT FOR YOUR REPLY.

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Raju Yadav January 8, 2018

Very helpfull .keep writing..... thanks

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Rajeev Jassal January 9, 2018

Glad you found it helpful Raju...

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Anders January 15, 2018

Hi! I Have a question regarding drill and training. You write that it should be marked as working hours but state the reason for the non-compliance as drill and training. What regulations can I refer to if the Captain on board don't agree? Best regard Anders

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Praveen January 16, 2018

Good day sir Thank you very much for the rest hour regulation explanations I have a doubt regarding same Officer and crew engaged as a part of first navigational watch and the further watches shall take adequate rest right How much is this adequate amount of rest for this purpose Ia it a complete 6 hour before watch or the normal criteria for daily compliances are enough.

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Capt. Shailendra K Singh February 17, 2018

Thanks for sharing Rest Hrs Clarification in very simple words.

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Raman Kumar jha February 18, 2018

Dear Sir, Excellent explation regarding Work/Rest hours. Easily understood. Thanks a lot.

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francesco montalbano March 12, 2018

Explain how is calculate on Isf wk3 hrs of rest in any 7 days periods This takes into account the rest in 7 days period. The word “any” is important in this. The 7 days period can be any time of any day and 7 days period thereafter. So I can choose 0900 hrs on 2nd March to 0900 Hrs of 07th March , as well as I can choose from 1200 Hrs on 5th march to 1200 hrs on 12th March Irrespective of which 7 days period of rest or work I enter , has been noted that in the coluun any 7 days the value Computed does not change

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Aswin Kalarikkal April 16, 2018

Good day Captain. Why are these requirements different for different conventions?

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Richard June 23, 2018

Hello, Great article, along with all your other articles. There is a debate of what the MLC/STCW hours of work and/or rest are under international law and UK law. Your article, MLC, STCW and the MCA state the MINIMUM requirements for REST as 10 hours in a 24 hour period & 77 hours in a 7 day period. MLC and the MCA talks about MAXIMUM hours of WORK as 14 hours in a 24 hour period & 72 hours in a 7 day period. See MSN 1888 annex Aii. "5. The limits on hours of work or rest shall be as follows: (a) maximum hours of work shall not exceed: (i) 14 hours in any 24-hour period; and (ii) 72 hours in any seven-day period; or (b) minimum hours of rest shall not be less than: (i) ten hours in any 24-hour period; and (ii) 77 hours in any seven-day period." The key question is, what does "OR" really mean? The flat state decides now does it? Which flags enforce hours of REST and which flags enforce hours of WORK? The big question is on any ship worldwide, or a UK ship, are you allowed to work 6 hours on 6 hours off for 7 days or more? That would be 84 hours of work that week and you would therefore get 84 hours of rest - minimum rest is ok (>77). However that would also be 7 hours OVER the 7 day maximum of 77 hours. Somebody read somewhere that the flag state decides whether they will adopt the minimum hours of rest or maximum hours of work and that the MCA does comply with MINIMUM hours of REST only and DON'T adopt the MAXIMUM hours of WORK. What about other flags? But there seems to be some confusion over this area. Exceptions exist but it's all rather hazy. Any thoughts? Richard

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Steven May June 26, 2018

Hello sir great article indeed..just one query what about tea breaks should it be shown also on rest hours or it’s just counted as working hours since I have experience different opinions from pre vetting inspectors stating that it should show rest period some say it should be counted as normal working hours ..always create confusion to me..can u clarify on this..once again thanks for the great article

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Anu Prabhudesai December 13, 2018

Seajobs are quite tough and taxing. Employees work under stressful conditions and I feel that the workers should have ample hours of rest as per the set organisations schedule. It will enable them to give their best performance for the success of the organisation.

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Leo December 16, 2018

Hello, Captain In offshore vessels is very usual the 6/6 watchkeeping, what means 12 work hours a day, everyday during 28 days (in Brazil). 7x12=84 hours. But the Regulations says that cannot have more than 72 work hours in any period of 7 days! How is this accepted so naturally worldwide?

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Albert THL February 23, 2019

How to split minutes in working and rest hour in watchkeeper client3, Example if i work from 08:00 to 12:10, then it working hour is 08:00 to 12:00 or 08:00 to 12:30?

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Mohammad April 15, 2019

Hi Capt. Good day, kindly advice as the 4 to 8 watch he start his work 0400 and complete at 0800 for any reason he do some work at 1030 to 1130 and get rest to start his watch at 1600 to 2000 , the question this will be violent to MLC as his rest lest than 6 hours or this will calculate from 2000 to next day 0400. Kindly advice with many thanks

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Ernesto May 10, 2019

While working on a schedule of 4 x 8 i work from 0400 to 0800, and 1600 to 2000, but do 2 extra hrs til 1000 in morning . If i were to work 8hrs in a row till 1200, how many hrs of consecutive rest will i need? 6? taking into account i am supposed to come on watch from 1600 to 2000. Thank You

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Neil MacCallum May 16, 2019

Hi there Part of a 7 day shift starting at 0600 on the day in question. Worked from 0600 until 1900 (30min lunchtime at 1300hrs) then rest period until Emergency call out from 21.30 until 0000hrs rest again until shift start at 0845 (delayed shift start from usual 0600) until 1900hrs ( 30 min lunchtime at 1300hrs again) are we compliant? ie was the compensatory rest period ok bringing up to 10 hr 15 min rest from end of shift prior to emergency? Many Thanks

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Neil MacCallum May 16, 2019

Previous comment should have read 0745 not 0845

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Ggwp 322 May 17, 2019

Mlc is bullshit they shoud take measure about seamen rest hours.they give only regulation no any action is done

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Arjun Singh July 12, 2019

To know how to manage Work and rest hrs without any delay visit, http://work-ship.com/

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Ajit Chavan August 5, 2019

I am now onboard on a UMS class product tanker, we did 6 on 6 off for period of 26 May to 20June, then normal 0800 hrs. to1800 hrs. schedule & now from 27 July to 5 August, does it comply with rest hour regulations

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Pedro Ferreira October 7, 2019

Good day, if a Crew members works more than 14hrs continuously, lets say 20hrs, how many hrs rest he should take after that period to avoid non conformity? "Safety the Vessel or Cargo excluded".

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Harbinder Singh October 8, 2019

Dear Sir, Excellent explanation regarding Work/Rest hours. Easily understood. Thanks a lot. Request for OPA 90 rest hours requirement in the near future.

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Aman deep October 9, 2019

Thank you for your explanation sir, I would like to know what is the diff between MLC rest hours and STCW rest hours. Which one a vessel needs to complied with?

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Alan pearson October 30, 2019

Can you work 8hrs on 8hours off

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Alok Ranjan November 17, 2019

Rest hour old records keeping requirements for how many year.

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Kadir Sert April 26, 2020

Thanks

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Amar anand May 6, 2020

Great article sir.....

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Satvinder May 16, 2020

Hi Rajeev. Thanks a lot for your explanation. I have a query: (6 + 3 + 3) will this rest hours combination meet the requirement of maximum two rest hour periods? Does it pass because total rest hours is greater than 10 or it fails because the min 10 hours rest is divided into more than two rest periods

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Satvinder May 16, 2020

Hi Rajeev, please permit me to give a link in my software to your blog above?

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Gerard June 1, 2020

Hi Capt. , I would like to know if you if the Manila amendments apply to watchkeepers only or does this apply to non-watchkeepers as well , where the 10 hours may be split up into more than 2 periods one of which shall be a minimum of 6 hours

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Kylo June 20, 2020

As far as I can tell from the screenshots, that software is calculating things wrong. https://myseatimezone-qiccpwbttgr04b6.netdna-ssl.com/blogadm/wp-content/uploads/2017/12/Rest-hours-in-7-days-period-with-exception.png Resting hours divided into not more than 2 parts here but one is not always being at least 6 hours in ANY 24 hour period (take a look at between 01:00 and 01:00) Or am I wrong?

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angel balagtas September 1, 2020

30minutes break is considered rest hrs example lunch break

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Neil Weston-Stokes October 21, 2020

This is a great explanation of work/rest regulations, please contact me at neil.westonstokes@isfwatchkeeper.com for a demo of ISF Watchkeeper.

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Bhuvaneshwar Mamgai December 5, 2020

Hi Sir how to comply with one day of rest per week and 8 hrs of work a day as per MLC 2006 Regulation 2.3 point no 3 - Each Member acknowledges that the normal working hours’ standard for seafarers, like that for other workers, shall be based on an eight-hour day with one day of rest per week and rest on public holidays. However, this shall not prevent the Member from having procedures to authorize or register a collective agreement which determines seafarers’ normal working hours on a basis no less favourable than this standard.

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Pawel December 29, 2020

Dear Rajeev, my question is this: Does the requirement of dividing HOR into no more than 2 periods, one of which needs to be at least 6 hours in lenght, has to be calculated only from 0000 to 2400hrs each day, or for ANY 24hr period? In the second case I can see a problem. When you analyse your example showing 7 exact day when seafarer is on duty from 0600 to 2000hrs, and you take 24hr period as from 0100hrs to 0100hrs the following day, than HOR in that 24hr period would be divided into two 5hr periods, meaning not coply with the rules. How to understand this?

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Pawel December 29, 2020

Dear Rajeev, my question is this: Does the requirement of dividing HOR into no more than 2 periods, one of which needs to be at least 6 hours in lenght, has to be calculated only from 0000 to 2400hrs each day, or for ANY 24hr period? In the second case I can see a problem. When you analyse your example showing 7 exact days when seafarer is on duty from 0600 to 2000hrs, and you take 24hr period as from 0100hrs to 0100hrs the following day, then HOR in that 24hr period would be divided into two 5hr periods, meaning not coply with the rules. How to understand this?

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Billy January 11, 2021

Dear sir, Good day, My question is, a watch keeper of 0800-12 and 2000-2400, and has an overtime hours of 1600-1800 everyday is there any violations of the rest hours considering that I had only 2 hrs rest before taking over the watch as OOW? Thanks.

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Gary January 15, 2021

Great post Just wanted to confirm if a crew is transferred to a vessel to begin a 12 hour shift then transferred back after with a transit time of 50 mins each way is this counted as 14 hours work time or 12 hours

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GAMMA Marine March 4, 2021

Thank you for providing such great information. Please find the details below for UK Master Mariner Course

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Khaing Saw Lwin May 25, 2021

When is the rest hour of seafarer exactly start breaking within the meaning of compliance? Is it started by the time the seafarer receive the call or by the time he shows up on deck/engine for work as per working arrangement? If it is the earlier, should the working hour be recorded about half an hour before coming on watch? This half an hour covers waking up call, meal, coffee, changing working dress etc.,

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the khans July 13, 2021

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Tony Smith March 23, 2023

good morning. can you tell me if the hr of rest is the same for harbour tugs, as the work is booked in the office will know what hr we do but they say we work to different working hr. and we can have up to 3 brakes in 24 hr period every day we work and 1 hr brake will count but we still have to maintain the boat and eat as we live on board doing two weeks on two weeks off. and when we are on rest we some times get disturbed with the messages from the office about jobs. it seams to be a lack of control over this side of the shipping industry.

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About Capt Rajeev Jassal

Capt. Rajeev Jassal has sailed for over 24 years mainly on crude oil, product and chemical tankers. He holds MBA in shipping & Logistics degree from London. He has done extensive research on quantitatively measuring Safety culture onboard and safety climate ashore which he believes is the most important element for safer shipping.