United States Coast Guard Refines Requirements for Crew Rest on Ocean-Going Vessels

Commercial vessels that operate beyond the internal waters of the United States, otherwise known as “beyond the boundary line,” are subject to the provisions of the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 (STCW). 

This International Maritime Organization treaty was amended in 2010 to enhance the crew rest requirements for most ocean-going vessels. As a signatory to the STCW and its amendments, the U.S. is obligated to amend its national regulations to be consistent with the STCW. Although these regulations are not yet promulgated, the United States Coast Guard issued a policy letter (CG-CVC Policy Letter No. 12-05) on October 11, 2012, setting forth provisions and guidelines regarding crew rest consistent with the STCW and with a recommendation to U.S. flag vessels to employ the guidelines to avoid delay or problems when visiting foreign ports.

Crew fatigue has been identified as a causative factor in many major marine casualties over the years. As a result, the international maritime community established requirements in the STCW to limit crew work hours. These crew work rules, revised in 2010, direct that vessel operators crew each vessel with these requirements in mind. Further, the master is required to prepare and post work schedules accommodating crew rest requirements and record the daily periods of rest for each crewmember in the ship’s log or some other appropriate record. The United States Coast Guard policy letter sets forth these requirements in advance of the promulgation of regulations to implement the 2010 Amendments.

Since 1995, the international standard for crew rest has required all navigational and engineering watchstanders to rest for a minimum of 10 hours in any 24-hour period. The required rest period may be divided into two shorter periods, but one rest period must be of at least 6 hours duration. Watchstanders may not work more than 14 consecutive hours without a rest period absent emergency circumstances. During rest periods, crewmembers may not perform any work, including administrative tasks, such as preparing/reviewing documentation or correcting charts. Crewmembers must be permitted uninterrupted sleep during the rest period.

There are exceptions to these crew rest requirements. For instance, emergency situations and emergency drills may properly impede crew rest periods. Once an emergency period has concluded, the master shall ensure that each crewmember is provided adequate rest as soon as practicable. Crewmembers may be required to work on reduced rest due to exceptional circumstances, but the reduced rest periods must not exist for more than two 24-hour periods in any seven-day period. Under the revised rest rules crewmembers must be provided at least 77 hours of rest during any seven-day period. However, if emergency situations cause crewmembers to work under reduced rest periods, in no case shall a crewmember have less than 70 hours of rest in any seven-day period.

These revisions to the STCW rest requirements, soon to be enacted into enforceable regulations by the U.S. Coast Guard, may well require adjustments to crew manning for some ocean-going vessels. If you have any questions regarding these requirements, please contact the Troutman Sanders Maritime and Government Contracts Practice Group.

Source: United States Coast Guard Refines Requirements for Crew Rest on Ocean-Going Vessels