IFSMA has since the beginning of the eighties discussed the issue of fatigue and its impact on disasters, accidents, incidents and also the health problem for masters, officers as well as ratings, especially on ships with only one master and one watchkeeping officer in short sea shipping.

This is most common onboard small ships in short voyages and near coastal traffic with arriving and leaving ports almost daily.

We have recently learnt from researches made in UK, Sweden and other countries that those ships are overrepresented in accidents such as collissions, groundings and other incidents caused by the officers on watch have fallen asleep, often due to heavy workload, excessive working hours and lack of sufficient rest.

Reports from accidents and researches from Sweden, UK and other Member-Governments indicate that the officers on those smaller ships work excessive hours, far above the permitted working hours and do not have sufficient rest hours in accordance with the regulations. We also have in a Swedish investigation established that the officers are making falsified records of their real working hours, after pressure from some shipowners, with threats of flagging out the vessel. This is very sensitive because most of the officers concerned, have restricted Certificates so they have no alternatives by finding other equivalent jobs at sea.

The causes to this situation are that more and more tasks and workload have been put on the shoulders of the watchkeeping officer, such as adminstrative requirements including ISPS and ISM Codes, watchkeeping at berth, tighter schedules, maintenance of the engines, departures and arrivals, discharching and loading, contact with authorities, agents etc. This also means that they regularly will have their resthours disturbed.

This means that on top of the mostly twelve hours a day on the bridge they have to fulfil the rest of all the different other tasks on the remaining one hour to comply with the ILO regulation on 77 hours of rest per week equivalent to 91 hours of work.The total crew is many times down to four to six people. This equation of the workload and the working hours available is impossible to solve even behind desk ashore. At four/five a ´clock in the morning, after five hours watch the officer´s sleepiness/fatigue makes him act as if he is influenced with 0.4 promille alcohol in the bloodstream. An officer who has been awake more or less for 24 will act as he has some 0.8 promille which many times is the case because all the disturbance factors during his resthours. If that was the case, should we permit that without any actions taken? No, therefore something has to be done.

Professor Andy Smith, Cardiff University, stated at the last STW Committee: “Seafarers´ fatigue is an occupational health and safety issue that is common and widespread. It is not being adequately dealt with by current legislation, management or working practices and there is an urgent need to rectify the situation”

IFSMA also wants to refer to our recorded statement at the last Sub-Committee:

“IFSMA proposed that the master should not be considered a watchkeeping officer when deciding the composition of the navigational watch.”

And also the recorded decision taken by the Sub-Committee:

“The STW Sub-Committee urged Administrations to consider the circumstances very carefully before allowing a safe manning document to contain provisions for less than three qualified deck officers, while taking into account all the principles for establishing safe manning.”

I also want to remind you that this report from the Sub-Committee was approved by MSC 83 in Copenhagen last year and we want this decision by the MSC recorded into the report of this meeting.

Further I also want to refer to the Secretay General Efthimios Mitropolus, who in one of his opening speeches stated:

Referring to the outcome of recent analyses of accidents, which indicates, ”due to inappropriate levels of manning and watchkeeping arrangements, particulary in short sea voyages, fatigue has emerged as a significant contributory factor in accidents”.

Perhaps the time has come for the principles in the STCW to be re-assessed, possibly by the identification of factors which can evaluate manning levels on ships of similar types, size and trade.

Taking what has been said into consideration, IFSMA is asking for a minimum requirement of one Master and two watchkeeping officers in all ships in international trade. The two watchkeeping officers should with sufficient marginal be able to keep their watches and perform other normal tasks within the present requirements of working and resthours. In our opinion it should be up to the shipmaster, whether there should be a two watch system with a master as support, or a three watch system.

We already have had at least one severe incident that most probably was caused by fatigue at around five o´clock in the morning, the collision between Stena Nautica and Joanna, but due to fair weather, all passenger and crew could be rescued, because the ferry didn´t capsized.

If we don´t do anything and just wait until the worst thing happens as a collission and/or a disaster with a vulnerable ro- ro passengership with a loss of many lives or a fully loaded gas- or oiltanker with severe damages to the environment, how can we then defend ourselves with all the knowledge that we have today?