Seafarers shouldn’t need to routinely falsify records on rest to avoid shoreside repercussions
By Katie Higginbottom
The ITF Seafarers’ Trust has funded an in-depth 3-year research project with World Maritime University on record keeping in relation to seafarers’ hours of work/rest that concluded in December 2024. The report, Quantifying an Inconvenient Truth, builds on an earlier companion publication, A Culture of Adjustment from the same team. Together they create a formidable argument for reviewing the industry’s approach to minimum safe manning and fatigue.
The prevalence of fatigue at sea and its impact on seafarers’ health and wellbeing as well as on maritime safety has been the subject of many studies and academic reports. Yet to date that knowledge has not translated into practical actions to address the underlying causes. So one could ask why bother to fund more research to gather dust on a bookshelf?
There are three main answers to that question – the first is that we should not give up on addressing an issue that is fundamental to seafarers’ quality of life and health and is not impossible to resolve. In a highly competitive business, the fact that it’s difficult to get the industry to genuinely prioritise the wellbeing of seafarers over economic imperatives is a challenge, but one we should take on.
Seafarer recognition
The second is timing and context. Since the pandemic there has been more recognition of the importance of seafarers and more recognition of the need to attract and retain skilled, critical professionals who are now in short supply. Influences on the industry are constantly changing, so just because it seems as though some things never change, it doesn’t mean they won’t if the stars align.
And the third is that this research project tackles the subject from a different angle that just might provoke a reaction leading to real change in practice. By focussing on the recording of hours of work/rest, the results of this project reveal the widespread adjustment of records to give an impression of compliance with regulations. In other words, falsification of documents is rife, and this practice is facilitated by systemic failures.
The global maritime industry is governed by international conventions, regulations and guidelines with agreed standards for implementation and enforcement. The expectation is that States ratify these conventions in good faith and in expectation of honouring their commitments. When it comes to hours of work there has been a perfect storm of increased responsibilities with more administration and more inspections, pressure on crew sizes and an unwillingness to address the matter through safe operational manning requirements. This research shows that the whole basis of maritime safety regulation is built on unreliable foundations.
One of the great advantages of working with the team at WMU is their wealth of hands-on maritime experience. Not only do they bring academic rigour to the issue, this is grounded in real life experience at sea, with the lead researchers being former captains. In addition, as an institution that falls under the International Maritime Organization’s technical co-operation department, they are perfectly well placed for facilitating engagement and co-operation with industry regulators and professionals. For us this was another key aspect of the project – the outcomes must have the potential to change the status quo and the process of getting there should bring people together in co-operation not through confrontation.
Quantifying an Inconvenient Truth presents the findings of research undertaken by Capt Bikram S. Bhatia, Prof/Capt Raphael Baumler, Dr Maria Carrera-Arce, Prof/Capt Michael E. Manuel and Prof Inga Bartuseviciene from data captured between June and December 2022. A total of 6,304 valid responses were received to a global survey of seafarers, far surpassing the recommended size and with broad socio-demographic and work-related characteristics. The questions covered seafarers’ perceptions of fatigue and risk factors, the characteristics of hours of work and rest and its recording, and reasons for noncompliance.
While a 40-hour working week would be considered the norm in many countries including the UK, with 48 hours as the maximum, IMO and ILO regulation allows seafarers to work much longer hours – up to 91 or even 98 hours per week – which is a staggering difference in standards. In spite of this astonishing amount of flexibility afforded to the industry at the expense of health and safety, falsification of Hours of Work Records is endemic. The regulation is consistently gamed and not enforced. The way the industry is structured makes it much easier to adjust records than to report accurately and risk the consequences. Somehow a huge gulf has developed between what is acceptable for people ashore and what is permitted for those working at sea. Fatigue inducing conditions have become normalised.
Detailed findings
There is broad consensus among seafarers (94.9% of respondents) that fatigue is a hazard that affects the safety, health and wellbeing of seafarers; most (93.4%) agreed that it is the most common safety-related challenge.
Over 64% of respondents reported working on average more than 10 hours per day, with 8.5% working more than 14 hours per day. They reported working an average of 74.9 hours per week with 11.7% working more than 91 hours per week.
When asked about days off, 89.6% of seafarers have no weekly day off and a significant majority of 78.3% reported having no full days off during their entire period on board. Only 10.4% reported having a full day off each week.
Looking at the extent to which seafarers keep to the stipulated limits, on average, respondents reported 7.1 instances of non-compliance per month. Most (88.3%) admitted to exceeding the working time limits at least once a month, with only a minority (11.7%) reporting full compliance.
On reporting, less than a third of respondents never adjust their records, with 64.3% reporting that they do adjust their records if they exceed the hours of work/rest limit.
The primary rationale for adjustment (80.2% of respondents) is to avoid findings of non-compliance during inspections and to avoid problems with the shipping company (75%). Around half (50.3%) did notify their company of noncompliance but responses from shore management were often ambiguous or unhelpful – with two thirds (66.7%) reporting the questioning of the management of the ship and almost half (49.1%) saying that the company instructs the ship to adjust the records for compliance.
Seafarers confirmed that the workload has increased with the multiplication of tasks creating an imbalance with the number of crewmembers.
Finding solutions
The obvious solution to the problem would be to increase the number of crewmembers on board, or to look at ways to reduce the workload. However, if it were that easy we would not still be funding research on the subject.
In fact, the first objective of the research is simply to achieve widespread recognition that the problem exists. We all need to recognise that it is not compatible to talk up the importance of mental health and wellbeing while accommodating the elephant in the room.
To that end, we launched the research report last September with a webinar ably chaired by Richard Meade, editor of Lloyd’s List. The WMU authors also presented the findings at a side event during the IMO’s Human Element Training and Watch-keeping sub-committee meeting in February and a paper will go to the IMO Maritime Safety Committee in June. In addition, findings have been used to substantiate proposed amendments to the Maritime Labour Convention strengthening the protections in relation to hours of work/rest that will be considered at the ILO Special Tripartite Committee in April.
We don’t anticipate an easy ride, but the evidence is there. We just need to cajole the industry into making the necessary adjustments, instead of the seafarers.
Katie Higginbottom is head of the ITF Seafarers’ Trust. The two studies can be read for free here
