Work/Rest Hours Record – Compliance and Fatigue Prevention

Work/Rest Hours Record

Ensuring Compliance, Safety, and Well-Being of SeafarersThe Work/Rest Hours Record is one of the most essential documents onboard a vessel — not only for compliance but also for safeguarding the health, safety, and efficiency of every seafarer.
Proper management of working and rest hours is a fundamental requirement under international maritime law, reflecting the industry’s commitment to safe operations and the prevention of fatigue-related incidents.

1. Legal Framework: MLC and STCW Requirements

The regulation of seafarers’ hours of work and rest is governed by two key instruments:

• Maritime Labour Convention, 2006 (MLC 2006) — Regulation 2.3 “Hours of Work and Hours of Rest”;

• STCW Convention (as amended in Manila, 2010) — Section A-VIII/1 “Fitness for Duty”.

Both conventions are complementary.
Their aim is to ensure that every seafarer has adequate rest to perform duties safely and to prevent excessive working hours that lead to fatigue, stress, and human error — major contributing factors to maritime accidents.According to MLC Regulation 2.3:

• Maximum working hours must not exceed 14 hours in any 24-hour period and 72 hours in any 7-day period; or

• Minimum rest hours must not be less than 10 hours in any 24-hour period and 77 hours in any 7-day period.

These rest hours may be divided into no more than two periods, one of which must be at least 6 hours long, and the interval between two consecutive rest periods must not exceed 14 hours.

2. Purpose of Work/Rest Hours Records

The Work/Rest Hours Record serves multiple functions onboard:

• Legal evidence of compliance with MLC and STCW requirements;

• Safety assurance, proving that crew are not overworked;

• Health protection, preventing chronic fatigue and medical risks;

• Audit and inspection tool for Port State Control (PSC), Flag State, and company ISM audits;

• Crew management tool, assisting Masters and officers in scheduling duties effectively.

Every seafarer must maintain a personal, signed record of hours worked and rested, verified by the Master or authorized officer. These records are subject to inspection at any time.

3. Practical Challenges in Maintaining Records

Despite clear rules, implementation can be challenging due to:

• Operational pressures, especially during port calls, cargo operations, or emergency situations;

• Under-manning, forcing seafarers to work beyond limits;

• Administrative errors or false entries, sometimes made to avoid non-compliance penalties;

• Cultural and managerial gaps, where fatigue is underestimated or normalized.

Inconsistent or falsified records not only breach international regulations but also expose the shipowner and Master to detention, fines, or even criminal liability.

4. Fatigue and Its Consequences

Fatigue has been recognized by the IMO and ILO as one of the most serious safety risks in shipping.
Scientific studies demonstrate that even moderate sleep deprivation reduces reaction time, decision-making, and alertness — comparable to alcohol impairment.The Erika (1999) and Herald of Free Enterprise (1987) disasters, among others, highlighted the catastrophic impact of fatigue and insufficient rest.
Fatigue contributes to over 25–30% of all marine casualties according to EMSA and MAIB reports.Therefore, compliance with rest-hour regulations is not a bureaucratic burden — it is a core safety function directly tied to human life, vessel performance, and environmental protection.

5. Tools and Systems for Managing Work/Rest Hours

Modern shipping companies use digital solutions to monitor and control working hours, including:

• Electronic Record Systems integrated into safety management software;

• Automated notifications when rest limits are about to be violated;

• Crew scheduling applications optimizing watch rotations;

• Fatigue risk indicators integrated into vessel management dashboards.

Examples include tools like AMOS, NS5, DANAOS, or MarineHR platforms, where rest-hour data is automatically linked to voyage plans and port operations, ensuring transparency and real-time compliance tracking.

6. Responsibility of Shipowners and Masters

Under MLC 2006 and the ISM Code, the shipowner and Master are jointly responsible for ensuring compliance.
They must:

• Maintain accurate records of work and rest hours for each seafarer;

• Provide enough personnel to perform all operations safely;

• Train officers in fatigue awareness and record management;

• Conduct internal audits and address violations immediately;

• Retain records onboard for at least 12 months for inspection.

Failure to comply can lead to detention of the vessel, revocation of certificates, or liability in case of incidents related to fatigue or human error.

7. Inspections and Consequences of Non-Compliance

Port State Control (PSC) officers, Flag State inspectors, and external auditors review Work/Rest Hour Records regularly.
Typical deficiencies include:

• Missing or unsigned records;

• Excessive work hours without compensatory rest;

• Manipulated or identical entries for all crew;

• Lack of awareness about regulatory limits.

Consequences can include detention, financial penalties, or withdrawal of the Declaration of Maritime Labour Compliance (DMLC).
In severe cases, it may lead to loss of P&I coverage or crew claims under labor law.

8. Best Practices for Compliance

To maintain a safe and compliant work-rest regime:

1. Implement daily monitoring and cross-checks by department heads;

2. Use automated alerts to prevent rule violations before they occur;

3. Hold weekly fatigue review meetings onboard;

4. Adjust work schedules before port operations;

5. Promote a “no retaliation” culture for reporting fatigue;

6. Encourage seafarers to rest properly and report cumulative stress.

When managed properly, rest-hour compliance not only prevents accidents but also increases crew morale, retention, and vessel performance.

9. Conclusion

The Work/Rest Hours Record is far more than a formal document — it is a vital safeguard for human life and maritime safety.
Accurate and transparent recordkeeping demonstrates a company’s professionalism, care for its people, and adherence to the highest international standards.
By prioritizing rest, the maritime industry protects not just compliance, but its most valuable asset — the seafarer.