Demonstrating Compliance with ILO 180 Working Hours Guidelines

Transcription

1 Demonstrating Compliance with ILO 180 Working Hours Guidelines Nick Roberts Team Leader - Time Charter Assurance 11/18/2009 Copyright: SIPC Shell International Trading and Shipping Company Limited

2 Lets Consider.. Why Monitor? What Rules? How?

3 Why? Fatigue Causes Incidents US pilot denies cockpit sleep Investigations are under way in the US to find out how a plane heading from San Diego to Minneapolis overshot its destination by 150 miles (240km). - BBC 24 th Oct 2009

4 Why? Fatigue Causes Incidents 10% of UK road fatalities (UK Govt) 11-23% of Collisions and Groundings (UK MCA) Fatigue is not well considered at sea, and yet its effects are insidious Chief Inspector of Marine Accidents MAIB April 2005

5 Why? Monitoring of Crew Performance More to Come!

6 Why? New Legislation? Maritime Labour Convention 2006 Regulation 2.3 Each Member shall ensure that the hours of work or hours of rest for seafarers are regulated Convention comes into force 12 months after ratification by at least 30 members with a total share in the world gross tonnage of ships of 33% Enforcement by Flag State Survey and Port State Inspection!

7 What Am I to Comply With?? ILO180 Already Ratified by: Belgium 10:06:2003 Bulgaria 24:02:2003 Denmark 10:07:2003 Finland 04:07:2002 France 27:04:2004 Germany 14:11:2006 Greece 14:05:2002 Ireland 22:04:1999 Latvia 13:01:2006 Luxembourg 30:11:2005 Malta 19:09:2002 Morocco 01:12:2000 Netherlands 16:06:2003 Norway 22:10:2003 Romania 11:10:2000 Saint Vincent and the Grenadines 08:02:2002 Seychelles 28:10:2005 Slovenia 21:07:2004 Spain 07:01:2004 Sweden 15:12:2000 United Kingdom 20:12:2001 MLC2006 Already Ratified by: Bahamas 11:02:2008 Liberia 07:06:2006 Marshall Is 25:09:2007 Norway 10:02:2009 Panama 06:02:2009

8 What Am I to Comply With?? In Simple Seaman's terms: In ANY 24 hours, all on board must have 10 hours of rest which must be split into no more than two periods, one of which must be 6 hours.

9 How? - Monitoring on Board Could this be the day-work C/O on your busy ship???

10 How? - Monitoring on Board Format does not meet ILO Guidelines

11 How? - Monitoring on Board Hours of Rest are for more than 2 periods

12 How? - Monitoring on Board Records do not consider any 24 hours - Non conformance therefore not fully recognised.

13 How? - Monitoring on Board Hours of Rest identify: 4 periods of less than 10 hrs rest in day 6 days when less than 77 hrs rest in week? (incorrect!!)

14 How? - ISF Watch Keeper and counts only two longest periods Considers previous 24 hr for each 30 min period when working. Entry = worst 24hrs in day!

15 How? - ISF Watch Keeper This rest in 24 hour period is redundant! But required!

16 How? - ISF Watch Keeper Hours of Rest now identify: 15 periods of less than10hrs rest a day (But the 7 day totals are all OK!!)

17 How? - ISF Watch Keeper End of Month Summary: - also indicates 15 days of nonconformance Notice comments: Compliant using 2 day rule not to ILO.. Actions Required?

18 How? - Alternative Software Ideas:

19 How? - Alternative Software Ideas: Considers previous 24 hr for every 30 min reports worst in day! (6on-6off now becomes problem)

20 How? - Alternative Software Ideas: Indicates exactly the periods that have been worked while in non conformance!

21 How? - Alternative Software Ideas: Hours of Rest now identifies: 19 periods of less than 10 hours rest a day! (but some of this is while at rest!) and also identifies the 25 periods when the officer worked while in non conformance or Worked while fatigued?

22 How? - Alternative Software Ideas: Ship: Month: End of Month Report Master : 316 hrs 34 hrs 10.76% Ch Off: 342 hrs 126 hrs 36.84% 2/Off: 250 hrs 5 hrs 2.00% 3/Off: 248 hrs 7hrs 2.82% Ch/Eng: 126 hrs 0hrs 0.00% 2 nd /Eng: 240 hrs 0hrs 0.00% Ch/Ck: 368hrs 12hrs 3.26% etc End of Month Report: Investigate greater than X %? How good are 2/O + 3/O?? Engineers recording correctly? Ch Ck Overtime over reported? Ship Total: 4,550hrs 190hrs 4.17% Trends? - Ship / Rank / Individuals? Actions required?

23 So Demonstrate Compliance. Decide Which legislation applies to you now, and in future?

24 So Demonstrate Compliance. How are you going to monitor it?

25 So Demonstrate Compliance. Is your SMS correctly worded?

26 So Demonstrate Compliance. Have you got software that will work for you?

27 So Demonstrate Compliance. Do the crews understand the rules and the software and will they record accurately? (They will need training?)

28 So Demonstrate Compliance. How will you deal with systemic high non conformance on particular ships/trades?

29 So Demonstrate Compliance. How will you deal with systemic high non conformance in particular ranks?

30 So Demonstrate Compliance. How will you deal with systemic high non conformance in particular individuals?

31 So Demonstrate Compliance. Include the topic in your office safety meetings / KPI visible to auditors etc

32 A Parting Thought?? Would you fly home in an aircraft where the Pilot had been fatigued while at the controls 25 times in the last month? - and the Operator had no idea what the level of fatigued was on his flight deck???