• A minimum of 6 continuous rest hours in any 24 hour period
• A maximum of 14 total work hours in any 24 hour period
• A maximum of 72 total work hours in any 7 day period

The minimum of 10 hours rest in any 24 hour period may be divided into no more than 2 periods, one of which shall be at least 6 hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours.

STCW 2010 applies to all persons who are assigned duty as an officer in charge of a watch or as a rating forming part of a watch (watchkeepers) and those whose duties involve designated safety, prevention of pollution and security duties.

The IMO STCW 2010 Manila Exceptions are conditional relaxations of the core IMO STCW 2010 rest hours regulations. There are two possible relaxations:

Weekly
• The minimum hours of rest in any 7 day period may be reduced from 77h to 70h for a period of up to 2 consecutive weeks. Once used, the seafarer may then not use the exception again for twice the period of exception. For example, if using the exception for 2 consecutive weeks, the exception may not then be used for the following 4 weeks.

Daily
• The minimum of 10 hours of rest in any 24h period may be made up of 3 rest periods, one of which must be at least 6h in length and the other two periods must be at least 1h in length.
• This exception can be used for a maximum of 2 x 24h periods in any 7 day period.

Manila exceptions can be used together or separately.

The Manila Exceptions may only be used on vessels where the flag state permits their use, and where collective bargaining agreements are in place (with written evidence on board) to permit their use.

The MLC 2006 regulations for work and rest hours can be adopted in one of two flavours, the ‘work’ based rules and the ‘rest’ based rules. the ‘work’ based rules are:

• A minimum of 6 continuous rest hours in any 24 hour period
• A maximum of 14 total work hours in any 24 hour period
• A maximum of 72 total work hours in any 7 day period

The hours rest may be divided into no more than 2 periods, one of which shall be at least 6 hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours.

The MLC 2006 regulations for work and rest hours can be adopted in one of two flavours, the ‘work’ based rules and the ‘rest’ based rules. the ‘rest’ based rules are:

• A minimum of 6 continuous rest hours in any 24 hour period
• A minimum of 10 total rest hours in any 24 hour period
• A minimum of 77 total hours rest in any 7 day period

The minimum of 10 hours rest in any 24 hour period may be divided into no more than 2 periods, one of which shall be at least 6 hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours.

The United States of America Oil Pollution Act of 1990 (OPA 90) states that on a tanker operating in USA waters, a licensed individual or seaman may not be permitted to work more than 15 hours in any 24 hour period, or more than 36 hours in any 72-hour period, except in an emergency or a drill.

In this subsection, “work” includes any administrative duties associated with the vessel whether performed on board the vessel or onshore.

This regulation is applied in addition to any applicable international water regulations such as STCW 2010 or MLC 2006.

These recommendations are an interpretation of how STCW 2010 and MLC 2006 rest hours calculations should be made. They are based on same core requirement of STCW 2010 and MLC 2006:

• A minimum of 6 continuous rest hours in any 24 hour period
• A minimum of 10 total rest hours in any 24 hour period
• A minimum of 77 hours rest in any 7 day period

The minimum of 10 hours rest in any 24 hour period may be divided into no more than 2 periods, one of which shall be at least 6 hours in length, and the interval between consecutive periods of rest shall not exceed 14 hours.

In ISF Watchkeeper, this regime complies fully with the OCIMF “Recommendations Relating to the Application of Requirements Governing Seafarers’ Hours of Work and Rest”.

These recommendations are minimum expectations to ensure compliance with related provisions and are provided for the information of OCIMF members, managers and the crew of applicable vessels.

Notwithstanding anything above, vessels are required to fully comply with their flag state requirements.

Please Note: STCW 2010 Manila Exceptions.
These exceptions can only be used if permitted by flag state regulations.

OCIMF consider that hours worked under these exceptions may still contribute to fatigue and therefore no allowance is made under this interpretation. (See above).

STCW 2010 applies to all persons who are assigned duty as officer in charge of a watch or as a rating forming part of a watch (watchkeepers) and those duties involve designated safety, prevention of pollution and security duties.

No. This is a common misinterpretation of the rules. It is contrary to the intention of the regulations to restrict rest. In fact, seafarers can have many rest periods per day, but only 2 rest periods can be used when calculating the minimum of 10h of rest in any 24h period. ISF Watchkeeper automatically makes this calculation.

With ISF Watchkeeper, record-keeping and data entry is simple, efficient and secure, meeting stringent data protection requirements and offering unique benchmarking against industry average non-conformance for work and rest hours.

You can manage your hours online, via our desktop app, or using our cloud based and mobile solution, providing instant access on smartphone, Mac, tablet and PC, meaning you can update work rest hours in real time, sign off timesheets while on the move and sail through any port state control inspection.

ISF Watchkeeper makes handling work and rest hours simpler, by providing the ability to pre-plan work schedules, reducing the time and effort required logging hours and managing compliance.

If a seafarer has exceeded the maximum working hours, or has not met the required minimum number of rest hours, then a compensatory rest period must be taken.

On 25th June 2010, IMO members gathered in Manila to amend the STCW 95 convention, to improve the global needs for safety and environment policy as well as ensuring the correct training and certification was in place on vessels to safely operate the advancing technology.

Rest hours onboard were increased from 70 hours to 77 hours per week to ensure a safe, efficient working practice for seafarers.

The 2010 STCW Manila amendments entered into force from the 1st January 2012.

There may be times when a master requires a seafarer to be on duty during a rest period, for example in an emergency or if the safety of the ship is at risk.

If this is the case then as soon as normal conditions have been restored, the seafarer should be provided with a suitable compensatory period of rest. This means that they are provided with sufficient rest to no longer be in non-conformance.

Training and operations like lifeboat drills, fire-fighting drills, and drills prescribed by national laws and regulations are not counted towards working hours by the compliance regimes.

Training and drills should, therefore, be conducted in a manner to ensure minimum disruption of the main daily rest period.

Fatigue onboard the ship is one of the major safety and performance concerns for seafarers. Ship working hours become a very important aspect of not only a vessel’s ability to function safely and effectively but the efficiency of its crew and officers too.

Failure to maintain individual seafarers’ work hour records that comply with the global format adopted jointly by the International Labour Organization (ILO) and the International Maritime Organization (IMO) could result in Port State Control difficulties, including possible ship detention.

Effective planning both on the ship and from the shore is essential to understand and manage non-conformance on any fleet. ISF Watchkeeper includes a wide range of tools for the Captain and for shore based decision makers to be informed about work activity ahead of time in order to maximise compliance.

ISF Watchkeeper has extensive data to help you understand which ports have the highest risk of non-conformance for your fleet.

ISF Watchkeeper has many tools to help you detect and understand which ranks experience the most rest hour compliance pressure.

ISF Watchkeeper has numerous tools to manage this for you and allow you to set pre-defined thresholds to detect and manage non-conformance and to identify risk areas.

This is a comprehensive feature of ISF Watchkeeper whereby you can set thresholds and be notified when they are breached to detect high non-conformance. It is a great way to manage records as they come in from a large number of vessels.

• IMO STCW
International Convention of Standards of Training, Certification and Watchkeeping for Seafarers, 1978, as amended (IMO STCW)
• ILO MLC
Maritime Labour Convention, 2006 (MLC)
• ILO C180
Seafarers’ Hours of Work and the Manning of Ships Convention, 1996 (C180)
• OPA 90
The US Oil Pollution Act of 1990 (OPA 90)
• OCIMF
Oil Companies International Marine Forum Recommendations Relating to the Application of Requirements Governing Seafarers’ Hours of Work and Rest (OCIMF), including TMSA 3 and the SIRE 2.0 programme.

Check with the flag state of the vessel if they require MLC or STCW compliance. If they specify MLC then verify if they require the rest based rules or the work based rules. For the rest based rules choose regime “ILO REST”, for the work based rules choose “ILO WORK”, Please note very few flag states follow the work based rules.

For flag states that specify STCW compliance, choose the regime “STCW 2010”. if the flag state further allows the use of the Manila Exceptions and you have collective bargaining agreements that also support this then also tick the “Manila Exceptions” box.

if all else fails / when in doubt, use STCW 2010 without the Manila Exceptions!

In April 2017, OCIMF (The Oil Companies International Marine Forum) released TMSA 3 to provide guidance on the various elements of tanker safety.

TMSA KPI 3A.1.3 requires that procedures ensure that working and rest hours of all personnel are in line with the STCW, applicable flag state requirements or any relevant authority guidelines for the vessel trade and are being accurately recorded and monitored.

• The vessel operator should demonstrate a suitable system in place to record rest hours and calculate conformance in any 24 hour and 7 day period, for each individual onboard, based on the governing requirements of STCW and MLC, or the vessel’s applicable regulations.

• Any duties performed outside a seafarer’s normal working hours, should be recorded against their daily records.

• Monthly non-conformance reports should be submitted to shore management, who should acknowledge the occurrence of 3 or more days’ non-conformance by any individuals in any 30 day period.