Recently a general cargo vessel in France faced difficulties during a “more detailed inspection” by PSCO with below deficiency imposed with action code 99:
“Discrepancies between records of working hours and real organization on board several drills periods not recorded as non resting time – Example for records
dtd 06/10/15 and 18/01/15 – Master instructed to avoid this from now and on”.
Based on above and in accordance with MLC ILO 2006 Title 2 / Reg. 2.3:
“Musters, fire-fighting and lifeboat drills, and drills prescribed by national laws and regulations and by international instruments, shall be conducted in a manner
that minimizes the disturbance of rest periods and does not induce fatigue”
“When a seafarer is on call, such as when a machinery space is unattended, the seafarer shall have an adequate compensatory rest period if the normal period of rest
is disturbed by call-outs to work.”
It is recommended to instruct Master’s of your Company’s fleet accordingly.
