CMM	Crew Management Manual (CMM) Work and Rest Hours	Doc No.: CMM-6.17 Revision: 01 Date: 15 Oct 2024 Issued by: DPA Approved by: MD

1. APPLICATION

This document is applicable to senior management onboard vessels and shore personnel as identified within the scope of this document.

2. PURPOSE

The purpose of this document is to provide instructions regarding management of work and rest hours onboard and record keeping, reporting requirements so as to prevent fatigue.

Fatigue is defined as reduction in physical and/or mental capability as the result of physical, mental, or emotional exertion which may impair nearly all physical abilities including strength, speed, reaction time, coordination, decision-making, or balance.

3. RESPONSIBILITIES

• Chief Engineer – Head of Department (HoD) of Engine department is responsible for planning and scheduling the Engine Department staff work hours.
• Chief Officer – HoD of Deck department is responsible for planning and scheduling the Deck & catering department staff work hours.
• Master – Overall responsible person to verify and approve the schedule of work and rest hours of the crew and monitor compliance to record keeping and reporting requirements.
• FLP dept – Ensure the vessel’s work rest hour data is imported into the shore-based software platform at least once every 3 days. Review the data and provide a response to the master. Escalate any violations to the Marine Superintendent for further action.

4. MINIMUM SAFE MANNING LEVEL

• Master shall ensure that the vessel meets minimum safe manning levels at all times.
• If not, inform crewing operations immediately and obtain flag dispensation as required.

5. PLANNING, RECORDKEEPING, MONITORING & REPORTING

PLANNING

HOD’s shall:

• Plan and schedule the work to ensure rest hour regulatory requirements as per Table 1.
• Prepare CRV-06 - Table of Shipboard Working arrangements and display on the notice board in common areas, Engine control room, and Bridge as appropriate.
• Alert Master in case of a potential violation of rest hours after preparing the work schedule.

Master shall:

• Ensure that the vessel complies with the work rest hours requirements as per:
  • Vessel’s flag state
  • STCW
  • MLC
  • OPA-90 (only applicable to tanker vessels while in US EEZ waters)
• Plan musters, firefighting, and lifeboat drills, and drills prescribed by national laws and regulations and by international instruments in a manner that minimizes the disturbance of rest periods and does not induce fatigue.
• Review the work schedule with the HOD and try to re-work the schedule if there is a potential violation reported by the HODs.
• Consult the MHSSEQ Superintendent of the vessel if unable to resolve the potential violation raised by the HODs.

Table 1: Work Rest Hours Requirement

STCW	ILO/MLC 2006	OPA 90 (only applicable to tanker vessels)
(As amended by the 2010 Manila amendments which entered into force on 1st January 2012)	(The provisions of ILO 180 have been included in the Maritime Labour Convention, 2006 which has come into force in 2013) (as amended by 46 U.S.C 8104)	OPA 90 Work rest hour only applicable tanker vessels while in US EEZ waters
Minimum 10 hours of rest in any 24-hour period		No requirement for hours of rest in any 24 hour period
Minimum amount of rest in any 7-day period = 77		No requirement for hours of rest for 7 day period
No restriction on maximum hours of work in any 24-hour period	Maximum 14 hours of work in any 24-hour period	Maximum 15 hours of work in any 24 hour period
No restriction on maximum hours of work in any 7-day period	Maximum 72 hours of work in any 7-day period	Maximum 36 hours of work in 72 hours
No restriction on maximum hours of work in any 7-day period	Maximum 72 hours of work in any 7-day period	Maximum 36 hours of work in 72 hours
Hours of rest may be divided into no more than two periods, one of which shall be at least six hours in length
Interval between rest periods not to exceed 14 hours

Table 2: Recordkeeping, monitoring and reporting

Frequency	Task	Responsibility	Remarks
Daily	Work and rest hours for every crew member shall be recorded in the software	HOD	HOD may assign a person to do the data entry into the Work Rest software, however HOD remains accountable
Daily	Verification of the work rest hours of all the crew	HOD	In case of any data entry errors then the same to be rectified immediately. Any valid violation to be reported to the Master
Once in three days	Exports the software once every 3 days as a minimum and any deviation from this to be advised to the MHSSEQ superintendent with reasons	Master	If unable to export, then inform MHSSEQ Superintendent accordingly
Weekly	Verify work rest hours are entered for all the crew. Conduct sample checks against the actual operations carried out eg: bunkering, cargo operations, tank cleaning, drills, UMS, pilotage etc	Master
Monthly	Provide a printout from the software with details of work rest hours for the month to the crew members and get their acknowledgement and file it onboard	HOD
Monthly	A summary report from the software sent to be sent to the Marine Manager / respective MHSSEQ Supt at the end of the month.	Master
Monthly	One violation per crew per month: Explain in remark column of rest hour sheet give compensatory rest and plan ahead to avoid recurrence. Two violations per crew per month: Master is required to investigate the cause of violations and submit feedback to office. Three violations per crew per month Master to raises a consolidated Non-Conformity and reverts with TSM Form 097 complete with Identified Root cause, Immediate Corrective Action and Long-Term Corrective Action.	Master
Vessel Visits	During vessel visits, carry out sample checks of crew work rest hours records of crew members against the actual operations.	VM/MHSSEQ Supt

• Musters, firefighting and lifeboat drills, and drills prescribed by national laws and regulations and by international instruments must be stated as work hours. Refer to respective Work and Rest hours Software for detailed user guide.
• A hard copy of the endorsed hours of rest must be retained onboard the vessel for a minimum period of 12 months.

• Nothing in the above sections shall be deemed to impair the right of the master of a ship to require a seafarer to perform any hours of work necessary for the immediate safety of the ship, persons on board or cargo, or for the purpose of giving assistance to other ships or persons in distress at sea. Accordingly, the master may suspend the schedule of hours of rest and require a seafarer to perform any hours of work necessary until the normal situation has been restored. As soon as practicable after the normal situation has been restored, the master shall ensure that any seafarer who have performed work in a scheduled rest period are provided with an adequate period of rest.

Practical Compliance / Role of Shore Management

Management of Watch Keeping & Working Routines

Generally, the three-watch system such as 4 on / 8 off, provides an optimal approach although non-conformances will be triggered by periods of additional work if they are not properly planned and managed.

A two-watch system, such as 6 on / 6 off, will provide short-term compliance although technical non-conformances will occur during each rest period under both the STCW and MLC Conventions. In addition, any period of additional work will result in significant non-conformances during subsequent work periods.

If necessary, Master may implement 5 on/7 off watch schedule to provide enough rest to the crew and meet the minimum rest hours regulations.

Day workers are generally viewed as being relatively straightforward when managing their work/rest periods. However, callouts and the response to alarms will impact on their ability to comply with minimum rest period requirements. Good planning and, where necessary, the adoption of compensatory rest periods will serve to limit the number of recorded non-conformances.

Crew should be given holiday on Sundays as much as practically possible.

On vessels with an additional deck officer for watchkeeping and where the Chief Officer is primarily on day work, the Master shall ensure that minimum 4 navigational watches per month are assigned to the Chief Officer to maintain his navigational skills.

Drills and training, fire rounds, and attending to UMS alarms are to be recorded as work.

According to IMO and OCIMF guidelines, musters, firefighting 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.

A short break is by definition considered as neither work nor rest. The definition of how long a short break is varies from Flag State to Flag State. When calculating rest, these break periods are ignored and not counted as rest. Software allows the user (vessel) to select their Flag’s interpretation of short breaks if one of the following:

• Do not exclude short breaks from rest hour count (short breaks are less than 30 mins)
• Short breaks are less than 1 hour
• Short breaks are less than or equal to 1 hour

For Company managed vessels, any break of 60 mins or less (0-60 mins) shall be excluded from the rest period.

Experience has shown that the levels of non-conformance on a vessel can be significantly reduced by enhanced awareness and management on board.

Over-reliance should never be placed on one individual, risking adverse impact on normal rest period requirements.

Role of Shore Management

Company provides proper guidance on the management of fatigue, its impact on safety, and the regulation of hours of work/rest.

Seafarers must alert their onboard managers should they be working, or at risk of working, in non-conformance or violations of the minimum requirements.

Masters are required to inform Crew Manager/respective MTSI immediately in case of:

• Anticipated periods of high workload, which may require additional personnel onboard.
• Proposed suspension of operations, for complying with rest hours after a period of high workload.

In the event of significant non-conformance, the Master is authorized to take action which may include the suspension of operations until personnel are suitably rested. Prior to that decision, the Master should have raised the issues and sought guidance from the marine department.

AA) Shore Management Actions: Shore management should also be aware of, and react to, planned or expected periods of high intensity operations and ensure that staffing on board is adequate in good time prior to the planned operations.

Operations should include, but not be limited to:

• Prolonged single STS operation. (>4 continuous operations)
• Prolonged port operations during a single call (>5 days or more)
• Vessel on short trades / hectic trade involving cargo operations and mooring/unmooring operations at more than 2 berths. (Frequent port calls, more than 7 port calls a month, or calling port every 3 days)
• Dry-dock preparations

BB) Monthly Monitoring by Shore Management (MTSI): Shore Management (MTSI) should ensure the following is done every month to ensure proper monitoring of work and rest hours:

• Discuss with the Master rest hours planning.
• Discuss the NC and violations in the rest hour management for the previous month.

CC) Monitoring and Evaluation: MTSI to monitor and evaluate rest hours received from the vessel once every 7 days and conduct a review and analysis in cooperation with TSI. Any major concerns to be raised to Senior Management by the Marine Manager.

Respond to NC raised by the vessel on breaches of hours of rest – Each NC to be evaluated and responded to accordingly.

Escalation to Marine Manager: The following should be escalated to the Marine Manager:

• Any operation as mentioned under AA.
• Any request for additional resources.

7. ADDITIONAL CREW

Master shall request for additional crew if the Vessel is unable to meet minimum rest hours as per the various regulations due to:

• Constant violation of rest hours
• Increased operations or maintenance
• Increased transits through high-risk areas/change in security requirements
• Change of trading pattern or area
• Hectic trade with fast turnaround and high number of operations
• Any other reason which may have an impact on crew rest hours

The Master shall send the request to MTSI with a copy to Crewing Operations.

8. SHORT-HAND MANNING

The Master shall re-schedule the working hours in the case of short-hand manning onboard due to some urgency until the manning levels are back to normal.

9. SOFTWARE

The Master shall use ISF Watch Keeper or similar DSM software to record the work and rest hours.