Where this sits
Governing: MSN 1877 (M) Amendment 1 (MLC Hours of Work Regulations 2018); MGN 505 (M) Amendment 1; MGN 590 (M+F); Railways and Transport Safety Act 2003, ss.78 and 81; COSWP 3.6. Builds on: L3.1.
Fatigue
COSWP 3.6.1 quotes the IMO definition (MSC/Circ.813): fatigue is "a 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." Tired crew fall off things, miss hazards and make bad calls on the helm.
The company and master should organise work to limit fatigue, but you have a duty too (3.6.3-3.6.4):
- arrive on board rested;
- take your scheduled rest and aim for about eight hours' sleep in 24;
- eat properly and lightly before sleep; avoid alcohol and caffeine before bed;
- put screens away before sleeping;
- record your hours of rest accurately.
Hours of rest (MSN 1877)
MSN 1877 applies the MLC hours of work regulations and states that charter yachts are covered (2.3).
| Rule | Minimum |
|---|---|
| Rest in any 24-hour period | 10 hours |
| Rest in any 7-day period | 77 hours |
| Daily rest split | No more than two periods, one at least 6 hours |
| Interval between rest periods | No more than 14 hours |
Worked check: rest 2300 to 0700 (8 h) and 1300 to 1500 (2 h) gives 10 hours in two periods, the longer being 8 hours. The longest gap between rest is 0700 to 1300 (6 h) or 1500 to 2300 (8 h), so all within 14. Compliant.
Other points:
- Short breaks are not rest (4.2).
- A call-out during rest earns compensatory rest (4.1).
- In an emergency, the master may suspend the schedule, then must give adequate rest (7.1).
- A table of duties is posted in an accessible place (6).
- Records are kept for each seafarer, completed at least monthly in arrears, endorsed by the master and the seafarer, and kept for at least one year (8).
WARNING: Honest records Falsified rest records hide exactly the fatigue that causes accidents, and they expose you as well as the yacht. Record what you actually worked.
Alcohol
Under STCW regulation VIII/1 the limit is 0.05% blood alcohol or 0.25 mg/l in breath. The UK aligned its law in 2015 (MGN 590):
| Medium | STCW | UK (RTSA 2003 s.81) |
|---|---|---|
| Blood | 0.05% | 50 mg per 100 ml |
| Breath | 0.25 mg/l | 25 micrograms per 100 ml |
| Urine | none | 67 mg per 100 ml |
Under s.78, a professional master, pilot or seaman on duty commits an offence if their ability is impaired by drink or drugs, or if they are over the limit. MGN 590 also says it is an offence to be impaired at any time on board if you might be required for emergency duties. It recommends company policies banning alcohol for four hours before a watch. Most yachts go further, with zero-tolerance rules during charter or under way.
Drugs and medication
Recreational drugs are a sacking offence on almost every yacht and a criminal matter in many ports. Tell the responsible officer about prescribed medication that could affect alertness (COSWP 3.4), and check before mixing medication with alcohol.