Managing fatigue and hours of rest
Fatigue is more than feeling tired and drowsy. Fatigue is a state of mental and/or physical exhaustion that reduces the ability to work safely and effectively.
The recent release by AMSA of the proposed changes to Marine Order 504 sets out increased requirements for fatigue management to be included in a vessel SMS.
Survey findings and feedback from industry in recent years has indicated that more needs to be done to address the risks of fatigue for masters and crew. In 2022, AMSA published the results of a 2019 survey on fatigue awareness in the DCV industry.
Findings from the survey showed:
- 40 per cent of respondents got less than six hours sleep in any 24-hour period when out at sea,
- 25 per cent of respondents stated they experienced fatigue ‘very often’ or ‘most of the time’ either ‘immediately before’ or ‘during’ their time at sea,
- 50 per cent of respondents indicated that they had either ‘not received’ any fatigue management training or guidance or they were ‘unsure’.
AMSA also received feedback during the last MO504 consultation in 2022-23 that there should be greater consideration to further strengthening requirements to address the risk of fatigue.
AMSA regulations (Marine Order 504) define ‘rest’ as ‘a period of time when a person, except in the case of emergency, is free of all duties and functions.’
Currently this requires the master and each crew member to have at least 10 hours rest in each 24-hour period if the vessel is operating with minimum crewing arrangements. (See Marine Order 504, Schedule 1, 6A(2)(c)).
AMSA is NOT proposing an immediate change to the ‘hours of rest’ in the current list of proposed Phase 2 changes to MO504.
AMSA sought input from industry to understand current arrangements and the benefits and/or challenges of applying existing rest requirements to all vessel masters and crew.
The proposals for change to the regulations may include that operators can decide whether the minimum of 10 hours rest in each 24-hour period is:
- Continuous (ie 10 hours straight rest)(this AMSA’s recommendation)
- Cumulative (ie made up of a number of shorter rest periods).
You can read more about the proposed changes here.
In particular, AMSA wanted to know
- How does industry ensure adequate rest for masters and crew?
- If each master and crew member is getting less than 10 hours of rest in each 24-hour period, why is this?
- What barriers are faced in providing the additional hours of rest?
You can read the WAFIC submission here.
Learn more about how to manage crew fatigue here.