The Australian Maritime Safety Authority (AMSA) has issued a vital Marine Notice (specifically Marine Notice 2025/03, “Watchkeeping and crewing standards,” issued on July 3, 2025) outlining its clear expectations for vessel owners and operators regarding critical aspects of maritime safety and seafarer welfare.
International Framework for Fitness for Duty
- STCW Convention (Standards of Training, Certification and Watchkeeping for Seafarers): This convention specifically mandates that administrations must consider the danger posed by fatigue of seafarers, particularly for those whose duties involve the safe and secure operation of a ship.
- Maritime Labour Convention (MLC): The MLC requires ships to have a sufficient number of seafarers to ensure safe, efficient, and secure operations under all conditions. This includes explicitly taking into account concerns about seafarer fatigue and the unique nature and conditions of each voyage.
- International Safety Management (ISM) Code: The ISM Code stipulates that each ship must be appropriately crewed to encompass all aspects of maintaining safe operations on board, thereby indirectly addressing the impact of crewing levels on fatigue.
Fatigue and Crewing
Appropriate crewing is essential to mitigate the risk of fatigue. Fatigue, encompassing both physical and mental exhaustion, poses a severe threat to safety, performance, and the overall well-being of seafarers. Fatigued crews are significantly more prone to:
- Making mistakes
- Suffering injuries
- Failing to adhere to proper watch-keeping protocols
- Missing early warning signs of dangerous situations developing
While the STCW Convention and MLC stipulate minimum hours of rest requirements, these alone are often insufficient to prevent fatigue. Other contributing factors, such as:
- Sleep quantity and quality: Interrupted or poor-quality sleep is a major issue.
- Circadian rhythms: Disruptions to natural sleep-wake cycles.
- Environmental conditions: Noise, vibration, temperature extremes, and ship motion.
- Task demands: The intensity and complexity of work tasks.
These factors can exert immense pressure on crews, compromising their vigilance, efficiency in duty performance, and ability to respond effectively to emergencies, even when statutory rest hours are technically met.
Therefore, ensuring appropriate crewing is a primary factor influencing the amount and quality of rest seafarers receive. This includes optimizing:
- Hours worked
- Work schedules
- Average time off work
- Other key factors that can influence or elevate the risk of fatigue.
Operators must ensure appropriate crewing levels in accordance with ISM Code requirements and the Principles of Minimum Safe Manning to maintain safe operations onboard at all times.
Watchkeeping Arrangements
Research into watchkeeping shift schedules has consistently identified the 6 hours on, 6 hours off (6-on, 6-off) watch schedule as a significant contributor to seafarer fatigue. Compared to other schedules, this arrangement is associated with:
- Less daily sleep: Seafarers struggle to obtain sufficient total sleep.
- Poor-quality, fragmented sleep: Sleep is often interrupted and less restorative.
- Increased likelihood of nodding off (micro-sleeps): Dangerous brief episodes of unintended sleep.
- Excessive sleepiness: Particularly pronounced in the early morning hours, coinciding with a natural dip in alertness.
This type of schedule often prevents a seafarer from achieving the minimum 6-hour continuous block of rest required by the STCW Convention. It also negatively impacts the quality of watch handovers, leading to failures in meeting the prescribed expectations for effective handovers under the STCW Convention.
A notable case illustrating these dangers is the 2016 investigation by the Transport Safety Board of Canada into the grounding and sinking of the Articulated Transport Barge (ATB) Nathan E Stewart. The investigation found that the officer on watch, who was on a 6-on, 6-off schedule, suffered acute sleep and circadian rhythm disruption for three consecutive days prior to the grounding. This watch schedule was identified as a major contributing factor to fatigue, leading to the watchkeeper falling asleep and missing a crucial course alteration, resulting in the ATB running aground.
AMSA’s Expectations for Safe Watchkeeping
The Australian Maritime Safety Authority (AMSA) is committed to upholding the requirements of all relevant Conventions to ensure all seafarers are fit for duty. AMSA’s clear expectation is that operators of vessels in Australian waters must demonstrate compliance with Convention standards and adequately consider the risks associated with fatigue.
AMSA specifically considers that the difficulties faced by watchkeepers in providing or receiving a proper watch handover, as well as meeting minimum rest requirements, directly challenge the effectiveness of a 6-on, 6-off working arrangement.
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Source: Australian Maritime Safety Authority
