Seafarers’ Hours of Work and Rest Regulations – MCA Review

Circular No: NP/062/25

 

TO ALL MARITIME BRANCHES AND REGIONAL COUNCILS

 

Our ref: S6/1

 

1^st April 2025

 

Dear Colleagues

 

Seafarers’ Hours of Work and Rest Regulations – MCA Review

 

The Maritime and Coastguard Agency is reviewing the UK regulations governing seafarers’ hours of work, specifically the Merchant Shipping (Maritime Labour Convention) (Hours of Work) Regulations 2018.^[1]

 

The regulations reflect the Maritime Labour Convention’s (MLC) minimum hours of work and rest for all seafarers, including Ratings. The legal minimum hours of rest for seafarers are:

 

• 10 hours in any 24-hour period; and
• 77 hours in any 7-day period

 

RMT agreements are generally above the minimum standards in these regulations. However, Section 7 of the Regulations grant exemptions for collective agreements that only require 70 hours of rest in any 7-day period. We need to know if any operators, whether they recognise the RMT or not, are using this exemption to make seafarers work longer.

 

We are concerned that some employers are using these regulations to undermine seafarers’ rights and welfare. Seafarer fatigue is a major concern for your union and a series of international studies^[2] show that there is a widespread problem in the reporting and compliance with seafarers’ hours of work and rest regulations. 

 

Your union also has other concerns relevant to this review, such as Ratings working split 6 hour shifts which damage seafarers’ physical and mental health, even as part of two-week on, two-week off roster patterns. Your union has raised this and other concerns at the MCA’s Fatigue Working Group.

 

I would be grateful if branches and members could provide any evidence of concerns over seafarers’ hours of work and rest to the National Policy Department d.crimes@rmt.org.uk by Wednesday 9^th April. The narrow window for responses reflects the MCA’s deadline. 

 

You will be kept advised of all further developments in this matter.

 

Yours sincerely

 

Eddie Dempsey

General Secretary