PSC deficiency code 18201: Fitness for duty - work and rest hours
Area 18 Maritime Labour Convention, 2006
This code is about fatigue: whether people on board, watchkeepers above all, get the rest the conventions require, and whether the records show it honestly. Inspectors check the paperwork and then test it against what the ship was actually doing.
What the inspector looks at
- The table of shipboard working arrangements is posted, in the working language and in English
- Rest hour records exist for every seafarer, are signed by the seafarer and the master, and the seafarer has a copy
- Recorded rest meets the minimums, and any breach is shown as a breach rather than hidden
- Records match the deck and engine log books, port arrival and departure times, cargo operations and drill times
- Masters and chief officers on two-watch ships, who are the usual pressure points
- What the company does when records show non-compliance
Common findings
- Records of hours of rest not reflecting actual hours worked during port stay
- Identical rest hours recorded for whole month, not credible
- Minimum hours of rest not complied with, no corrective action
- Table of shipboard working arrangements not posted
- Records not signed by seafarer, no copy given
- Drills held during rest periods not taken into account
The rule behind it
MLC 2006 Regulation 2.3 and Standard A2.3 set the limits, and STCW regulation VIII/1 with section A-VIII/1 of the STCW Code applies them to watchkeepers. Each flag sets either maximum hours of work or minimum hours of rest. The usual rest figures are at least 10 hours in any 24 hours and 77 hours in any 7 days, split into no more than two periods, one of them at least 6 hours long, with no more than 14 hours between periods. Limited exceptions are possible where the flag allows them, and for watchkeepers only within the conditions STCW sets.
Action codes you are likely to see
Missing signatures or a table that isn't posted are typically 17 or 10. Records that don't reflect reality, or breaches with no response, often get 16 or 17 plus an ISM deficiency (15150). Where a watchkeeper or the master is so short of rest that the ship can't sail safely, the inspector can treat it as a ground for detention (30) until rested crew are available. See action taken codes.
How to close it
Correct the records so they show actual hours, including breaches, and have them signed. Post the table and give seafarers their copies. Where breaches came from workload, the evidence that closes it is a change: extra crew for port calls, a revised watch system, or rescheduled drills, recorded through the SMS. Keep the corrected records, the company's response and any crew change documents with the Form B.