1. Incidents, Fatigue & Fatigue Management INTERTANKO - October 2006. David George – Global Ship Quality Assurance Manager Nick Roberts – Senior Ship Assessor

3. Innumerable Studies Agree - Fatigue Causes….. Performance variability Slowed physical and mental reaction time Increase in work related errors Increased tendency to persistently repeat behaviours Increase in false responding Increase in memory errors Decreased vigilance Reduced motivation and laxity

4. Fatigue is not well considered at sea, and yet its effects are insidious Stephen Meyer Chief Inspector of Marine Accidents MAIB April 2005 The study…concluded that….watch keeper fatigue was a major factor in many accidents, and particularly groundings…and will be no surprise to officers involved in the short sea trade in particular MAIB Safety Digest 1/2005

5. The HOW Rules – STCW & ILO180 RegulationWork/Rest in 24 hrs Work Rest in 7 days No & Length of Rest Periods ScheduleRecords STCW10 hrs rest. This may be reduced to 6 hours for not more than 2 days 70 hours rest (equates to 98 hrs work) Not more than two periods of rest, one of which must be at least 6 hours Sets out hours of work for watch keepers ILO 180 Guidelines 14 hrs of work Or 10 hours of rest 72 hrs work Or 77 hrs rest Not more than two periods of rest, one of which to be 6 hrs. Interval between rest periods not to exceed 14 hrs Specific format table for every position. Actual times for at sea and in port Daily hours records to be maintained to specific format

6. Which HOW Rules apply Which HOW Rules apply? (ILO rule what ILO rule?) ILO 180 Convention ratified by 20 nations ILO 180 imposed by EU on member states ILO Consolidated Convention on Maritime labour standards. EU Port State instructed not to disadvantage EU ships when considering HOW systems in place on Non-EU ships. STCW US legislation

7. Summary of ILO Guidelines… Any 24 hours -10 hrs off; no more than 2 periods; one period of at least 6 hours In 7 days - 77 hrs of rest or 72 hours of work If called during rest – Compensatory rest Schedule – To give times every individual will work Records – To be completed monthly to specified format

8. Concerns Interrupted rest becomes two periods (Emergencies Mooring; Drills; Paperwork; Meal relief etc!). Dayworker with regular 10 hour rest out of conformance every rest period Schedule requirement – Wrong People at Wrong Times Complexity - Computer analysis required to spot non conformance. Management unaware of levels of Non conformance

9. Main Changes from STCW… Loose 2 days at 6 hours rest 7 day rest requirement increases to 77 hours OR 7 day work requirement reduced to 72 hours Schedule to specific format and requires actual times of work Record of Working hours to a specific format Record of Working hours for all on board

10. Typical Work Patterns..

14. Other Observations…. Scope for exceptions bycollective agreement Rules acknowledge drills /alarms/ emergencies will create non-conformance – requires compensatory arrangements Non conformance applies to rest periods or work periods?

15. Getting it Wrong… Fatigue…..Real or imagined… Incidents Port State Observations – Worse to come? SIRE observations/ Incidents / Oil Major concerns? Most Companies measure when their Lube oil is getting tired – lets do it for our crews?

16. Who Has Signed up…. (From ILO June 2006) Belgium10/6/03 Bulgaria24/2/03 Denmark10/7/03 Finland4/7/02 Greece14/5/02 Ireland22/4/02 Latvia 13/1/06 Luxembourg 30/11/05 Malta 19/9/05 Morocco1/12/05 Netherlands 16/6/03 Norway22/10/03 Romania11/10/00 St Vin & Gren 8/2/05 Seychelles28/10/05 Slovenia21/07/04 Spain 7/1/04 Sweden15/12/00 UK20/12/01 Plus all other EU States….. Plus those now signing ILO Consolidated Convention…….