MARITIME LABOUR INSPECTION MLC, 2006

MARITIME LABOUR INSPECTION MLC, 2006
Title 3: Accommodation, recreational facilities, food and catering These materials will need to be adapted by Trainers to their own national situations. In particular, a key concept under the MLC, is that the working and living conditions are inspected not for compliance with that Convention directly, but rather for compliance with the national provisions implementing the Convention. As indicated in the module relating to flag State inspection and certification, these presentations cannot take account of the requirements under the national provisions that will be applied by the inspectors, and are therefore necessarily based on the provisions of the MLC, 2006, and in particular its Code containing Standards and Guidelines. In Title 3, there is a mixture of Standards, some of which are generally worded, requiring, for instance, that particular aspects of accommodation or recreation facilities should be “adequate”, and giving examples of what would be considered as “adequate” in the Guidelines, but leaving it to the national provisions to set out the precise requirements. There are other Standards, however, setting out very precise requirements which need to be included in the national provisions (although some flexibility may be possible through “substantial equivalence”). The Trainer should, therefore, where possible refer to the national provisions of the inspectors’ country, especially where their national provisions contain details that differ from the MLC, 2006 provisions. Where, however, the national provisions express any requirements with general wording, such as “adequate” or “reasonable”, the Trainer may need to refer to the Guidelines in Title 3 for more precise guidance on the expectations behind the requirement concerned.

3.1 Accommodation and recreational facilities
3.2 Food and catering The Trainer could refer to the main sources of information for the Module: Title 3 of the MLC, 2006, Regulations 3.1 and 3.2 (which inspectors should have open in front of them) and the national Part I of the DMLC the ILO’s international Guidelines for flag State inspections (flag State inspection guidelines), Chapter 3, section 3.2. the national provisions as set out in the DMLC Part I a sample DMLC Part II The Trainer should note that all three areas covered by Title 3 – accommodation, recreational facilities and food and catering – are subject not only to inspection, but also to certification on the ships to which the certification provisions apply. It could also be noted that the lists in Appendix A5 -I and A5-III set these out as three specific items (accommodation; on-board recreational facilities; food and catering) although there are only two Regulations on the matters ( Regulations 3.1 and 3.2).

ACCOMMODATION AND RECREATIONAL FACILITIES
Regulation 3.1 – Standard A3.1 Guideline B3.1 Purpose: To ensure that seafarers have decent accommodation and recreational facilities on board ILO 92, 133 & 147 The Trainer should point out that it is incumbent on the competent authority to ensure that accommodation and recreational facilities on board ships flying the country’s flag is decent and is consistent with promoting seafarers’ health and well-being. The Trainer should note that this is the basic level to be applied to all ships that are inspected. Unless the country has provisions that differ from the Convention and, for example, require all ships under the flag to meet these standards, the Trainer should note that the conditions set out in the Code of Title 3 which relate to “construction and equipment” apply only to ships constructed on or after the date of entry into force of the MLC, 2006 for the country concerned. In relation to the word “equipment”, the Trainer should explain that it covers fixtures and similar articles to which it would be difficult to make alterations to bring them into line with the Convention. The definition of what is meant by “constructed” should be noted (last sentence of para. 2 of Regulation 3.1). The Trainer should also explain what requirements relating to construction or equipment apply to ships constructed before the MLC, 2006’s entry into force for the inspectors’ country. This explanation will depend upon whether or not the ILO Accommodation of Crews Convention (Revised), 1949 (No. 92) and/or the Accommodation of Crews (Supplementary Provisions) Convention, 1970 (No. 133) were previously applicable (because, in particular, of the country’s ratification either of those Conventions or of the Merchant Shipping (Minimum Standards) Convention, (No. 147)). If one or both of those Conventions were previously applicable, the Trainer should explain that their provisions relating to construction and equipment will continue to apply to ships constructed prior to the entry into force of the MLC, 2006 (Regulation 3.1, para. 2) and a copy of the Convention(s) still applicable should be made available to the inspectors. If neither of those Conventions was previously applicable, the Trainer should note the general requirement that ships must have decent accommodation and recreational facilities that are consistent with promoting seafarers’ health and well-being. In this regard, the Trainer could ask the following question: Question: The sleeping rooms on a ship constructed prior to the entry into force of the MLC, 2006 for the country are much smaller than the sizes prescribed by the Code, giving many seafarers a sense of claustrophobia. Is it right for the inspector to require this situation to be rectified? Answer: Yes. Although the specific requirements relating to construction that are set out in the Code do not apply, the accommodation on ship must still respect the general terms of Regulation 3.1 requiring “decent accommodations … consistent with promoting the seafarers’ health and well-being”.

Basic requirements – Key areas general requirements (Standard A3.1, par. 6) the size of rooms & other accommodation spaces (Standard A3.1, par. 9, 10) heating and ventilation (Standard A3.1 par. 7) noise and vibration & other ambient factors (Standard A3.1, par. 6(h)) sanitary & related facilities (Standard A3.1, par. 11, 13) lighting (Standard A3.1, par. 8) hospital accommodation (Standard A3.1, par. 12) recreational facilities (Standard A3.1, par. 14, 17) occupational safety & health and accident prevention (Standard A3.1, par. 2(a), 6(h)) A3.1.4, R4.3 The Trainer should refer the inspectors to Standard A3.1, noting that this section of the Code lays down the basics for the accommodation and that its first five paragraphs are concerned with the making of laws and their application (to be summarized in the country’s DMLC Part I). The Trainer should draw the inspectors’ attention to paragraph 4 of Standard A3.1, setting out six key areas in which implementation of the requirements of the Convention must be ensured. The Trainer should note that these six items, as well as some other areas that must also be considered, are all listed in the slide. Reference can also be made to the suggestions in the guidelines for flag State inspection, Section 3.2.

Basic requirements Flexibility Variations & exemptions A3.1.19 A & 21 FS Guidelines Ch. 2 par. 35 to 44 The Trainer should point out that Standard A3.1 contains some flexibility that can be exercised by the competent authority after consultation with the shipowners and seafarers organizations. There are: some specific provisions relating to special purpose ships, passenger ships and ships less than 3000 GT; Standard A3.1, para. 19 provides that “fairly applied variations” may be permitted to take account of differing and distinctive religious and social practices; however this cannot result in overall faculties that are less favourable than would have existed for seafarers if Standard A3.1 had been applied Standard A3.1, paras 20 and 21 also allow the country to exempt ships of less than 200 GT from some specific requirements in certain circumstances, subject to the need to protect seafarers’ health and safety. The Trainer could point out that where this flexibility has been exercised by the competent authority it should be indicated in the national DMLC, Part I. The Trainer could also refer to the discussion in the flag State inspection guidelines, see: Chapter 2 paras 35 to 44.

Design and construction General requirements Headroom (203cm) Insulation (heat, cold, noise) (includes bridge and ECR) Position of sleeping rooms (load line/collision bkd) Lighting & drainage Health, safety, accident prevention (Cf. Reg. 4.3) A3.1.6, R4.3 FS Guidelines Sec. 3.2 Ch.3 The Trainer should then deal with the “general requirements for accommodation”, referred to in paragraph 6 of Standard A3.1, which are relevant to design and construction. Attention should be drawn to section 3.2 in Chapter 3 of the flag State inspection guidelines concerning Regulation 3.1. In particular, inspectors should be reminded of the plan approval process undertaken during the construction of the ship as well as the need, as part of the first inspection of a ship and after any substantial alteration, to verify that the accommodation and recreational facilities have been constructed in accordance with the approved drawings. The Trainer should point out that Standard A3.1, paragraph 6, covers the following points to be checked, in particular: 1 Minimum headroom of 203 cms for full and free movement, with a possibility for the competent authority to allow a limited reduction, where reasonable (because of the ship’s operation) and not resulting in discomfort. 2 Adequate insulation to protect the seafarer from heat, cold, condensation or noise inside the accommodation, by which is meant living quarters and some working areas such as inside the bridge or in the engine control room. 3 With the exception of passenger ships, sleeping rooms must be above the load line. Also no sleeping room is allowed forward of the collision bulkhead. In passenger ships the sleeping rooms can be below the load line as long as satisfactory provision is made for lighting and ventilation. It should be pointed out that sleeping rooms under working alleyways are no longer permitted. Working areas must be segregated from sleeping areas. Bulkheads between the two must be steel or similar (this is covered under SOLAS requirements as far as construction of bulkheads is concerned). The Trainer should explain the reason why: namely, to ensure that there is no possibility of gas or other noxious fumes etc getting into sleeping areas. 4 The need for proper lighting (to be covered in greater detail later) and sufficient drainage. 5 The applicability of health and safety requirements etc to accommodation and recreational and catering facilities particularly with respect to the risk of exposure to hazardous levels of noise and vibration and other ambient factors and chemicals must also be considered (dealt with in the module relating to Regulation 4.3). The Trainer could ask inspectors to review the relevant national provisions on these matters.

Design and construction Detailed guidance Bulkheads (insulation, keep clean, vermin) Protection from heating systems (mach. Casing, galleys, steam pipes) Accommodation spaces should be insulated (Condensation, overheating) Non-slip decks Avoid dirt traps (Flooring material, joints) The Trainer should explain that the present slide covers recommendations in the Convention on details that follow from the basic requirements set out in the previous slide and that most of them are just common sense. However, since these details are set out in the Guidelines in Part B of the Code (Guideline 3.1.1), there is a greater possibility that the national provisions covering the matters on the present slide will be different. Where this is the case, the Trainer should refer to the requirements under those national provisions. With any necessary adaptations to reflect the relevant national requirements, the Trainer should draw attention, in particular, to the need to check: 1 That external bulkheads of sleeping rooms and mess rooms are adequately insulated, that internal bulkhead surfaces and deckheads are of material with a surface easily kept clean, and that no form of construction likely to harbour vermin is being used. Bulkhead surfaces and deckheads in sleeping rooms and mess rooms should be capable of being easily kept clean and light in colour with a durable, non-toxic finish. 2 That all machinery casings and all boundary bulkheads of galleys and other spaces in which heat is produced are adequately insulated where there is a possibility of resulting heat effects in adjoining accommodation or passageways. Measures should also be taken to provide protection from heat effects of steam or hot-water service pipes or both. 3 That sleeping rooms, mess rooms, recreation rooms and alleyways in the accommodation space are adequately insulated to prevent condensation or overheating. 4 That the decks in all seafarer accommodation are of approved material and construction and provide a non-slip surface impervious to damp and easily kept clean. 5 That, where the floorings are made of composite materials, the joints with the sides are profiled to avoid crevices.

Ventilation Basic requirements Sleeping rooms and mess rooms to be adequately ventilated Air conditioning except in temperate zones Open air ventilation for sanitary spaces A3.1.7 (a) to (c) The Trainer should refer to the basic requirements in the national provisions implementing Standard A3.1, para. 7(a) to (c), noting the possibility that the national provisions may in certain circumstances exempt ships under 200 GT from the air conditioning requirement (Standard A3.1, paras 20(a) and 21).

Ventilation Detailed guidance Should supply fresh air in all conditions (mechanical or not) Shouldn’t be too noisy Must be able to clean the system (e.g.legionella) Must be constantly powered, but need not be on the emergency system B3.1.2 The details in this slide are taken from the recommendations in Guideline B3.1.2. With any necessary adaptations to reflect any national requirements that differ from the measures in Guideline B3.1.2, the Trainer should draw attention, in particular, to the need to check: 1 That the system of ventilation for sleeping rooms and mess rooms is controlled so as to maintain the air in a satisfactory condition and to ensure a sufficiency of air movement in all conditions of weather and climate. This does not have to be a powered system but, if not, it must be shown that it works. 2 That the air-conditioning systems used, whether of a centralized or individual unit type, are designed: - to maintain the air at a satisfactory temperature and relative humidity as compared to outside air conditions, - to ensure a sufficiency of air changes in all air-conditioned spaces, - to take account of the particular characteristics of operations at sea, and - not to produce excessive noises or vibrations. 3 That the air-conditioning systems facilitate easy cleaning and disinfection to prevent or control the spread of disease. The Trainer should point out that this is of particular importance because of such diseases as Legionella which can be easily spread through an air-conditioning plant. 4 That power for the operation of the air conditioning and other aids to ventilation is available at all times when seafarers are living or working on board and conditions so require. However, this power need not be provided from an emergency source.

Heating Basic requirement Adequate heating except in tropical climates A3.1.7.d The Trainer should refer to the basic requirement in the national provisions implementing Standard A3.1, para. 7(d).

Heating Detailed guidance In operation at all times Using an appropriate means (no steam in accommodation) Maintaining satisfactory temperature Avoiding risks or discomfort B3.1.3 The details in this slide are taken from the recommendations in Guideline B3.1.3. With any necessary adaptations to reflect any national requirements that differ from the measures in Guideline B3.1.3, the Trainer should draw attention, in particular, to the need to check: 1 That the system of heating the seafarer accommodation should be in operation at all times when seafarers are living or working on board and conditions require its use. Equally it should not operate when it is not needed. 2 However, that within the accommodation area, steam is not being used as a medium for heat transmission. This is because of the danger of leaks. Also steam heating tends to create piping and radiators which get excessively hot and therefore constitute a hazard. 3 That the heating system is capable of maintaining the temperature in seafarer accommodation at a satisfactory level under normal conditions of weather and climate likely to be met within the trade in which the ship is engaged. The Trainer should refer to the standard prescribed by the competent authority in this connection, if known, or advise the inspectors to obtain the necessary guidance from the competent authority. 4 That radiators and other heating apparatus are placed and, where necessary, shielded so as to avoid risk of fire or danger or discomfort to the occupants. The Trainer should explain that, in fact, it is fairly unusual these days to get radiators but, if used, they should placed or shielded to avoid someone falling against them. Usually heating is done through the ducting.

Lighting Basic requirement Natural light and adequate artificial light for sleeping rooms and mess rooms (special arrangements may have been permitted for passenger ships) A3.1.8 The Trainer should refer to the basic requirement in the national provisions implementing Standard A3.1, para. 8.

Lighting Detailed guidance Electric lighting (requested) Berth lights Natural light (Nat. standards) A3.1.9, B3.1.4 The details in this slide are taken from the recommendations in Guideline B3.1.4. With any necessary adaptations to reflect any national requirements that differ from the measures in Guideline B3.1.4, the Trainer should draw attention, in particular, to the need to check: 1 That electric light is provided in the seafarer accommodation. On most modern ships this is not normally a problem. However on older ships it can be, as old incandescent lights do not supply the same level of lighting. If there are not two independent sources of electricity for lighting, additional lighting should be provided by properly constructed lamps or lighting apparatus for emergency use. The Trainer could note that this is normally covered by the SOLAS regulations. 2 That, in sleeping rooms, an electric reading lamp is installed at the head of each berth. This is a berth light. It should be such that the occupant of the berth is not likely to burn themselves on it but should be adequate for them to be able to read. 3 That the national standards set by the competent authority for natural and artificial lighting are observed (these standards may provide for special arrangements for lighting (see Standard A3.1, para. 8).

Sleeping rooms Basic requirements Principle of one room per seafarer Separate rooms for men and women Separate berth in all circumstances Minimum inside dimensions of berths Minimum floor areas Additional space for certain officers Minimum furnishing to be provided A3.1.9 The Trainer should note that the requirements concerning sleeping rooms apply only on ships where sleeping accommodation is required. The Trainer should refer to the basic requirements in the national provisions implementing Standard A3.1, para. 9, including any exemptions for ships less than 3000 GT or passenger ships or special purpose ships that may have been granted by the competent authority in accordance with that Standard. The Trainer could note the general requirement in para. 9(c ) that sleeping rooms are to be of adequate size and properly equipped so as to ensure reasonable comfort and facilitate tidiness. The following points to be checked should, in particular, be covered: 1 On most ships occupancy is one person per sleeping room; but on passenger ships this can be increased up to four and on ships under 3000 GT to two. On special purpose ships there can be more than four per sleeping room. The Trainer could note that usually this is accommodation which is not permanently occupied. In all cases these increased numbers sleeping in the room are subject to the room size requirements set out in the Convention. The competent authority can allow a reduction in the floor area on ships under 3000 GT, special purpose ships and on passenger ships in order to enable single occupancy. 2 Separate sleeping accommodation for men and women. 3 There must be a separate berth for each seafarer with the minimum inside dimension of the berth of 198 x 80 cms. 4 A table showing minimum floor areas is provided in another slide. The Trainer should provide information on the applicable national provisions, if known, or advise the inspectors to obtain the necessary guidance from the competent authority. Sleeping rooms for seafarers performing the duties of officers are subject to a minimum floor area requirement depending on whether the position is that of a senior or junior officer and whether the rooms have a private sitting room or day room. In addition, ships under 200 GT may have been exempted, in certain circumstances, from the requirements relating to floor area (Standard A3.1, paras 20(b) and 21). The Trainer could note that floor size is normally a concern for plan approval or first inspection or inspection after alterations. 5 Masters, Chief Engineers and Chief Officers must have, in addition to their sleeping rooms, an adjoining sitting room, day rooms or equivalent additional space on ships of 3000 GT or above (on smaller ships, exemptions may have been made by the competent authority). 6 For each occupant, the sleeping room furnishings should include a lockable clothes locker of 475 litres with a shelf plus a separate drawer or other space of 56 litres (or if the two are combined the locker must be at least 500 litres) and a table or desk with comfortable seating as necessary. In addition, where no bathroom is attached, each sleeping room must have a washbasin with hot and cold running fresh water, with a possible exception that can be made by the competent authority for passenger ships normally engaged in voyages of less than four hours (Standard A3.1, para 11(d), (e). Ships under 200 GT may also have been exempted in certain circumstances from this requirement (Standard A3.1, paras 20(a) and 21).

Table of floor areas for sleeping rooms Criteria (in GT) Single berth sleeping rooms Double berth sleeping rooms in cargo ships Ratings sleeping rooms in passenger ships Officers sleeping rooms in passenger ships (no day room) Officers sleeping rooms in cargo ships (no day room) Special purpose ships <3000 tons 4.5 m2 7 m2 7.5 m2 /person 3000 tons – tons 5.5 m2 8.5 m2 /person tons 10 m2 /person 2 ratings 7.5 m2 3 ratings 11.5 m2 4 ratings 14.5 m2 >4 persons 3.6 m2 /person Junior Officers (no day room) Senior Officers (no day room)

Sleeping rooms Detailed guidance Toilet facilities, where reasonable/practicable Partners to be taken into account Watch keepers separate from others (as far as practicable) Petty Officers, maximum 2 per room Second Engineers, additional space if possible Requirements for berths Other fittings (mirror, basin, curtains, coat hooks…) Measuring floor space (furnishing included / bathroom excluded) B3.1.5 The details in this slide are taken from the recommendations in Guideline B3.1.5. With any necessary adaptations to reflect any national requirements that differ from the measures in Guideline B3.1.5, the Trainer should draw attention, in particular, to the following additional points: 1 If it is practicable every sleeping room should have private toilet facilities consisting of a shower and toilet separate from the sleeping area. 2 The berth arrangements should take account of any accompanying partner. 3 Having watch keepers sharing the same sleeping room should be avoided. 4 Petty officers should be limited to two per sleeping room, where shared sleeping rooms are permitted. 5 If possible 2nd Engineers should be given the same type of accommodation as Chief Officers. 6 Berths, maximum two tiered but only one tiered when there is a porthole or outside light above the berth, i.e., when the berth is situated on the ship’s side. Specifically construction of the berth and the berth mattress should be checked to ensure that it is comfortable and the mattress and cushioning made of an approved material that is not likely to harbour vermin. There are various other requirements for berths in Guideline B3.1.5, which should be reflected in the national provisions. 7 There are various other fittings required such as a mirror, basin, bathroom cabinet, curtains, coat hooks etc. The approach that the Trainer could suggest to the inspectors is to think about what they would normally have in a bedroom and bathroom. 8 When measuring floor space, areas occupied by berths, lockers and other furnishings should be included but small or irregular spaces that cannot be used for furnishings should be excluded.

Mess rooms Basic requirements Location: apart from sleeping rooms; close to galleys Adequate size & comfort; properly furnished and equipped A3.1.10 The Trainer should refer to the basic requirements in the national provisions implementing Standard A3.1, para. 10. 1 The Trainer should point out that ships below 3000 GT can be exempted from the first requirement by the competent authority (after consulting the shipowners’ and seafarers’ organizations concerned) and should provide information on such exemptions, if known, or advise the inspectors to obtain the necessary guidance from the competent authority.

Mess rooms Detailed guidance Common or separate? Size: 1.5m2 per person Sufficient equipment and facilities B3.1.6 The details in this slide are taken from the recommendations in Guideline B3.1.6. With any necessary adaptations to reflect any national requirements that differ from the measures in Guideline B3.1.6, the Trainer should draw attention, in particular, to the need to check: 1 That the decision on whether to have a common or separate mess rooms for officers and ratings (usual on the larger ships) has been taken after consultation with seafarers’ and shipowners’ representatives and has been approved by the competent authority. The Trainer should point out the factors that would be relevant to approval by the competent authority, as mentioned in the Guidelines, such as ship size and cultural, religious and social needs of the seafarers concerned. The Trainer could note that if inspectors are authorized to provide approvals on behalf of the competent authority they should tread very carefully to avoid conflict based on their own ideas. 2 That the floor area is not less than 1.5 m2 per person using the mess room concerned. 3 That there are enough tables and chairs to accommodate the greatest number of seafarers likely to use them at the same time. Tops of tables and chairs should be made of damp-resistant material. 4. At all times a refrigerator that is large enough for the number of seafarers using the mess room should be available. Seafarers should also have access at all time to facilities for heating water for drinks etc and cool water facilities. If there is no separate pantry, lockers and washing up facilities for mess utensils should be provided.

Sanitary facilities Basic requirements Access, hygiene, comfort; separate for men & women Laundry facilities A3.1.11(a) & 13 This slide covers basic requirements in Standard A3.1, para. 11(a) and para.13. The Trainer should refer to the basic requirement that all seafarers must have convenient access to sanitary facilities meeting minimum standards of health and hygiene and reasonable standards of comfort, with separate sanitary facilities being provided for men and for women. There must also be laundry facilities (even if a laundry service is provided) although ships under 200 GT may be exempted in certain circumstances from this requirement (Standard A3.1, paras 20(a) and 21).

Sanitary facilities Basic requirements and detailed guidance Facilities of adequate quality Convenient location Number: minimum 1 per 6 persons Laundry facilities to be provided A (b) to (f) - B3.1.7 The details in this slide are taken from Standard A3.1, para. 11(b) to (f), and Guideline B3.1.7. With any necessary adaptations to reflect any differing national requirements, the Trainer should draw attention, in particular, to the need to check: 1 That washbasins and tub baths are of adequate size and approved material; that toilets are of an approved pattern, have a suitable flushing system and are adequately screened from any other toilet in the same space; and that the floor is capable of being washed down with a drain and is watertight from other areas. The Trainer should again draw attention to the importance of checking whether the competent authority has permitted any variations under Standard A3.1, para. 19 to take into account of differing religious and social practices that might be relevant to sanitary facilities, for example, practices relating to the design of washing/shower facilities. 2 That sanitary facilities are available not only within the main accommodation but also within easy access of the navigating bridge and the machinery space or near the engine room control centre (i.e., for watchkeepers). Ships under 3000 GT may be exempted by the competent authority (after consulting the shipowners’ and seafarers’ organizations concerned). 3 That there must be at least one convenient location, with a toilet, washbasin (with hot and cold running water) and tub or shower, for every six persons or less, discounting seafarers who have personal sanitary facilities. The Trainer could also remind inspectors that they need to check whether sufficient facilities are available to provide separate sanitary facilities for men and women. 4 That laundry facilities are appropriately located. They should include washing machines, drying machines or adequately heated drying rooms, as well as irons and ironing boards or their equivalent. Question: A ship has 18 seafarers on board. Two of them are women. How many sanitary facilities are required (assuming there are no private bathrooms)? Answer: at least four – three for the 16 male seafarers, and one for the two female seafarers (at a location that is convenient for each of them).

Hospital accommodation Basic requirements Separate accommodation for ships with 15+ seafarers on voyages lasting 3+ days (rule can be relaxed by competent authority for ships in coastal trade) To be used only for medical purposes Easy to access, comfortable housing, conducive to prompt & proper attention A3.1.12 The Trainer should refer to the basic requirements in the national provisions implementing Standard A3.1, para. 12 and the DMLC, Part I.

Hospital accommodation Detailed guidance Functional design Number of berths prescribed by authority Exclusive sanitary accommodation B3.1.8 The details in this slide are taken from the recommendations in Guideline B3.1.8. With any necessary adaptations to reflect any national requirements that differ from the measures in Guideline B3.1.8, the Trainer should draw attention, in particular, to the following additional points: 1 The design of the accommodation should facilitate consultation and first aid and help prevent the spread of disease. The various arrangements should be designed to ensure comfort and facilitate treatment. 2 The inspectors should check that there are the number of hospital berths that are required by the competent authority. 3 Sanitary accommodation (at least one toilet, one washbasin and one tub/shower) should be provided for the exclusive use of the occupants. The facilities should be either in, or close to, the hospital accommodation.

Other facilities to be provided Basic requirements and detailed guidance Open air on deck Offices Protection from mosquitoes Other amenities A & 15, B3.1.9 The details in this slide are taken from Standard A3.1, paras 14 to 16 and the recommendations in Guideline B3.1.9. With any necessary adaptations to reflect any differing national requirements, the Trainer should draw attention, in particular, to the following points: 1 There must be open deck space that can be used by seafarers off duty that is big enough to cater for those on board. This does not include deck spaces where there is danger from injury due to ship working operations. 2 Separate office space must be provided for the use of the deck and engine departments. It can be a common office or they be separate offices Ships below 3000 GT can be exempted from this requirement by the competent authority (after consulting the shipowners’ and seafarers’ organizations concerned). 3 If the ship regularly trades to tropical areas there must be devices to stop mosquitoes. The inspector should find out from the competent authority what devices are required. For example, usually an air-conditioned accommodation block is adequate. If there is no air-conditioning, then screens or some other approved system should be available. 4 While not required it is usual for there to be separate changing facilities available for the engine department personnel and also possibly for the deck and catering personnel. In this case they should be located outside the engine room or other work space but with easy access and should be fitted with individual clothes lockers and washing facilities The Trainer should note the relevant national provisions on these matters.

Bedding, mess utensils etc. Detailed guidance B3.1.10 The Trainer should note that the Convention also contains guidance in Guideline B on other items that should be checked (in accordance with national requirements). Although not the subject of a specific standard these could be considered as guidance relating to decent accommodation and could be checked when inspecting sleeping rooms, mess rooms and sanitary facilities. With any necessary adaptations to reflect any differing national requirements, the Trainer should draw attention to the need to check that the seafarers are given clean bedding and mess utensils for use on board ship and that the bedding is of good quality and that the eating utensils are of approved material that can be easily cleaned. Sufficient sanitary and hygiene items such as soap, towels and toilet paper should also be provided.

Recreational facilities, mail and ship visit arrangements Basic requirements Appropriate facilities, amenities and services, as adapted to meet the special needs of all seafarers who must live and work on ships Detailed guidance Examples of appropriate facilities Minimum that must be provided Facilitation of mail & communication (reasonable price) Seafarers’ partners & other visitors on board ship A3.1.17, B3.1.11 1 The Trainer should draw attention to the terms of the basic obligation to be met by shipowners that is set out in paragraph 17 of Standard A3.1, and note that a large number of recommendations as to what would constitute appropriate facilities, amenities and services are given in Guideline B3.1.11, especially in paragraph 4. The Trainer should note that facilities are to be for the benefit of all seafarers. The Trainer should underline the importance of the relevant national provisions of the inspectors’ country and the related decisions of its competent authority as to the precise facilities, amenities and services that should be provided since Guideline B does not make any definite recommendation in this connection (using wording such as “Consideration should be given to”). Inspectors should consequently seek guidance from the competent authority in this respect. 2 It nevertheless seems possible to state that the minimum required are facilities for reading, writing and playing games. The Trainer might note the importance of reviewing Regulation 4.3 and the Code provisions on safety and health and accident prevention and the general requirements in Standard A3.1, para. 6(h) regarding preventing the risk of exposure to hazardous levels of noise, vibration and other ambient factors. This could relate, for example, to the location of recreational facilities. 3 There should also be arrangements in place for forwarding seafarers’ mail. 4 Moreover, where possible and dependent on national legislation or international law or regulations, measures should be considered to ensure that seafarers are expeditiously given permission to have visitors (such as partners, relatives, friends etc) on board when the ship is in port and have their partners accompany them on occasional voyages. This is obviously dependent on the need to address security clearances in ports and whether there is adequate space on board. The Trainer might refer to Guideline B3.1.5, para. 1 which recommends berth arrangements that are “as comfortable as possible for the seafarer and any partner who may accompany the seafarer”. The Trainer might need to also explain that the word partner is used to refer to a person who is the spouse of the seafarer, although they may not be married, and that a spouse may also be of the same gender as the seafarer. Guideline B should be studied and any national provisions considered. The sample DMLC Part II would also be helpful to review from this point of view. Question: A seafarer wants to have his or her spouse accompany him/her on a voyage. The ship’s master asks for advice as to whether she or he is required to give permission. Answer (depending on whether national provisions state otherwise): Guideline B3.1.11, para, 6, which explains expectations regarding the implementation of Standard A3.1, para 17, suggests that permission should be granted whenever it is “practicable and reasonable”. It can, however, be expected that the spouse should obtain insurance coverage against accidents and illness.

Prevention of noise and vibration Basic requirements and detailed guidance A3.1.4, B3.1.12 The Trainer should remind the inspectors that “noise, vibration and other ambient factors” is one of the areas highlighted in paragraph 4 of Standard A3.1 for particular attention, noting that this is very often a problem on modern ships: due to present ship design the accommodation is often located right above the engine room and as far aft as possible, which makes vibration and noise an inherent problem. Its importance is highlighted again in paragraph 6(h) in connection with preventing the risk of exposure in connection with accommodation, recreational and catering facilities and also, as mentioned in the previous slide, implicated in the reference in paragraph 17 to the need to take into account Regulation 4.3 and the Code in connection with recreational facilities, amenities and services. The Trainer should go through Guideline B with the inspectors, paragraph by paragraph. With respect to paragraph 4, the Trainer should provide the inspectors with a copy of the national standards setting limits for noise levels for working and living spaces, if available, or advise them to seek the necessary material or guidance from the competent authority. The Trainer should note that a copy of international limits for noise levels should be in English or the working language of the ship should be carried on board and accessible to seafarers.

Checking for compliance Frequent inspections Summary of points to be checked A3.1.18 FS Guidelines Sec. 3.2 Ch. 3 1 The Trainer should underline the importance of the requirement (in Standard A3.1, para. 18) for frequent inspections to be carried out on board ship by or under the authority of the Master. The results of each inspection are to be recorded and to be available for review. The Trainer should point out that, on ships subject to certification, the DMLC Part II, setting out the measures that the shipowner has adopted for ensuring ongoing compliance, should be checked particularly with respect to the schedule and responsibilities for carrying out these frequent inspections. In addition, the results of those inspections, including significant deficiencies found, should be recorded in, or in connection with, the DMLC (Standard A5.1.3, para. 11). If inspectors are confident that the measures in the DMLC Part II are being properly implemented, including the recording of their results, this should assist their own inspection. 2 The Trainer should once again draw attention to the guidance provided in the flag State inspection guidelines, Chapter 3, section 3.2 under Regulation 3.1 “How to check the basic requirements” and “Examples of deficiencies”, clarifying that this guidance obviously does not exhaustively cover all the points that would need to be checked, but concentrates on those that definitely should not be missed. The Trainer might also note the sample of an Aide Memoire that could be developed by inspectors, using their national provisions, to assist with the inspection.

Regulation 3.2 – Standard A3.2 Guideline B3.2
FOOD AND CATERING Regulation 3.2 – Standard A3.2 Guideline B3.2 Purpose: To ensure that seafarers have access to good quality food and drinking water provided under regulated hygienic conditions The inspectors should have in front of them Chapter 3, section 3.2 of the flag State inspection guidelines under Regulation 3.2 “How to check the basic requirements”. The national DMLC Part I and an sample DMLC Part II should also be available. The Trainer should point out that, Regulation 3.2 covers issues that will involve a number of methods to verify operating conditions on the ship. Interviews with seafarers in private will be important, as well as visual observation of food and water supplies to make sure that seafarers are not charged for their food, that the food and drinking water supplies which are provided are of appropriate quality and quantity and nutritional value and that seafarers are being given a sufficient choice, bearing in mind any religious or cultural prohibitions concerning particular kinds of food. The Trainer could note that inspectors will need to develop sufficient expertise in national provisions regarding food safety and preparation. The inspector will need to verify that the seafarers responsible for cooking, handling and storing food have been properly trained and also to know what to look for when checking that those seafarers are doing their job properly. In this connection, the Trainer should provide inspectors with information on the relevant national provisions that set the minimum standards for quantity and quality of food and drinking water and that apply to catering at sea, especially those relating to the preparation and handling of food in hygienic conditions.

FOOD AND CATERING Basic requirements Food & drinking water supplies: suitable quantity, nutritional value, quality & variety having regard to the number of seafarers, their religions or cultures, & duration & nature of voyage Properly organized and equipped catering department; hygienic preparation and serving Adequate, varied and nutritious meals provided free of charge during the seafarers’ engagement Properly trained or instructed catering staff Frequent documented inspections The Trainer should discuss each of these basic requirements, which are set out in Regulation 3.1 and in general terms under (a), (b) and (c) of Standard A3.2, para. 2, with more specific requirements set out in the rest of the Standard. 1 The Trainer could point out that the first requirement has two aspects: (a) an adequate planning of supplies, ensuring that the supplies planned are of suitable quantity for the voyage concerned, of suitable quality and variety (taking account of possible religious and cultural factors) and of suitable nutritional value, and (b) the actual presence of those planned supplies on board when needed. Question: What sources of information might be needed or useful for checking whether supplies have been adequately planned? Possible answers: visual observation of the food and water supplies; the shipowners’ plans in the DMLC Part II, and the related catering plans; the plans for menus; the crew list (to verify the number of seafarers to be fed and also possibly to give an idea of possible religious or cultural factors); and talking to the seafarers, the Master and the ship’s cook. Question: How can the inspector know whether the supplies planned are of suitable quantity, nutritional value and variety? Possible answer: From the information on national minimum requirements provided by the competent authority and visual observation. The Trainer could refer to the advice given in the flag State inspection guidelines concerning interviews, in private, with a representative number of seafarers as well as to guidance obtained from the competent authority concerning the needs of seafarers in terms of quantity, quality and nutrition. The Trainer should refer in this connection to Guideline B3.2.1, which underlines the responsibility of the competent authority to collect up-to-date information on nutrition and on methods of purchasing, storing, preserving, cooking and serving food, with special reference to the requirements of catering on board a ship, and also to develop educational materials and onboard information concerning methods of ensuring proper food supply and catering services.

FOOD AND CATERING Basic requirements Properly organized and equipped catering department; hygienic preparation and serving B 2 The Trainer should again draw attention to the need for information from the competent authority, which (according to Guideline B3.2.1, para. 2, “should issue recommendations to avoid wastage of food, facilitate the maintenance of a proper standard of hygiene, and ensure the maximum practicable convenience in working arrangements”. The Trainer should explain that the next slide lists only some indicators of potentially unhygienic practices. The idea here is not to provide a course on food preparation at sea – although Trainers should consider arranging, in appropriate cases, for inspectors to have such a course – but rather to provide examples of clear situations which, if found, would indicate that the qualifications of the seafarers’ concerned cannot be relied on. The Trainer should point out that, if even a single one of those indicators is found, the inspectors should, if they have the necessary knowledge and experience, carry out a meticulous examination of the catering facilities and practices on the ship, or otherwise call in a food catering expert to perform such an examination.

Indicators of potentially unhygienic practices
FOOD AND CATERING Indicators of potentially unhygienic practices Frozen meat not adequately separated from other frozen foods Food maintained at above the standard temperature for frozen or chilled food Raw food touching or dripping onto cooked food Ready-to-eat food kept uncovered or for too long Ready-to-eat food used beyond the “Use by” date Food stored close to cleaning products No cleaning products available Presence of pests Galley staff without clean, required clothing Inadequate facilities for frequent hand washing Inadequate spaces for hot & cold running water for washing food Food handled by staff smoking, eating, drinking or unwell Dirty or untidy galleys or equipment Dirty extractor fans or filters Chopping boards scratched, pitted or scored, or used for both e.g. raw meat and cooked food The Trainer should point out that these are simply important examples and that inspectors should refer to the information provided by the competent authority for what should be expected.

FOOD AND CATERING Basic requirements Adequate, varied and nutritious meals provided free of charge during the seafarers’ engagement 3 The Trainer could refer to the advice given in the flag State inspection guidelines concerning interviews, in private, with a representative number of seafarers as well as to guidance obtained from the competent authority concerning the needs of seafarers in terms of quantity, quality and nutrition.

Basic requirements Properly trained or instructed catering staff
FOOD AND CATERING Basic requirements Properly trained or instructed catering staff ships’ cooks: 18+ dispensations by competent authority (next port of call or maximum 1 month) B A3.2.5, 6 & 18 4 The Trainer should underline the need for the inspectors to know what qualifications have been established by the national provisions and the competent authority for the various kinds of catering staff and to have a list of institutions or Recognized Organizations (in the inspectors’ country or elsewhere – see Guideline B3.2.2, para. 3)) which are authorized to issue the certification or other qualification established by the competent authority. The Trainer should point to the particular care needed when checking whether the catering staff, and especially the ship’s cook or other person processing food in accordance with paragraph 5 or 6 of Standard A3.2, possess the qualifications required of them. This verification must of course include age: no seafarer under 18 must work as a ship’s cook (Standard A3.2, para. 18). The Trainer should note that under paragraph 5 even when the competent authority has not required the ship to carry a fully qualified cook any seafarers who are involved with processing food in the galley must still have been trained or instructed on issues such as food and personal hygiene and handing and storage of food on ships. The Trainer should note that the Convention allows the competent authority to provide a dispensation in “circumstances of exceptional necessity” to the requirement for a fully qualified cook. If such a dispensation has been granted to a seafarer it can only be given for a limited period of time; either the next port of call for the ship or for a maximum period of one month. The seafarer concerned must still have been instructed in food and personal hygiene as well as handling and storage of food on board ship.

Basic requirements Frequent documented inspections of:
FOOD AND CATERING Basic requirements Frequent documented inspections of: food & drinking water supplies all storage and handling spaces & equipment galley & other equipment for preparing and serving food A3.2.7 5 The Trainer should underline the importance of the requirement (in Standard A3.2, para. 7) for frequent documented inspections of all the areas set out in the slide that must be carried out on board ship, by or under the authority of the Master. The inspector should expect to see records of these inspections including any problems identified and corrective actions taken. The Trainer should point to any national provisions that establish a minimum frequency for these inspections.

Checking for compliance
FOOD AND CATERING Checking for compliance Summary of points to be checked A3.2.7, A FS Guidelines Ch.3, Sec. 3.2 1 The Trainer should, again, underline the importance of the requirement (in Standard A3.2, para. 7) discussed in the previous slide, for frequent documented inspections to be carried out on board ship, by or under the authority of the Master, in accordance with the ongoing compliance procedures under Title 5. The Trainer should point out that, on ships subject to certification, the DMLC Part II, setting out the measures that the shipowner has adopted for ensuring ongoing compliance, should be checked particularly with respect to precisely what is to be inspected and how often. In addition, the results of those inspections, including significant deficiencies found, should be recorded in, or in connection with, the DMLC (Standard A5.1.3, para. 11). If inspectors are confident that the measures in the DMLC Part II are being properly implemented and documented, this should assist their own inspections. 2 The Trainer should once again draw attention to the guidance provided in the flag State inspection guidelines, Chapter 3, section 3.2 under Regulation 3.2 “How to check the basic requirements” and “Examples of deficiencies”, clarifying that this guidance concentrates on the points that should not be missed, and that the effectiveness of an inspection will greatly depend also upon other factors, particularly the inspectors’ knowledge and experience with food catering inspection and their professional judgment. The Trainer might also note that, as mentioned at the beginning of the presentation on this Regulation, inspection of this requirement will require a variety of methods such as reviewing documentation, visual observation of the catering facilities and food storage areas and the food and water supplies, and importantly interviews, in private, with the seafarers including catering staff. The Trainer should also remind inspectors that Regulation 3.1 and the Code also refer to some food storage and food and beverage preparation matters (such as requirements for refrigerators and access to facilities for beverages). Although dealt with in a separate Regulation in the Convention, these facilities must also be checked to ensure they meet hygiene and other standards, to the extent relevant, that have been discussed in this module. The Trainer might also note the sample of an Aide Memoire that could be developed by inspectors, using their national provisions, to assist with the inspection.

Summary Any questions? Main points covered in the presentation:
3.1 Accommodation and recreational facilities For ships constructed prior to entry into force of the Convention, non-application of the Code provisions relating to construction and equipment. Depending on the situation in the inspectors’ country: the continued application of the requirements for construction and equipment in ILO Convention No. 92 and/or No. 133. In all cases, accommodation and recreational facilities on ships must be “consistent with promoting the seafarers’ health and well-being” as required by Regulation 3.1. Identification of the key areas for special attention: size of rooms and other spaces; heating and ventilation; noise and vibration; sanitary facilities; lighting; hospital accommodation. Summary of the requirements for each of the accommodations or recreation facilities, including those concerning the key areas. The need for inspectors to take account of any exemptions or variations that may be allowed by the national provisions or by the competent authority to take account of differing and distinctive religious and social practices or specific kinds or sizes of ships (special purposes ships, passenger ships, ships under 3000 GT and less than 200 GT). 3.2 Food and catering Food & drinking water supplies: to be of suitable quantity, nutritional value, quality & variety. The need to be alert to the presence of cultural and religious considerations that need to be taken into account. The requirement for a properly organized and equipped catering department with the hygienic preparation and serving of adequate, varied and nutritious meals. Meals to be provided free of charge during the seafarers’ engagement. The need to ensure that ships’ cooks and other catering staff are properly trained, that they have the required qualifications, and that they are carrying out their job properly, with an emphasis on hygiene. The need for inspectors to be familiar with national provisions relating to hygienic food preparation and storage and requirements for food and water supplies. In the case of both Regulations 3.1 and 3.2: The need for frequent onboard inspections to be carried out and documented, by or under the authority of the Master. The link between this requirement and the role of the DMLC Part II.

MARITIME LABOUR INSPECTION MLC, 2006

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MARITIME LABOUR INSPECTION MLC, 2006

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