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MLC, 2006 certification process

Difficulties encountered

MSSM, Nyborg, 27th August 2013

Bengt Sangberg
Introduction & Objectives
MARITIME LABOUR
CONVENTION
2006

PRESENTATION TOPICS
 Overview of Maritime Labour Convention, 2006

 Convention ratification process development

 MLC, 2006 certification progress

 General experience on MLC, 2006 certification process

 Deficiencies identified during MLC, 2006 certification process

 MLC – Experienced deficiencies during inspections

 Bureau Veritas MLC related services


MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 2
Overview of Maritime Labour Convention 2006
Overview of Maritime Labour Convention 2006

The reasons for change

► Increased internationalization of ship registries

► Need to provide a level playing field and avoid


exploitation of seafarers

► Law ratification rate for some existing key ILO


Conventions

► Problems for inspection and enforcement (first time inspection


and certification system established for ILO convention)

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 4


Overview of Maritime Labour Convention 2006

Who or what does the MLC,


2006 apply to?
► Seafarers

 every persons working in any capacity on a ship


to which the Convention applies

Broad definition including the range of people


employed at sea who carry out jobs not
traditionally understood to be part of the
seafaring workforce

(Some national flexibility is allowed)

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 5


Overview of Maritime Labour Convention 2006

Who or what does the MLC, 2006 apply to?

► Shipowner

The MLC, 2006 defines a shipowner as the owner of the ship or another
organization or person, such as the manager, agent or bareboat charterer,
who has assumed the responsibility for the operation of the ship from the
owner and who, on assuming such responsibility, has agreed to take over the
duties and responsibilities imposed on shipowners in accordance with the
Convention.
This definition was adopted to reflect the idea that irrespective of the particular
commercial or other arrangements regarding a ship‘s operations, there must be
a single entity, the shipowner that is responsible for seafarers‘ living and
working conditions

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 6


Overview of Maritime Labour Convention 2006

Which ships does the MLC, 2006 apply?


Which ships does the MLC, 2006 apply to?

► The MLC, 2006 applies to all ships engaged in commercial


activities (except fishing vessels, ships of traditional build and
warships or naval auxiliaries).

► Ships of 500 GT or over are required to be certified

 they must carry a Maritime Labour Certificate as well as a


Declaration of Maritime Labour Compliance.

► Ships below 500 GT are subject to inspection at intervals not


exceeding three years.

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 7


Overview of Maritime Labour Convention 2006

The Regulations of MLC 2006 are organized in five Titles

► Title 1 – Minimum requirement for seafarers to work on a ships

► Title 2 – Condition of employment

► Title 3 – Accommodation, recreational facilities, food and catering

► Title 4 – Health protection, medical care, welfare and social


protection

► Title 5 – Compliance and enforcement

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 8


Overview of Maritime Labour Convention 2006

Inspection and certification process

MLC, 2006 documents

 Maritime Labour Certificate (validity 5 years)


 Interim Maritime Labour Certificate (validity 6
months)
 Declaration of Maritime Labour Compliance
(DMLC) part I and II

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 9


Overview of Maritime Labour Convention 2006

►DMLC Part I (Flag)

 identify the list of matters to be inspected


 identify the national requirements embodying the
relevant provisions of this Convention
 provides a reference to the relevant national legal
provisions
 refer to ship-type specific requirements
 record any substantially equivalent provisions
 clearly indicate any exemption granted by the
competent authority as provided in Title 3

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 10


Overview of Maritime Labour Convention 2006

DMLC part II (Shipowner)

►Part II may take a number of forms.

►It should be drafted in clear terms designed to help all persons


concerned ( flag State inspectors, authorized officers in port States and
seafarers), to check that the requirements are being properly
implemented.
►The DMLC part II is certified by the Administration or its RO before a
certificate can be issued

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 11


Convention Ratification Process Development
Convention Ratification Process Development

The Convention will enter into force12 months after ratification


by 30 countries representing 33% of world tonnage

Entry into force for first group of ratifying states on


20.08.2013

Ratifying countries (41)


(as of August 2013)
Antigua and Barbuda, Australia, Bahamas, Barbados, Benin, Bosnia
and Herzegovina, Bulgaria, Canada, Croatia, Cyprus, Denmark, Fiji*,
Finland, France, Gabon*, Greece, Japan, Kiribati, Latvia, Lebanon*,
Liberia, Luxembourg, Malta, Marshall Islands, Morocco, Netherlands,
Nigeria, Norway, Palau, Panama, Philippines, Poland, Russian
Federation, Saint Kitts and Nevis, Saint Vincent & the Grenadines,
Serbia, Singapore, South Africa, Spain, Sweden, Switzerland, Togo,
Tuvalu, United Kingdom, Viet Nam*

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 13


Convention Ratification Process Development

Bureau Veritas Flag State recognitions for MLC activities


Full scope recognition
Review and approval of DMLC II
Shipboard inspections
Issuance of certificates

Full scope recognition with MLC ratifying countries


Antigua and Barbuda, Australia, Bahamas, Cyprus, Denmark, Latvia, Liberia
(without DMLC II approval), Luxembourg, Malta, Marshall Islands, Morocco,
Netherlands, Norway, NIS, Panama, Philippines, Singapore, Saint Kitts and
Nevis, Saint Vincent and the Grenadines, Singapore, Serbia, Switzerland,
Tuvalu

Full scope recognition with not MLC ratifying countries


Bangladesh, Belize, Germany, Gibraltar (case by case bases), Hong Kong,
Lithuania, Qatar, Vanuatu

Recognition process in progress


Greece, Russian Federation, other ratifying countries

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 14


MLC, 2006 Certification Progress
MLC, 2006 Certification Progress (as per end of July 2013.)

Certification progress of MLC ratifying country ships

MLC CERTIFICATION FOR SHIPS WITH MLC RATIFYING FLAGS MLC CERTIFICATION FOR SHIPS WITH MLC RATIFYING FLAGS
CERTIFICATION DMLC II MLC CERTIFICATION DMLC II MLC
FLAG FLAG
DEADLINE REVIEWED INSPECTIONS DEADLINE REVIEWED INSPECTIONS

ANTIGUA AND BARBUDA 20.08.2013. 140 75 NETHERLANDS 20.08.2013. 374 290

BAHAMAS 20.08.2013. 143 106 NORWAY 20.08.2013. 9

CYPRUS 20.08.2013. 115 76 NIS 20.08.2013. 4 1

DENMARK 20.08.2013. 9 5 PANAMA 20.08.2013. 286 189

GREECE 04.01.2014. 2 PHILIPPINES 20.08.2013. 51 14

St VINCENT AND
THE
KIRIBATI 20.08.2013. 1 GRENADINES 20.08.2013. 49 24

LIBERIA 20.08.2013. 59 SINGAPORE 20.08.2013. 154 92

LUXEMBOURG 20.08.2013. 8 3 SWITZERLAND 20.08.2013. 9 6

MALTA 20.08.2013. 198 99 TUVALU 20.08.2013. 26 5

MARSHALL ISLANDS 20.08.2013. 159 110 TOTAL: 1737 1154

Mandatory certification of ships as per MLC requirements

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 16


MLC, 2006 Certification Progress (as per end of July 2013.)

Certification progress of non MLC ratifying country ships


MLC CERTIFICATION FOR ISM SHIPS WITH MLC NON RATIFYING FLAGS MLC CERTIFICATION FOR ISM SHIPS WITH MLC NON RATIFYING FLAGS

CERTIFICATION DMLC II MLC CERTIFICATION DMLC II MLC


FLAG FLAG
DEADLINE REVIEWED INSPECTIONS DEADLINE REVIEWED INSPECTIONS

ALGERIA NONE 11 2 MALAYSIA NONE 18 1

BRAZIL NONE 1 MONTENEGRO NONE 2

COMOROS NONE 1 PORTUGAL NONE 3

PORTUGAL
(MADEIRA
INT. SHIP.
CURACAO NONE 1 REGISTER) NONE 7

DOMINICA NONE 4 SAMOA NONE 1

FAROE ISLANDS NONE 15 11 SAUDI ARABIA NONE 6

GERMANY NONE 1 SOUTH AFRICA NONE 4

GIBRALTAR NONE 28 18 THAILAND NONE 2

HONG KONG NONE 171 96 TURKEY NONE 24 1

INDONESIA NONE 1 VANUATU NONE 2 1

IRELAND NONE 27 1 URUGUAY NONE 1

ITALY NONE 2 TOTAL: 334 131

KUWAIT NONE 1 CERTIFICATION PROCESS SUMMARY


DMLC II review Inspected ships
MLC ratifying flags 1737 1154

Voluntary certification of ships MLC non ratifying flags 334 131


TOTAL: 2071 1285

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 17


General experience on MLC, 2006 certification process
General experience on MLC, 2006 certification process

Stages of ship certification process for MLC ratifying flags (mandatory certification)
• Issuance of DMLC Part I by the Administration
• GAP analysis (not mandatory) and development of DMLC Part II by Shipowner (based on
national requirements defined in DMLC Part I)
• Review of DMLC Part II by Recognized Organization or Administration for verification of
Shipowners documented system compliance with Flag state national requirements
• Initial onboard inspection for verification of onboard implementation of Shipowners
documented system
• Issuance of Maritime Labour Certificate or Statement of Compliance (as per
Administration requirements) and approval of DMLC Part II

Stages of ship certification process for non MLC ratifying flags (voluntary certification)

• GAP analysis (not mandatory) and development of DMLC Part II by Shipowner (based on
MLC 2006 requirements)
• Review of DMLC Part II by Recognized Organization or Administration for verification of
Shipowners documented system compliance with MLC 2006 requirements
• Initial onboard inspection for verification of onboard implementation of Shipowners
documented system
• Issuance of Maritime Labour Certificate or Statement of Compliance (as per
Administration requirements) and approval of DMLC Part II

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 19


General experience on MLC, 2006 certification process

Difficulties observed during certification stages


• Issuance of DMLC Part I by the Administration
• Some Flag states late in establishment of national requirements and DMLC Part I
• Shipowners commenced work on draft DMLC Part I
• Due to MLC 2006 flexibility Flag states have different national requirements
• For non ratifying States, Shipowners developed DMLC Part II based on MLC 2006
requirements and will need to by updated once the State will ratify the Convention
or issue national requirements
• GAP analysis (not mandatory) and development of DMLC Part II by Shipowner (based
on national requirements defined in DMLC Part I)
• Some shipowners late in preparation of DMLC Part II
• Difficulties in complying with national requirements
• Shipowners having multiple Flag fleets need to prepare flag specific
DMLC Part II for every flag due to Flag state specific requirements
• Review of DMLC Part II by Recognized Organization or Administration
• DMLC Part II in different forms
• As self standing document
• With references to other procedures and documents
MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 20
General experience on MLC, 2006 certification process
Difficulties observed during certification stages
• Review of DMLC Part II by Recognized Organization or Administration
• Identification of Shipowner (entity responsible for all MLC 2006 requirements)
• In most cases ISM manager, in some cases other entity (owner of the ship)
• In some cases ISM Manager, identified as Shipowner, does not accept the
responsibility for all MLC 2006 requirements ( i.e. liability for wages and cost in
respect of sickness and injury)
• Difficulty to identify the MLC responsible Shipowner on large passenger vessels
due to the fact that this entity has to take full MLC responsibility for all seafters
onboard (navigational and non navigational)
• Seafarer Employment Agreement (SEA) not as required by MLC 2006
• Shipowner Representative signature without Shipowner authorization
• Shipowner not identified on Seafarer Employment Agreement
• Seafarer Employment Agreement not containing all mandatory data
• Compliance with existing accommodation requirements
• Difference in applicability of existing ILO accommodation conventions (ILO 92
and 133) due to Flag state ratifications
• Some ships not in possession of document (issued by Flag or Classification
Society) confirming compliance with applicable ILO accommodation conventions
• Survey for compliance with applicable ILO Accommodation convention performed
on many ships

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 21


General experience on MLC, 2006 certification process

Difficulties observed during certification stages


• Review of DMLC Part II by Recognized Organization or Administration
• Shipowners Controll of Seafarers Manning Offices
• No evidence that the Shipowners has assured that the SMOs used work in
compliance with MLC requirements
• Shipowners difficulties in proving financial security for repatriation
• Initial onboard inspection
• Detailed list of deficiencies by MLC 2006 Regulation in next section
• Issuance of Maritime Labour Certificate or Statement of Compliance (as per
Administration requirements) and approval of DMLC Part II
• Different Flag state requirements related to type of document to be issued
• Some Flag states defined Statement of Compliance and some Maritime
Labour Certificate to be issued
• Different certificate formats for MLC 2006 ratifying and non ratifying Flag
states

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 22


General experience on MLC, 2006 certification process
Rectification of difficulties observed during certification stages
• Issuance of DMLC Part I by the Administration and
• GAP analysis (not mandatory) and development of DMLC Part II by Shipowner (based on national
requirements defined in DMLC Part I)
• During the one year entry into force period all ratifying flags and many non ratifying flags
issued final versions of DMLC Part I enabling Shipowners to finalize required documentation
• Review of DMLC Part II by Recognized Organization or Administration
• DMLC part II review process is interactive between the Shipowner and the Recognized
Organization or the Administration which performs the review
• The process is finished only after DMLC part II is fully in compliance with national
requirements as defined in DMLC Part I enabling the initial onboard inspection
• Initial onboard inspection
• All non compliances found during the onboard inspections were classed as serious
deficiencies, deficiencies or observations and treated in line with Recognized Organization
procedures
• Immediate corrective actions in case of serious deficiencies were performed and corrective
action plan in case of deficiencies has been agreed with 3 months maximum for
implementation
• Rectification of deficiencies will be followed in accordance with Recognized organization or
Administration procedures
• Issuance of Maritime Labour Certificate or Statement of Compliance (as per Administration
requirements) and approval of DMLC Part II
• Recognized Organizations certificates issuance system has been adapted to meet all different
Flag requirements

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 23


Deficiencies identified during MLC, 2006 onboard inspections
Deficiencies identified during MLC, 2006 onboard inspections

MLC
Regulation Serious Deficiency Deficiency Observation Total
During 1285 MLC inspections there were
2.1 2 169 96 265 - 3 Serious Deficiencies
3.2 68 118 186
-631 Deficiencies
1.2 52 71 123
3.1 1 78 44 122 - 495 Observations
2.3 45 31 76 onboard 395 vessels distributed on 17
4.1 50 19 69
4.3 37 30 67
MLC 2006 regulations
1.4 29 25 54
2.2 40 11 51
Most affected regulations:
5.1.5 15 22 37
1.3 19 10 29 - 2.1 – Sefarers’ Employment Agreement
2.5 12 4 16
(SEA)
5.1.1 6 5 11 - 3.2 – Food and catering
4.2 4 4 8
-1.2 – Medical Certificate
4.5 4 3 7
2.4 2 1 3 -3.1 - Accommodation and recreational
2.7 1 1 2
Total 3 631 495 1126
facilities

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 25


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 1.2 – Medical Certificate
- medical certificates not complying to national requirements
- expired certificates onboard
- seafarers without color vision certificates
• Regulation 1.3 – Training and qualifications
- crew members without valid or expired certificates of competency
- ship cooks without certificate of competence recognized by Flag
• Regulation 1.4 – Recruitment and placement
- no evidence that the Shipowner has verified that Manning Agencies used work in
compliance with MLC requirements

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 26


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 2.1 – Seafarers Employment Agreements
- Seafarers with expired SEA (Sefarers’ Employment Agreement) onboard (Serious
Deficiency)
- SEA not signed by MLC Shipowner or representative (Serious Deficiency)
- SEA and/or CBA (Collective Bargaining Agreement) not in English language on
ships in international voyage
- SEA not containing all required by MLC Regulation 2.1.4
- amount of paid annual leave
- name and address of the Shipowner
- notice of termination not defined
- record of employment not issued to seafarers
- record of employment containing evaluation of seafarers work

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 27


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 2.2 – Wages
- wage slip not delivered on monthly basis
- wage not calculated as required (i.e. holidays not included, overtime)
- transfer of wage sometimes not effective
• Regulation 2.3 – hours of work and rest
- work and rest hours divided in more then two periods
- working schedule not posted onboard
- sefarers not receive copies of work and rest hours record
- work and rest hours record and shipboard working schedule not on approved
format
- work and rest hours record not endorsed by master and/or seafarer
• Regulation 2.4 – Entitlement to leave
- no confirmation that annual leave and public holiday compensation was paid

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 28


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 2.5 – Repatriation
- repatriation conditions in SEA (Seafareres’ Employment Agreement) not in
compliance with MLC requirements
- some repatriation costs not paid by shipowners i.e. food
• Regulation 2.7 – Manning levels
- seamen’s books not endorsed properly
• Regulation 3.1 – Accommodation and recreational facilities
- accommodation arrangement not in compliance with approved drawings (Serious
Deficiency on non MLC ratifying flag vessel)
- Accommodation maintenance not as required (mostly on older vessels)
- toilets not clean
- dirty galley and stores
- common toilets equipment damaged
- mess room equipment damaged
MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 29
Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 3.1 – Accommodation and recreational facilities
- records of crew accommodation as required by the Administration not onboard
• Regulation 3.2 – Food and catering
- storage of food not as required
- food preparation and catering areas not hygienic (mostly on older vessels)
- quantity of food not sufficient for the intended voyage
- no evidence that the catering crew has received required training
- periodical inspections of food storage and preparation areas not performed at
intervals required by the Administration
- no drinking water analysis records onboard

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 30


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 4.1 – Medical care onboard ship and ashore
- onboard medical store not in line with administration requirements
- hospital equipment not functional (oxygen system)
- required medical documentation not onboard (manuals, IAMSAR)
- standard medical report form prescribed by the administration not onboard
• Regulation 4.2 – Shipowner’s liability
- burial expenses clauses not in compliance with MLC requirements
- no procedure for safeguarding of sick or injured seafarer property

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 31


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by MLC, 2006 regulation


• Regulation 4.3 – Health and safety protection and accident prevention
- risk assessment not evaluating all shipboard operations
- noise and vibration levels not established and controlled
- occupational health and safety issues not addressed
- health and safety committee not established onboard
- OSH training and programe not performed and followed onboard
- accident prevention and safety culture not promoted onboard
• Regulation 4.5 – Social security
- social security protection required by CBA (Collective Bargaining Agreement) not
provided
• Regulation 5.1.1 – General principles
- documentation required by the administration and copy of the Convention not
provided onboard

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 32


Deficiencies identified during MLC, 2006 onboard inspections

Identified deficiencies by regulation


• Regulation 5.1.5 – On board complaint procedure
- copy of On board complaint procedure nor available to all seafarers
- seafarers not familiar with the procedure
- On board complaint procedure not in compliance with Administration
requirements
- required contacts (Administration, Shipowner) not included in the
procedure

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 33


MLC – Experienced deficiencies during
inspections
MLC – Experienced deficiencies during inspections

INSPECTOR 1
1.Follow-up and implementation by Flag administrations
Delay of Flag States’ implementation
2.Follow-up by our class society
Late submissions of DMLC Part II
3.Implementation by Ship managers
Some shipmanagers were not aware of MLC 2006 as late as Aug. 2103

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 35


MLC – Experienced deficiencies during inspections

INSPECTOR 1
4.Findings onboard

• Some Danish CBA (Collective Bargaining Agreement) are not in English available
• Toilets in cabins not operational
• Storage of food in an not hygienically way, food stored in workshop or machinery
space
• Certificate of competency by the flag state not available onboard
• Contract of the master only available in the local language
• No clear contract for the apprentice
• Use of a non certified crewing agency.
• Outdated medicines
• Hospital in use as normal cabin
• Galey found with broken tiles at the floor and walls.
• Rest hours not in compliance with the requirements. Too little sleep too many
working hours, rest hour period not in compliance.
• Point of contact for complaints in port not available.

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 36


MLC – Experienced deficiencies during inspections

INSPECTOR 1

5.Present situation
• Still many ships have to be inspected for MLC.
• Still ships to be reviewed for DMLC Part II

• Advice for the future systems: Step by step implementation dates for different type
of ship.

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 37


MLC – Experienced deficiencies during inspections

INSPECTOR 2

1. Galleys and provision stores with poor maintenance standard


2. Missing details in Seafarers’ Employment Agreement (SEA)
3. Collective Bargaining Agreements (CBA) in national language only
4. Cooks knowledge improper in way of correct handling and storing of provision.
5. List of port contacts ( ports of call ) missing
6. Accommodation inspections not recorded.

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 38


MLC – Experienced deficiencies during inspections

INSPECTOR 3

• SEA (Seafarers’ Employment Agreement) and CBA (Collective Bargaining


Agreement) not in English language, especially for Danish flag
• Date of birth and place of birth of seafares missing in SEA
• Missing information regarding the link between SEA and CBA (for exp. CBA
number ITF No. S13690 non specified).
•Found different CBA s on board, and not linked one each other and not indicated in
the SEA
•Date and place where the contract is concluded;
•Medical Certificates of Danish flag found on board, for all seafares, is not the one
indicated in the web site www.dma.dk. All seafars have instead a medical certificate
called" Health Certificate for Seafarers and Fishermen ", which sometimes is a Blue
Book and sometimes is a White Book.
•No evidence, for all crew members, of the basic training course according to STCW
78-95, Reg. A-V1/1, A-V1/1-2, A-V1/1-3, A-V1/1-4, (Personal Survival Techniques,
Fire Prevention on Fire Fighting, First Aid, Personal Safety and Social
Responsibility.)
•Missing contract between Company/Manager/Owner and Recruitment agency.
•Missing evidence of seafares safety representative and safety committee.
MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 39
MLC – Experienced deficiencies during inspections

INSPECTOR 3

• Food refrigerator found in boson store, in forecastle, close to paints and chemical
agents
• Kitchen found dirty, especially in the corners under the furniture's and ovens, and
broken tiles as well
• Main deck floor pavements, relative to cabins, corridors, stairs, mess room,
toilettes showers, results damaged and a lot of cracks in many parts. Where carpets
are applied they were dirty and damaged. No washing machine for carpets was
present on board
• Side scuttles, relative to crew cabins and galley results full or rust and gaskets
damaged. Signs of water ingress
• Cabins light without ceiling cover protection
• Toilettes and showers signs of rust, water leaking and corrosion in water and
discharge pipes
• Door and bulkhead separating, between steering gear room and provisions room,
not properly closed

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 40


MLC – Experienced deficiencies during inspections

INSPECTOR 4

• Medical certificate not containing minimum information


• Medical practitioner not approved
• No suitable contract for cadet
• Chemicals used without Safety Data Sheets
• Seafarers’ Employment Agreement (SEA) not containing minimum information

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 41


MLC – Experienced deficiencies during inspections

INSPECTOR 5

• Seafarers not familiar with complaint procedure


• Collective Bargaining Agreement (CBA) not available on board
• Seafarer's discharge book missing
• Wages not matching contract

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 42


Bureau Veritas MLC, 2006 related services
Bureau Veritas MLC, 2006 related services

Client DMLC II in Veristar Info

• Web based
application
accessible to
clients in personal
Veristar fleet view
• Reducing time for
creation and
submission of
DMLC II for review
• DMLC II
documentation for
the same Flag may
be cloned to other
ships in fleet of the
same flag

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 44


Bureau Veritas MLC, 2006 related services

Assessment of seafarer manning offices

► Reg 1.4 and Code –


Requirement for licencing and
certification of manning
agencies
► NI 563 – QMS for Seafarers
Manning Offices
► BV Attestation of Compliance

► More then 100 Attestations issued by


Bureau Veritas on Voluntary Basis
 United Kingdom
 Philippines
 Greece
 India
 Croatia
 Ukraine
 Germany

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 45


Bureau Veritas MLC, 2006 related services

Guidance Note NI577 –


ACCOMMODATION
► for assignment of additional class
notation ACCOMODATION
► may be requested for ships of
ratifying and non ratifying countries
► design and construction in respect
with Title 3 of MLC 2006
► defining the requirements for
• accommodation design
• vibration
• noise
• indoor climate
• lighting

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 46


Bureau Veritas MLC, 2006 related services

www.bvbusiness-school.com
► E LEARNING course

Introduction to the Maritime Labour Convention, 2006


• first step of MLC related education
• addressed to ship's crew
• company MLC supporting staff
• anyone involved in MLC related issues at general level.

Course is accessible on line through following web site

www.bvbusiness-school.com

MSSM Seminar – MLC 2006 – Nyborg, Denmark – 27 & 28 Aug. 2013 47


Thank you

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