Concentrated Inspection Campaign (CIC) 2024: Crew Wages and Seafarer Employment Agreements

The maritime industry is preparing for the upcoming Concentrated Inspection Campaign (CIC) in 2024, focusing on “Crew Wages and Seafarer Employment Agreements under MLC” (Maritime Labour Convention). This comprehensive guide provides essential information for shipowners, managers, and crew members to ensure compliance and avoid potential detentions.

Duration and Timing

The CIC is scheduled to run for three months, from September 1, 2024, to November 30, 2024. This timeframe allows for a comprehensive assessment of vessels across different regions and provides ample opportunity for Port State Control officers to conduct thorough inspections.

Participating Authorities

Paris and Tokyo MoUs

The campaign is jointly organized by the Paris and Tokyo Memoranda of Understanding on Port State Control. These are two of the most influential regional port state control regimes, covering a significant portion of the world’s maritime traffic.

Other PSC Regimes

Most other Port State Control regimes are expected to participate in this CIC, extending its reach globally. This widespread participation ensures a consistent approach to enforcing Maritime Labour Convention (MLC) standards across different regions.

US Coast Guard Exception

The United States Coast Guard is not expected to participate in this CIC. This is likely due to the US not being a signatory to the MLC, although they enforce similar standards through their own regulations.

Focus Areas

The CIC will concentrate on three main aspects of seafarers’ rights:

1. Crew Wages: Inspectors will verify that seafarers are paid correctly and on time, in accordance with their employment agreements and MLC standards.
2. Seafarer Employment Agreements (SEAs): These documents will be scrutinized to ensure they comply with MLC requirements, including clear terms of employment, working conditions, and rights.
3. Financial Security Requirements: This relates to the 2014 amendments to the MLC, which mandate that shipowners provide financial security to cover abandonment, as well as contractual claims for death or long-term disability.

Inspection Process

Integration with Routine Inspections

The CIC will not be conducted as a separate inspection but will be incorporated into regular Port State Control inspections during the specified period. This approach allows for a more comprehensive evaluation of vessels’ overall compliance.

Additional Questionnaire

A supplementary questionnaire containing 10 specific questions related to crew wages and employment agreements will be used during these inspections. These questions are designed to probe deeper into the vessel’s compliance with MLC standards.

Key Points

• Detention Grounds: Almost all questions in the CIC questionnaire can potentially lead to vessel detention if significant non-compliance is found. This underscores the importance of thorough preparation by shipowners and managers.
• Compliance with MLC: The campaign aims to ensure that shipowners are fulfilling their responsibilities regarding seafarers’ basic rights as outlined in the Maritime Labour Convention.
• Extended Inspections: If Port State Control officers encounter uncertainties or suspicious circumstances during the initial inspection, they may decide to extend their examination to other crew-related matters.
• ISM-Related Deficiencies: Deficiencies found during this CIC may also lead to International Safety Management (ISM) Code-related deficiencies. This could result in more severe consequences, including detention, as it indicates systemic issues in the vessel’s management.

Preparation Recommendations

• Up-to-Date Information: Ensure all required information about working arrangements and payments is current and readily available to crew members. This includes wage accounts, overtime records, and leave calculations.
• Inform Ship Masters: Brief ship masters about the upcoming CIC and the types of documents that may be requested during inspections. This preparation helps ensure smooth cooperation during PSC visits.
• Display MLC Documents: Prominently display all relevant MLC documents on board the vessel. This includes certificates, declarations of compliance, and seafarers’ employment agreements.
• Familiarize Crew: Ensure masters and officers are well-versed in their duties related to MLC compliance and are familiar with the supplementary checklist that will be used during inspections.
• Update Safety Management System: If necessary, consider updating the vessel’s Safety Management System to reflect any recent changes in MLC requirements or company policies related to crew wages and employment agreements.

By thoroughly preparing for the 2024 CIC on Crew Wages and Seafarer Employment Agreements, shipowners and managers can minimize the risk of detentions and ensure compliance with MLC standards, ultimately contributing to better working conditions for seafarers worldwide.