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Advancing the Conversation on Seafarer Fatigue at the IMO

by Phil Schifflin, Esq. — Director, Center for Mariner Advocacy, The Seamen’s Church Institute

In late February, I had the opportunity to represent the International Christian Maritime Association (ICMA) at the International Maritime Organization’s (IMO) Human Element, Training and Watchkeeping (HTW) Subcommittee meeting, held February 23–27 in London. As Director of the Center for Mariner Advocacy at the Seamen’s Church Institute (SCI), I make it a priority to attend the HTW meetings when they occur, as among the IMO’s many committees and subcommittees, this body is most directly focused on seafarers.

This year’s meeting addressed several important issues. The agenda was largely dominated by the comprehensive review of the STCW (Standards of Training, Certification and Watchkeeping for Seafarers) Convention, which is a top-to-bottom examination of the international framework that establishes training standards for seafarers worldwide. The review is a long-term undertaking that has already been underway for several years and will likely require several more years before it is completed.

In addition, this subcommittee examined emerging questions around specialized training requirements for seafarers serving aboard vessels powered by alternative fuels. This is an issue that will only grow in importance as the maritime industry moves toward new energy technologies.

However, the topic that demanded most of my attention, and that I believe carries particularly significant implications for seafarers, was the scoping exercise examining fatigue-related provisions within the IMO framework. The purpose of the exercise was to determine what issues and reference materials should be considered as the IMO evaluates how best to address seafarer fatigue. Not surprisingly, opinions among delegates varied. Some preferred a more focused review on a narrower range of issues. ICMA, instead, advocated a broader, more holistic examination of the factors contributing to fatigue. Ultimately, ICMA’s view was supported by a majority of the delegates. 

The next phase of this work will take place through a correspondence group that will continue the analysis between now and the next HTW Subcommittee session, scheduled for 2027. I expect to participate in that group on behalf of ICMA as the work continues.

In addition, another IMO body, the Subcommittee on Implementation of IMO Instruments (III), may also have a role to play in the fatigue discussion. This subcommittee develops much of the guidance related to port state control procedures, and there are ongoing questions about whether additional tools or processes could help inspectors more effectively detect violations of seafarers’ hours-of-work and hours-of-rest requirements. I will be monitoring the development of the III Subcommittee’s agenda ahead of its meeting later this July. If the fatigue issue appears there, I anticipate attending and again representing ICMA in those discussions.

The goal for ICMA, as always, is that the voices and well-being of seafarers remain central to the IMO’s regulatory conversations. These subcommittee meetings, particularly HTW, remain the most important forums for advancing that goal. I am encouraged that the recent discussions have opened the door to a more comprehensive look at one of the industry’s most persistent human-factor challenges: fatigue at sea.