Maritime Environment Policy and Law

MarinePALS CEO Presses for Practical Safe Manning Reform as IMO Reopens Seafarer Fatigue Discussions

As the International Maritime Organization prepares to reopen discussions on seafarer fatigue and hours of work at the 12th session of its Sub-Committee on Human Element, Training and Watchkeeping (HTW 12), MarinePALS CEO Captain Pradeep Chawla has called for a realistic reassessment of global manning scales, warning that growing workloads and stricter compliance demands are not being matched by adequate crew numbers.

Captain Chawla said ship operations have become increasingly complex, with busier schedules, heavier administrative burdens and tougher inspection regimes, while onboard crew numbers have steadily declined. He noted that safety standards have improved significantly over the years, citing advancements in navigation systems, communications, engines and environmental protection measures. International conventions such as SOLAS, MARPOL, STCW and the Maritime Labour Convention have become more detailed, inspections stricter and monitoring tighter. However, he stressed that while regulatory oversight has intensified, the number of personnel available onboard to manage these requirements has decreased.

He warned that every new regulation introduces additional documentation, logbooks and checklists. While each requirement may be reasonable individually, together they significantly increase workload pressures. According to Captain Chawla, seafarers worldwide are increasingly voicing frustration over the growing list of responsibilities that must be handled with existing manning levels.

Drawing on five decades of industry experience, including 17 years at sea and more than 30 years ashore in QHSE and training leadership roles, as well as involvement in IMO discussions and accident investigations, Captain Chawla said the upcoming HTW 12 review must not repeat previous cycles of debate without tangible progress. He emphasized that if regulators are serious about addressing fatigue, they must examine the direct relationship between workload, fatigue and safe manning levels.

Rather than proposing a blanket increase in crew numbers across all vessel types, he outlined practical principles for regulatory reform. These include establishing a non-competitive global minimum manning baseline, with a Master and three navigation watchkeepers considered essential; differentiating requirements based on sea areas, with stricter standards in congested coastal and high-traffic waters; factoring port intensity into manning decisions, particularly for vessels making multiple calls within a seven-day period; and recognizing differences in ship type and trade profile, such as the operational contrast between short-sea chemical tankers in Northern Europe and VLCCs on long ocean voyages.

He also urged flag administrations to use modern tracking platforms and AI systems to actively monitor trading patterns and port calls to trigger reviews of manning adequacy. Stricter control of exemptions was another key proposal, with stronger penalties for deliberate non-compliance or misleading declarations to ensure fairness and consistency across the industry.

Captain Chawla added that the industry seeks a level playing field and that consistent enforcement across flag states would encourage compliance. He cautioned that inconsistent interpretation of rules can create commercial imbalances. Stressing that safe manning has been debated many times before, he said the current discussion must be detailed and constructive, acknowledging the real task load faced by seafarers.

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Appealing to regulators ahead of HTW 12, he warned that without addressing underlying pressures such as workload, fatigue and inconsistent enforcement, the maritime sector risks revisiting the same concerns after every major accident. He concluded that the concerns raised by seafarers should be taken seriously, emphasizing that their lives and wellbeing must remain central to regulatory decisions.