Watchkeeper Fatigue

July 15th, 2005 by JCB
Posted in Features | No Comments »

WATCHKEEPER FATIGUE

Although pilots in the UK frequently have antisocial shifts the issue of fatigue seems to be generally well managed (except perhaps on the Humber!) by rosters which have evolved over time in most ports to provide a compromise between productivity and adequate rest. This fact seems to be bourn out by investigations into pilotage incidents which have not identi.ed fatigue as a statistical cause. Further con.rmation is that fatigue has not been raised as an agenda issue at conference except in relation to verifying compliance with the Working Time Directive. Having made that statement it doesn’t mean that we should ignore the issue of fatigue since an increasing amount of research places pilots in the highest zone of those at risk from the cumulative effects of disruption to sleep patterns. These effects are mainly an enhanced risk of heart disease, obesity and depression. Regrettably, as we all know, these effects, coupled with the high stress levels associated with pilotage, have resulted in pilots suffering above average levels early retirement and premature death.

For many years pilots, whilst acknowledging that modern on-board equipment has made navigation in pilotage waters safer, have argued that compulsory pilotage should not be reduced because as new technology has been introduced the consequent reduction

in manning has more than cancelled out any safety advantages achieved by such technology. This argument has of course been fiercely opposed by the shipping

industry and some ports who always perceive compulsory pilotage as an expensive and outdated anachronism! However, the statistics cannot be disputed and fatigue amongst seafarers is now a major cause of groundings and collisions and at last there is a spotlight being shone upon shipboard practices which is revealing a murky world of

unethical practices which until now have prevented the reality of seafarer fatigue from being exposed to the public gaze. Much of the focusing of this spotlight has been undertaken by the MAIB who are to be congratulated in their persistence over the last few years in placing the issue on the agenda at maritime forums and this perseverance is now at last producing recognition that a serious problem exists.

The results of a specialist survey undertaken by the MAIB, in conjunction with Qinetiq Centre for Human Sciences, into the six on / six-off watch system operated by deck officers on many vessels make for frightening reading.

Such is the concern of the MAIB over this issue, they have taken the unprecedented step of including a special report on their survey in the Safety Digest 1/2005 One aspect of this survey looked in detail at 19 groundings where the on-board watch patterns were identi.ed and the statistics from those 19 groundings revealed two key facts:

·        68% of the vessels were operating a 2 watch system

·        100% of the groundings between 0000 – 0600 were on vessels operating a two watch system.

Using an assessment programme based on one used for aircrews the MAIB survey model analysed the typical working pattern of an officer on a 12-6 watch on a 2,000grt ship. Even when not subjected to extra duties in the off watch period the model indicated that “dangerous” levels of fatigue were reached after as little as two to three weeks.

The MAIB report states that the “…survey serves to reinforce the MAIB’s long-held belief that fatigue, brought on by minimal manning and arduous watchkeeping and operational routines, is endemic at sea, especially in the short sea trade”. The report also states that:

A number of the accidents in the study were caused as a direct result of a lone watchkeeper falling asleep, but fatigue was a factor in many more of them. Long before a watchkeeper has reached the stage where he cannot keep his eyes open, fatigue is affecting his performance. It can cause the following:

·        Inability to concentrate, including being less vigilant than usual

·        Diminished decision-making ability including:

·        Misjudging distance, speed, time etc

·        Overlooking information required for complex decisions

·        Failing to anticipate danger

·        Poor memory, including forgetting to complete a task or part of a task

·        Slow response, including responding slowly to normal, abnormal or emergency situations

·        Reduced competence in interpersonal dealings

·        Attitude change, including:

·        Being too willing to take risks

·        Displaying a “don’t care” attitude

·        Disregarding warning signs

The data used in the safety study, especially that associated with grounding accidents, indicated a strong link between fatigue and watchkeeping arrangements. In its “Lessons” summary the report includes the following two specific recommendations:

·        Minimum safe manning levels need to be increased so that each seagoing

vessel of over 500gt has at least a master and two bridge watchkeeping officers.

·        Masters and owners should ensure that a vessel does not leave harbour unless all the watchkeepers, including the master where appropriate, are well rested.

NUMAST has taken up the issue and been running a major campaign recently to highlight the problem. Further to data received from the MAIB survey, NUMAST are supporting research by Cardiff University’s centre for occupational and health psychology sponsored by the MCA and H&SE. This is a major survey which is due to be completed in September 2006 and is surveying seafarers in three sectors, deep sea, offshore and short sea.

THE EU WORKING TIME DIRECTIVE?

In order to address the problem of fatigue at sea the EU included seafarers in the WTD in July 2003. Despite much resistance from shipowners the directive rules that seafarers should work no more than 14 hours in any 24 with a maximum of 72 hours in any seven day period. They are entitled to 10 hours rest in any 24 hour period with rest of 77 hours in any seven day period. The rest period may be divided into two periods but must include at least one period of 6 hours and the interval between consecutive rest periods must be no longer than 14 hours.

Having worked the 12 -6 watch myself as Second Mate in the 1970’s for 4 -6 weeks at a stretch my observations are that these WTD working rules, if adhered to, would result in a reasonably safe watchkeeping regime. The problem is that the rules are not being adhered to and up until now no one has really shown any interest in enforcement. Indeed, evidence seems to indicate that whilst all companies now issue instructions to their Masters that working hours must be compliant with the WTD some companies unofficially, actively discourage the Master to actually follow the regulations. The compliance instructions obviously remove the potential for liability from the Owners but leave the Master literally between the rocks and a hard place! The Master is always under pressure to sail and regrettably there is evidence to support the claims that if a master delays his ship for the purposes of resting the crew he will rapidly be replaced by a Master who is prepared to interpret the regulations in a more “flexible” manner! From a practical point of view there are frequently pressures on berth availability which may force a master to sail anyway and anchoring is not really a solution since normally an anchor watch will need to be kept so the vessel might just as well be on passage.

There are of course exceptions and I have piloted many coasters where the owners request the master to ensure that the crew are sufficiently rested in accordance with regulations and will never query his decision to remain alongside a berth for rest. I have also piloted other small vessels where, although the vessel is not subject to compulsory pilotage a master has taken a pilot in order to catch up on rest for

himself. It is of course an appalling situation where such good practices are undermined by a significant number of operators who whilst writing instructions on compliance will penalise or threaten a master who actually seeks to operate within the law. The

situation is also not helped by the practice by some companies of offering the master additional payment for self piloting his vessel thus providing a financial incentive to

stay on the bridge although he may be dangerously fatigued. Most VTS centres will have records of desperate attempts to alert non-piloted vessels that are standing into danger. Although it is obvious that these navigational errors are a result of the master or

watchkeeper falling asleep there is always an excuse other than fatigue provided by the master and some of these can be very imaginative and occasionally amusing. Insects of various varieties and grades of malevolence are a popular reason for causing

distractions to the OOW but in all cases the watchkeeper is always effusive with thanks when alerted to the danger! Unfortunately

outside areas covered by VTS (and occasionally within) the OOW fails to awake and the results are yet another wreck on the coast or a collision. It is the investigations into these incidents that has revealed the problems of fatigue

INSPECTIONS & ISM

The point is often argued that vessels need to show records of compliance with the WTD as part of their ISM procedures and it is true that “official” records of inspections will reveal that vessels are complying with the WTD and that there is no problem.  How can this happen? Well, “flogging the log” is still a thriving practice and I have had masters admit to me that they keep one set of records for the inspectors and another for the office for the overtime! I have also heard a story of a company sending a computer program to cover shipboard ISM requirements and in the section for recording working hours, if hours in excess of those permitted by the WTD were entered, the program refused to accept “illegal” data and requested that the operator enter correct data!!

IS THE PROBLEM BEING EXAGGERATED?

The reason that a formal survey is being undertaken is a direct result of the hidden picture revealed by MAIB investigations.  A survey by NUMAST amongst its members, who one would expect to be working on fully compliant vessels, revealed the following statistics:

2% of masters and officers were clocking up 16 or more hours per

day

2.4% worked in excess of 100 hrs per week.

29% did not regularly obtain 10hrs rest in 24

12% failed to get at least 6 hrs unbroken rest in 24

27% worked 15 or more hours continuously

20% spent 4 or more hours on additional duties.

50% felt that their working hours presented a potential threat to their personal health and safety 30% felt that working hours presented a danger to safe operations on board.

Obviously, being statistics, these figures need to be put in context since they represent those who responded to the survey. NUMAST does not detail the respondents as a percentage of the membership but it is obvious that those who are working non compliant hours are more likely to respond than those who are on fully compliant vessels. Despite this the survey does reveal a disturbing picture of non compliance with the WTD and another important finding of the survey was that only 7% stated that their hours had reduced in the last 5 – 10 years where a massive 51% reported an increase in working hours over that period.

Could these results be put down to members disgruntled with their lot and therefore be unrepresentative?

The following represents the findings of a researcher who spent fourteen days on board a 3500dwt mini bulker, with only two watchkeepers, during which time the vessel visited ports in Holland, Sweden, Germany, Belgium and Portugal.

“Both men were working six hours on, six hours off on a four months-on/two months-off work/leave pattern. The standard working arrangement for the deck officers was therefore 12 hours a day, seven days a week for four months without a break.  Whilst such a working schedule appears patently excessive by onshore standards, 84 hours a week is actually very much the best case scenario for seafarers working a six-on/six-off two man watch.  The captain in particular would frequently work from the start to the finish of a port visit without sleep, a stretch of as long as 24 hours. With only two officers to cover a 24 hour watch there was no ‘slack’ in the system – if one of the officers was unfit to work the other officer was forced to cover, putting an immense burden of duty on both seafarers.’

The researcher said it was clear that excessive job demands had been woven into the culture onboard ship. The deck officers on the vessel were expected to work 12 hours a day – which failed to account for the fact that one or two hours of paperwork would routinely have to be done in supposedly ‘off-duty time.”

The study identified a number of factors which come together to make working on a mini-bulker particularly demanding:

·        Short port stays, leaving no time for rest or recovery before heading back out to sea

·        Frequent port visits

·        Changing cargo types placing extra demand on the crew to prepare the ship accordingly

·        Only two officers to cover a 24-hour watch

·        Longer pilotage

·        Unpredictability of tramping’ from port-to-port, which can be stressful and makes planning sleep and rest periods difficult

“In terms of understanding seafarers fatigue, therefore, where working hours might often appear the obvious culprit a more sophisticated approach is required’ which sees excessive working hours as potentially symptomatic of a poor solution to the port versus-

sea ‘crewing conundrum’,” the report concluded. As the researcher left the ship at the end of the study, the master appealed to him to highlight their conditions. “Something’s going wrong,” were his parting words.

SHOULD PORTS BE INVOLVED IN THE DEBATE?

The ports are obviously reluctant to become involved in this issue.  Already, the owners of small vessels feel port charges such as pilotage more than larger vessels and ports have addressed this either by subsidising the charges applicable to small vessels from the revenue obtained from the larger vessels or by excluding small vessels from compulsory pilotage altogether. Regular traders will usually be issued with a pilotage exemption certi.cate. The factor of fatigue is not addressed because if the master declares compliance with international and local regulations then the attitude is that the vessel will be manned in accordance with regulations so fatigue management is a matter for the Master and therefore not relevant to a vessel’s visit to the port. But, is this a neat excuse for avoiding the issue? Under the UK’s Harbours Act a Harbour Authority has a “duty of care” to all shipping and infrastructure within its jurisdiction. Despite the fact that a Master may declare that his vessel is compliant with WTD regulations it may become evident that the vessel is in breach of the WTD. If we take the case of a two watch feeder containership, the master will normally keep the 6 -12 watch and if he is the only PEC holder for a port he will be required to be on the bridge at all times whilst in port limits. This vessel might report at the outer limits of a port at 0400 and berth at around 1000. Typically this class of vessel will turn around in about 5 hours so will leave around 1700 and therefore clear the port limits at around 2300. With both master and mate required for berthing and port work neither can possibly comply with the WTD and both will be fatigued. If the master fell asleep on the outward passage and the vessel ran aground or had a collision could he hold the port in any way liable because since the port’s records are capable of identifying a breach of the WTD could the port be found to have failed in its duty of care by permitting the vessel to sail? I would be interested to know the thoughts on this from any lawyers amongst you.

WHAT CAN PILOTS DO?

Whilst piloting a vessel, if a pilot becomes aware that fatigue may be a problem the pilot can be placed in an awkward position if the Master tells him in con.dence that he is suffering from fatigue.The Master/Pilot relationship could be weakened if the pilot immediately reports the fatigue to the Harbour Master but there is a duty to report the matter in the interests of safety. The port may .nd it impossible to take any action if the Harbour Master visits the vessel and the Master shows false documents indicating compliance with rest regulations. Likewise if the MCA are called to inspect the vessel, again the Master may be reluctant to reveal a true picture and have the vessel detained. In such a case the best solution would appear to be to obtain as many details as possible from the Master and report the matter to CHIRP. By using the RISAP inter pilot reporting facility other ports can be alerted to the problem and if suf.cient data is obtained then the con.dential and anonymous CHIRP process would probably be able to confront the owners without jeopardising the Master’s position. In the case of exempt vessels the problem is more dif.cult but if a vessel appears to be displaying symptoms of being under the command of a fatigued PEC holder then the HM and the MCA should de.nitely be informed.

CONCLUSION

The fact that this issue is now receiving serious attention is welcome but it is not going to be easy to change the status quo and already pressure is growing to prevent the matter being raised at the IMO. The current situation is summarised in the following edited

extracts from a Lloyds List feature (2^nd June) entitled “go on, stop on”

“There is no doubt in the minds of the MAIB inspectors who have ploughed through the causes of some 1,600 accidents over a 10-year period that “poor manning levels and fatigue were major causal factors in collisions and groundings”.

“It is an anachronism in the 21^st century”, Admiral Stephen Meyer points out, “that seafarers are falsifying their timesheets to prove that they are working ONLY a 98-hour week. And many of these seafarers work every week, without a break, for between four and nine months before getting leave”.

There is equally no doubt that the operation of ships with a Master and mate alternating 6-hour watches is a recipe for disaster, even though it is a practice that has been widely used in the short sea trades, often, and illegally, without even a lookout during hours of darkness.

There is conclusive research to point to the rapid onset of fatigue aboard ships operated in such a fashion. There is, in fact, no reason for such a way of working to be perpetuated, and the MAIB has made it clear that it considers this way of ship operation is downright dangerous.

It is also interesting to note that the MAIB is regarded with great respect for its independence and could form a “model” for other casualty investigation systems in both European countries and elsewhere.

But issues of fatigue and manning levels cannot be confronted at a national level. The International Maritime Organization needs to take the matter forward as a matter of urgency.

Which makes it quite mysterious that a UK paper on this subject, in which the MAIB research featured largely as evidence, was withdrawn at the last minute from discussion at the recent Maritime Safety Committee, after pressure from the European Commission. That’s not a mystery, that’s a scandal.”

JCB