Seafarer fatigue: why safety management is incomplete without the human element

In the analysis of major maritime accidents, from groundings to collisions in busy waterways, “human error” is always named as the main culprit. Yet careful investigation shows that human error is often the direct result of an overlooked physiological phenomenon: fatigue. Shipping companies that build their safety management system (SMS) only on flawless completion of paper checklists are completely exposed to this silent risk.

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1. Where the regulatory regimes meet: STCW, MLC 2006 and the IMO guidelines

Controlling fatigue at sea rests on three distinct legal and technical pillars:

• The STCW Convention (Regulation VIII/1 and Section A-VIII/1): this regulation focuses on “fitness for duty” and requires a minimum of 10 hours of rest in any 24-hour period and 77 hours in any seven-day period. Rest may be divided into no more than two periods, one of which must be at least 6 consecutive hours.
• The Maritime Labour Convention (MLC 2006, Regulations 2.3 and 2.7): from the standpoint of seafarers’ fundamental labour rights and welfare, this convention sets the permitted limits of work (under the maximum hours of work regime, 14 hours in any 24 hours and 72 hours in any 7 days; or under the minimum hours of rest regime, 10 and 77 hours) and the adequacy of manning (safe manning) in proportion to workload.
• IMO’s comprehensive fatigue guidelines (MSC.1/Circ.1598, adopted 2019): these guidelines take a systemic approach and stress that fatigue is not only a matter of hours of sleep; it is also the result of cognitive workload, noise, vibration, voyage planning and commercial pressure.

2. The hidden challenge: a “culture of adjustment” against reality

Reputable international research, including a World Maritime University study (WMU 2020) and UNCTAD’s Review of Maritime Transport (UNCTAD RMT 2025), has exposed a widespread structural anomaly known as the “culture of adjustment”. Survey research has pointed to a gap between recorded hours and hours actually worked in part of the fleet; the size of the gap depends on the sample and the research method.

A decision scenario and its operational consequence (hypothetical, informed by evidence)

In a hypothetical scenario, a container ship, after two back-to-back night-time discharge and loading operations in neighbouring ports with short stays, strikes a marker buoy in thick fog in a navigation channel. The hypothetical investigation shows that the officer of the watch had had only 3 hours of broken sleep in the previous 24 hours because of port operations and responding to audits; yet the ship’s rest-hours software had recorded full 10-hour compliance. Evidence like this can lead to closer examination by port State inspectors and action proportionate to the facts of the case; detention is not the certain consequence of every discrepancy.

Three management actions for shipping lines

• Organisational ownership of the action: the designated person ashore (DPA) and the fleet operations manager ashore (and at sea, the master).

1. Establish a just reporting culture: give the master and officers the authority and job security to record real hours of work and to declare that they are not physiologically fit, without fear of commercial reprimand.
2. Review minimum safe manning dynamically: audit whether the number of crew fits the real volume of cargo and anchorage operations, beyond the paper minimum stated in the flag’s document.
3. Integrate smart workload monitoring software into the SMS: use predictive fatigue monitoring systems and adjust voyage plans before entering high-traffic sea areas.

Conclusion

Seafarer fatigue is not a technical fault in the engine room that can be fixed by replacing a part; it is a test of the honesty and maturity of a shipping company’s safety management system. Protecting the human element is the most lasting investment in preventing costly maritime accidents.