November 1, 2011
The number of people on board a yacht is a topic that has been discussed across the globe, from the highest halls of the International Maritime Organization to the most obscure seaside taverns.
It seems that everyone that makes their living on the water has an opinion on this subject. How many is enough? How many crew is too many? Is that just running crew? What about maintenance?
Depending on your perspective, the answers can change.
The requirements for minimum safe manning originate in various regulations, including the Safety of Life at Sea Convention (SOLAS), Seafarer’s Training Certification and Watchkeeping (STCW) Code, IMO resolutions, several International Labor Organization (ILO) conventions, International Telecommunications Union (ITU) guidelines, World Health Organization (WHO) circulars, and numerous national laws.
As you can see, there are multiple interests involved in the manning of a yacht. The underlying principle in all of these rules is to establish the minimum number of people on board to safely operate the yacht.
In this process, the assigning authority for minimum safe manning is the flag administration, also known as the flag state. This is the country in which the yacht is registered and the flag of which flies on the stern.
The statutory applicability of minimum safe manning affects all seagoing vessels, except warships and recreational vessels not engaged in trade (i.e., private yachts).
In the yachting world, each flag administration defines its own policy for minimum safe manning. Each individual commercial yacht or, where allowed, those private yachts conducting limited charters, will be issued a document outlining the minimum number of crew required on board.
This column will address, in no particular order, the policies for the most common flags currently seen on yachts.
United States of America
For yachts registered under the U.S. flag, the U.S. Coast Guard assigns the minimum safe manning criteria for inspected vessels. Any yacht subject to inspection under 46 US Code will have the minimum complement of officers and crew necessary for the safe operation of the vessel outlined on the Certificate of Inspection (COI).
Red Ensign
While each individual flag of registry under the Red Ensign (UK, BVI, Cayman Islands, etc.) has the authority to assign the minimum manning levels, overall guidance is provided in Section 26 of the Large Commercial Yacht Code (LY2).Based upon the type of yacht (sail or motor), length, tonnage, and area of operation, the flag will issue a Minimum Safe Manning Document (MSMD) to the yacht.
For example, under the Cayman Islands flag, for pleasure yachts engaged in trade, the MSMD will be issued in accordance with LY2, as an internationally acceptable equivalence to SOLAS.
The issue of an MSMD is mandatory for all pleasure yachts engaged in trade over 500 GT, however it is Cayman Islands policy to provide an MSMD for all pleasure yachts of 24m and larger certified in accordance with the LY2 Code.
Marshall Islands
For yachts registered under the Marshall Islands flag, there are two classifications of yachts that are issued a Minimum Safe Manning Certificate (MSMC). These are commercial yachts and private charter yachts.
While the manning levels for each classification are nearly identical, the minimum qualifications for individual crew do fluctuate. For all commercial and private charter yachts of 24m load line length or more and/or of 80 gross tons or more must possess an MSMC issued by the maritime administrator.
St. Vincent and the Grenadines
In this flag’s recent revision of its Safety Code of Practice for Pleasure Yachts Engaged in Trade, it amended its safe manning policy. A Minimum Safe Manning Document (MSMD) was originally required only for commercial yachts above 500 GT. For yachts less than this size, it was the owner’s discretion to determine the number of crew on board.
With the new code released on Oct. 1, the requirement for an MSMD was lowered to all commercial yachts of 24m in length or more.
Malta
The Maltese Administration will issue a Minimum Safe Manning Certificate (MSMC) for commercial yachts of more than 24m in length following receipt and review of the application for a safe manning document.
The application may be supplied with the owner’s proposed manning levels and copies of related certification.When determining the minimum manning levels on board, Malta takes a similar approach to other registries. It will consider the following factors when assigning the minimum manning:
Gross tonnage;
Main propulsion machinery power installed on board;
Length and nature of voyages with passengers on board;
Frequency of port calls;
Nature of areas of operation, including the environmental conditions and time of year;
Size, age, type of yacht, type of rig (in case of sailing yachts), equipment, automation and layout;
Type of construction and type of equipment on board;
STCW requirements; and
Yacht’s operational requirements.
While the above explanations are the current policies of these flags, it is important to note that there is a considerable regulation still pending ratification that will drastically affect minimum safe manning scales. This is the Maritime Labour Code (MLC).
Because existing regulations primarily focus on watch standers, the MLC will now require flag administrations to consider all seafarers on board. This will include the interior staff, their working and rest hours.
It will be interesting to see how the various flag states interpret the new manning requirements and make them applicable to their respective fleets. History shows that as technology advances, physical manpower decreases. Yet somehow, the amount of actual work always seems to increase, only to be shared by even fewer people.
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