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UMS and its impact on safe manning

As onboard automation increases, manning levels are bound to reduce. Regulatory bodies assessing Minimum Safe Manning requirements, may not however always agree with owners’ assessment of safe operations with reduced manning. In The Coral Knight [2022] AMSA refused to allow owners to have two engineers onboard instead of three. Owners approached the Appeals Tribunal in Australia. Not too long ago, on the other side of Pacific, a Canadian Court had decided against interfering with Transport Canada’s assessment of required manning levels. Did the Appeals Tribunal choose the same path or set a new precedent?

Coral Knight provided both emergency towing services and maintenance services. With the UMS system operational, owners wanted to reduce the number of engineering officers required onboard. AMSA however was not okay with the vessel conducting emergency towing ops with only two engineers. Their main concern was increased risk of fatigue due to high workload and long hours when the vessel is providing emergency towage services where an engineer was to be transferred to the stricken vessel. Owners were of the view that UMS vessels will generally have increased availability of adequately rested engineers, and this will assist in their availability to perform emergency towage ops.


The Administrative Appeals Tribunal, while making reference to IMO Resolution A.1047(27) on Principles of Minimum Safe Manning, said that the requirements listed therein cannot possibly be met at all times, as there will always be emergencies in which mandated rest hours will be breached, and there will be situations where safety, security and environment protection will be compromised no matter how many personnel are onboard. Agreeing with the views of the expert appointed by the owners and taking into account their proposal to provide compensatory rest to the crew, the Tribunal decided that operations can be conducted safely with only two engineers onboard. They noted that major maritime events requiring an engineer to be transferred to a stricken vessel are rare in Australian waters.


AMSA was directed to remove the requirement of having a third engineer onboard from the MSD.





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