Insights

Final results and CiC intensity Index on Crew Wages and Seafarer Employment Agreements (MLC, 2006)(September-November Data)

A joint Concentrated Inspection Campaign (CiC) has been launched during autumn for Crew Wages and Seafarer Employment Agreements (MLC, 2006)compliance under the following regimes:

  • Paris Memorandum of Understanding (Paris MoU)
  • Tokyo Memorandum of Understanding (Tokyo MoU)
  • Black Sea MoU

The Concentrated Inspection Campaign (CiC) aimed to create awareness within the shipping industry about the requirements on crew wages and seafarer employment agreements (MLC, 2006); and to verify that ships comply with these requirements. This Concentrated Inspection Campaign, was  conducted from 1st September 2024 to 30th November 2024, in parallel with regular PSC Inspections, meaning that when a PSCO is boarding a vessel for inspection, apart from the checklist for the regular PSC inspection, follows an additional CiC Checklist, framed by a list of 10 additional questions focusing on CiC subject (Crew Wages, SEA and MLC implementation).

Please see Annex A for the Inspection Checklist
Please See Annex B for the list of CiC related Deficiency Codes, corresponding to each question
Please See Annex C for the methodology used to calculate the CiC Intensity Index

The following outlines the findings related with CiC per MoU under review for the total period of the Campaign.

MoU Ports with PSCI # PSCIs Total # DEF # CiC DEF % CiC DEF % CiC DEF L12M CiC Intensity Index %
Paris MoU 384 2,209 6,113 352 5,8% 2.6% 120%
Tokyo MoU 269 4,370 11,231 627 5,6% 2.2% 159%
Black Sea 18 480 2,005 13 0.6% 0.5% 28%

As an overall result, all participating MoUs had increased percentages on CiC related deficiencies.

 

Ports with Higher CiC Intensity Index

The following are the Top 10 ports with higher CiC intensity Index for Paris MoU (sorted by Higher CiC Intensity Index).

Port Country # PSCIs Total # DEF # CiC DEF % CiC DEF % CiC DEF L12M CiC Intensity Index %
Algeciras Spain 27 32 7 21.9% 3.2% 578%
Venice Italy 18 116 4 3.4% 0.8% 314%
Riga Letonia 31 53 3 5.7% 2.1% 166%
Antwerpen Belgium 79 393 15 3.8% 1.6% 142%
Gent Belgium 26 184 8 4.3% 1.8% 141%
Rotterdam Netherlands 61 156 9 5.8% 2.7% 111%
Vancouver Canada 45 214 7 3.3% 1.6% 107%
Hamburg Germany 44 154 5 3% 1.7% 93%
Constanta Romania 59 312 7 2.2% 2.0% 12%
Burgas Bulgaria 33 163 4 2.5% 2.2% 10%

 

The top 5 CiC related deficiencies marked in Paris MoU during CiC Period as follows:

# Deficiency Code & Description Detainable DEF Non Detainable DEF Total DEFs
1 01220-Seafarers’ employment agreement (SEA) 27 272 299
2 01308-Records of seafarers’ daily hours of work or rest 5 93 98
3 18203-Wages 3 76 74
4 01139-Maritime Labour Certificate 4 50 54
5 18204-Calculation and payment of wages 5 16 21

 

The following are the Top 10 ports with higher CiC intensity Index for Tokyo MoU (sorted by Higher CiC Intensity Index)

Port Country # PSCIs Total # DEF # CiC DEF % CiC DEF % CiC DEF L12M CiC Intensity Index %
Sydney, NSW Ausralia 33 75 4 5.3% 0.7% 647%
Ningbo China 37 142 10 7% 1% 629%
Ho Chi Minh City Vietnam 85 41 9 22% 3.1% 602%
Incheon South Korea 45 103 16 15.5% 2.3% 575%
Vostochny Russia 39 135 9 6.7% 1.3% 428%
Yantai China 38 203 7 3.4% 0.7% 395%
Qingdao China 41 174 4 2.3% 0.5% 384%
Lianyungang China 41 159 6 3.8% 0.9% 325%
Tanjung Perak Indonesia 30 17 4 23.5% 5.7% 313%
Shanghai China 112 344 20 5.8% 1.5% 285%

 

The top 5 CiC related deficiencies marked in Tokyo MoU during CiC Period as follows:

# Deficiency Code & Description Detainable DEF Non Detainable DEF Total DEFs
1 01220-Seafarers’ employment agreement (SEA) 30 345 375
2 18203-Wages 9 114 123
3 01139-Maritime Labour Certificate 1 101 102
4 01331-Collective bargaining agreement 1 41 42
5 18204-Calculation and payment of wages 4 22 26

 

The following are the Top 5 ports with higher CiC intensity Index for Black Sea MoU (sorted by Higher CiC Intensity Index) followed by the other major ports which showed a different approach during CiC.

Port Country # PSCIs Total # DEF # CiC DEF % CiC DEF % CiC DEF L12M CiC Intensity Index %
Trabzon Turkey 13 70 2 2.9% 0.5% 491%
Batumi Georgia 28 81 2 2.5% 0.6% 304%
Chornomorsk Ukraine 18 49 2 4.1% 2% 102%
Kulevi Georgia 12 2 2 100% 0% 100%
Bartin Turkey 6 33 1 3% 0% 100%
Novorossiysk Russia 159 852 0 0% 0.3% -100%
Izmail Turkey 20 53 0 0% 5.7% -100%
Samsun Turkey 32 78 0 0% 0.6% -100%
Bartin Russia 47 254 0 0% 0.1% -100%
Tuapse Ukraine 12 58 0 0% 0.7% -100%

 

The top 5 CiC related deficiencies marked in Black Sea MoU during CiC Period as follows:

# Deficiency Code & Description Detainable DEF Non Detainable DEF Total DEFs
1 01220-Seafarers’ employment agreement (SEA) 1 20 21
2 18203-Wages 2 6 8
3 09235-Fitness for duty – work and rest hours 4 4
4 01307-Minimum hours of rest 4 4
5 01139-Maritime Labour Certificate 1 2 3

 

Terminology used

PSCI: Port State Control Inspections

DEF: Deficiency

CIC: Concentrated Inspection Campaign

L12M: Last 12 Months

 

Annex A: Concentrated Inspection Campaign (CiC) Questionnaire

The list with the CiC questions is as follows:

No Description Yes No Detention
1. Is the Seafarers’ Employment Agreements (SEA) signed by both the seafarer and the shipowner or a representative of the shipowner?
2. Is the seafarer able to access information regarding their employment conditions on board?
3. Are standard forms of SEAs and parts of any applicable collective bargaining agreements, subject to Port State Control (PSC) inspections under Reg. 5.2, available in English?
4. Does the SEA include all the required elements specified in the MLC 2006 Standard?
5. Do particulars included in the seafarers’ employment agreement comply with MLC, 2006 requirements?
6. Are wage or salary payments made to the seafarer at no greater than monthly intervals?
7. Have seafarers been given a status of accounts and wages paid on at least a monthly basis?
8. Are wage or salary payments in accordance with any applicable CBA or SEA?
9. If payments made to a seafarer include deductions, are they in accordance with MLC Convention?
10.
  1. Is a certificate or documentary evidence of financial security, issued by the financial security provider, available on board in the event of compensation for death and long-term disability?
  2. Is a certificate or documentary evidence of financial security, issued by the financial security provider, available on board in the event of the repatriation?

 

All of above items may lead to Detention if the findings are not on the satisfaction of PSCO.

 

Annex B: Concentrated Inspection Campaign (CiC) corresponding Deficiency Codes

Deficiency Codes Related to Inspection Campaign

No Questions and possible findings Related PSC Deficiency Codes
1. Is the seafarer given a SEA signed by both the seafarer and the shipowner or a representative of the shipowner? 01139, 01140, 01220
2. Is the seafarer able to access information regarding their employment conditions on board? 01220, 01306, 1307, 01308, 01331, 01336, 01337, 09234, 09235, 09236, 18201, 18202, 18203, 18204, 18205, 18299
3. Are standard forms of SEAs and parts of any applicable collective bargaining agreements, subject to Port State Control (PSC) inspections under Reg. 5.2, available in English? 01220, 01221, 01308, 01331, 01336, 01337, 09234, 09236, 18101, 18102, 18201, 18204
4. Does the SEA include all the required elements specified in the MLC 2006 Standard? 01220, 01307, 01308, 01331, 01336, 01337, 09234, 09236, 18101, 18102, 18201, 18202, 18204, 18205, 18299
5. Do particulars included in the seafarers’ employment agreement comply with MLC, 2006 requirements? 01220, 01221, 01331, 01336, 01337, 09236, 18202, 18204, 18205, 18299, 18406
6. Are wage or salary payments made to the seafarer at no greater than monthly intervals? 01139, 01140, 01220, 01221, 01331, 18203
7. Have seafarers been given a status of accounts and wages paid on at least a monthly basis? 01331, 18203, 18204, 18205
8. Are wage or salary payments in accordance with any applicable Collective Bargaining Agreement (CBA) or SEA? 01139, 01140, 01220, 01221, 01331, 18203, 18204
9. If payments made to a seafarer include deductions, are they in accordance with MLC Convention? 01139, 01140, 01221, 01331, 18204
10.
  1. Is a certificate or documentary evidence of financial security, issued by the financial security provider, available on board in the event of compensation for death and long-term disability?
  2. Is a certificate or documentary evidence of financial security, issued by the financial security provider, available on board in the event of repatriation?
  1. 01139, 01140, 01220, 01221, 01331, 01337, 18406
  2. 01139, 01140, 01220, 01221, 01331, 01336

 

The listed items if identified as Deficiencies on board, are descripted by a set of Deficiency Codes ( a question may create more than one Deficiency Codes as findings). There are a total of 29 different codes to support the findings for Fire Safety (including drills and supportive equipment).

 

Annex C: Concentrated Inspection Campaign (CiC) Intensity Index Methodology

To assess the CiC Intensity Index a simple methodology has been applied based on the % share of CiC Deficiency Findings before the CiC period (namely, the Last 12 months) and the period where CiC is being applied.

The CiC corresponding Deficiency codes that are listed in Annex B (in relation to the CiC Questions) have been analysed for these periods under review (L12M before the CiC and the CiC Period).

The methodology is very simple to determine the CiC Intensity ion any port in relation with CIC related deficiency codes and findings.

The CiC Intensity Index is calculated as follows:

CIC Intensity Index = { [B – A]/A }%

A = CIC Deficiency Codes Share % (of Total Deficiencies in any given port) for the Last 12 Months (L12M), i.e. the period September 2023 till August 2024.
B = CIC Deficiency Codes Share % (of Total Deficiencies in any given port) for 1st September to 30th November.

Explanation and Meaning
The higher the percentage of CIC Intensity Index, the higher the focus (i.e. intensity) on the CiC related Questions and Corresponding Findings.