Crew and people · 6 min read
MLC rest hours: the rules, the common violations and the audit trail
10 hours in any 24, 77 in any 7 days, no more than two periods. Why compliant-looking days still breach, and how to keep a record that survives inspection.
The Maritime Labour Convention, 2006 and the STCW Convention set the same core limits for a seafarer's rest: at least 10 hours in any 24-hour period and 77 hours in any 7-day period. Rest may be split into no more than two periods, one of them at least 6 hours long, and no more than 14 hours may pass between consecutive periods of rest.
The numbers fit on a sticky note. The trouble is that they apply to every rolling window, not the calendar day, and that the record must match everything else the ship writes down. Port State officers, vetting inspectors and client auditors all read rest-hour records, and all of them compare them with the logbooks. This article sets out the rules precisely, the violations we see most often, and how to build an audit trail that stands up.
The rules, precisely
MLC Standard A2.3 gives a flag State two ways to set the limit: minimum hours of rest, or maximum hours of work. Most fleets manage to the rest limits, because STCW binds watchkeepers and those with safety, security and pollution-prevention duties to them in any case.
| Rule | Limit | Where it comes from |
|---|---|---|
| Minimum rest in any 24 hours | 10 hours | MLC Std A2.3; STCW A-VIII/1 |
| Minimum rest in any 7 days | 77 hours | MLC Std A2.3; STCW A-VIII/1 |
| Periods of rest in 24 hours | At most 2, one of at least 6 hours | MLC Std A2.3; STCW A-VIII/1 |
| Interval between rest periods | At most 14 hours | MLC Std A2.3; STCW A-VIII/1 |
| Alternative, if the flag chooses it | Work at most 14 h in 24 and 72 h in 7 days | MLC Std A2.3 |
| STCW weekly exception | Down to 70 h in 7 days, at most 2 weeks in a row | STCW A-VIII/1 |
| STCW daily exception | Up to 3 rest periods, one of 6 h, none under 1 h, on at most 2 days in 7 | STCW A-VIII/1 |
Exceptions are exceptions
STCW lets a flag State permit exceptions, and MLC lets flag States approve collective agreements that do the same. Under STCW the weekly minimum can drop to 70 hours for no more than two consecutive weeks, and the gap between two periods of exception must be at least twice the length of the exception. Daily rest may be split into three periods on no more than two days in any seven, provided one period is at least 6 hours and neither of the others is shorter than 1 hour.
Separately, the Master may suspend the schedule for the immediate safety of the ship, persons on board or cargo, or to help other ships or people in distress. Once the situation is over, seafarers who worked during a rest period must get adequate compensatory rest. Every exception and every suspension must appear in the record as what it is.
Why 12 hours of rest can still be a breach
The first line is a classic 4-on, 8-off watch: two rest blocks of eight hours. It complies comfortably. The second line is the same officer on a port day with an arrival, a drill and cargo work. The total rest is 12 hours, which looks fine, but it comes in short pieces and none of them is six hours long. That breaches the two-period rule and the six-hour rule at once. The third line is the same day re-planned, with the drill moved and the cargo watch split differently: 14 hours of rest in two periods of seven hours. Same work, compliant.
The common violations
We see the same patterns again and again. None of them needs bad intent; all of them need a plan.
- The rolling window. "Any 24 hours" means every 24-hour window, not midnight to midnight. A breach can hide across midnight where each calendar day looks fine.
- Arrival and departure. Pilotage, mooring, cargo, bunkering and inspections cluster in the same hours. Short rest periods pile up on the same officers.
- Drills in rest time. MLC asks that musters and drills be held so they minimise disturbance of rest and do not cause fatigue. Drills at 1500 for the 12-to-4 watch break that.
- Call-outs without compensatory rest. An engineer called to an alarm during rest is owed compensatory rest. If the record does not show it, the next inspector will ask.
- Records that do not match the logs. Port State officers compare rest-hour records with the deck and engine logbooks, the oil record book, the cargo log and the pilot card. A record that shows rest while the log shows the officer on the bridge is worse than an honest breach.
- The Master's own hours. The Master is a seafarer too, and the hours around arrival and departure are often the Master's longest.
- Retyped records. Records filled in neatly at the end of the month, all in the same hand, all compliant, read as what they are.
Where it shows up in inspections
Rest hours sit in several regimes at once. Port State control checks them under MLC and STCW. In SIRE 2.0, fatigue and workload is one of the nine performance influencing factors an inspector can tag. The OVID questionnaire asks whether hours-of-rest records are completed in line with the rules. The Paris MoU's 2024 figures put MLC Title IV at 10.4% of all deficiencies, and the Tokyo MOU recorded 8,193 deficiencies on working and living conditions in 2024. Neither figure is about rest hours alone, but both show how closely inspectors now read the labour side of a ship.
The audit trail that stands up
The rules on records are short. Each seafarer's daily hours of rest are recorded in a standardised format, following the IMO/ILO guidelines on tables of shipboard working arrangements and formats of records, or an equivalent. The seafarer gets a copy of their own record, endorsed by the Master or a person the Master authorises, and signed by the seafarer. A table of shipboard working arrangements, in the working language and in English, is posted where it can be seen.
| Element | Good practice | Red flag for an inspector |
|---|---|---|
| Timing | Entered daily, by the seafarer or from the watch system | Filled in at month end |
| Source | Linked to the logbook, alarm log and cargo log | Standalone sheet with no link to events |
| Breaches | Recorded honestly, with the reason and the fix | None ever, on a busy trade |
| Exceptions | Marked as exceptions, with compensatory rest shown | Exceptions not distinguished from normal hours |
| Signatures | Seafarer signs; Master or delegate endorses; copy given | Signed by one person for everyone |
| Review | Office reviews trends by rank and ship monthly | Nobody ashore reads them |
Predict, do not just record
Most rest-hour systems record what happened. The better practice is to look ahead. When a port call, a drill and a watch pattern meet, the breach is visible a day in advance. Changing the watch then costs far less than explaining a breach afterwards. A good plan spreads arrival work so the officer on the bridge for the pilot is not also on deck for cargo two hours later.
What to do Monday
- Check every ship's rest records for the last 30 days using rolling 24-hour and 7-day windows, not calendar days.
- Compare a sample of three port days per ship with the deck and engine logbooks.
- Move routine drills out of rest periods for the watches they affect; publish the drill plan against the watch plan.
- Confirm each ship's table of shipboard working arrangements is current and posted in the working language and English.
- Record every call-out during rest with the compensatory rest given.
- Look at the next port call for each ship and flag the officers most likely to breach; re-plan now.
- Make sure every seafarer has a signed, endorsed copy of their own record.
Questions and answers
How many hours of rest must a seafarer have?
At least 10 hours in any 24-hour period and 77 hours in any 7-day period, under MLC Standard A2.3 and STCW Code section A-VIII/1.
Can rest be split?
Into no more than two periods, one of which must be at least 6 hours, with no more than 14 hours between consecutive rest periods. STCW exceptions allow three periods on at most two days in seven.
What exceptions are allowed under STCW?
A flag State may allow the weekly minimum to fall to 70 hours for no more than two consecutive weeks, with a gap of at least twice the exception's length before the next one.
Do drills count as work?
Yes. Drills should be planned to minimise disturbance of rest, and a seafarer called out during rest is owed adequate compensatory rest.
Who signs the rest-hour record?
The seafarer signs their own record and receives a copy; the Master, or a person the Master authorises, endorses it.
What do Port State officers check?
That records exist in the standard format, are signed and endorsed, match the logbooks and other records, show any exceptions honestly, and that the table of working arrangements is posted. *This article explains; it is not legal advice. Check your flag State's rules and any applicable collective agreement.*
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