COSWP · Publications · Salvage · MLC

The on-board complaint procedure — posted, with named steps: typically HOD, then master, with timescales, and the seafarer's right to be accompanied and protected from victimisation. Beyond the ship: the DPA route for safety-flavoured issues, the flag state, and in port the Port State Control officer or the ITF — and MLC requires the contact details to be available to them. My part as OOW is procedural honesty: take it seriously, record it, escalate it within the steps, and never sit on it — an unresolved complaint that surfaces at a PSC inspection as 'the ship ignored me' is a finding against the vessel, where the same complaint handled through the procedure is evidence the system works.

A Merchant Shipping Notice (MSN) has the force of law — it sets out mandatory requirements under Merchant Shipping legislation and non-compliance is an offence. A Marine Guidance Note (MGN) is guidance and best practice — not legally mandatory but the MCA expects compliance and PSC inspectors use it as a benchmark. A Marine Information Note (MIN) is a short-term informational notice with no legal force — it is published for a limited period and then withdrawn. All three are published on the MCA website.

No cure no pay is the traditional basis of salvage law — a salvor is only entitled to a reward if the salvage operation is successful and the property is saved. If the vessel or cargo is not saved, no reward is payable regardless of the effort expended. The 1989 Salvage Convention modified this for environmental cases — a salvor who prevents or minimises environmental damage may receive special compensation even if the vessel is not saved. The standard salvage contract is Lloyd's Open Form, which uses no cure no pay as its basis with the environmental compensation provisions of the 1989 Convention.

A Permit to Work is a formal documented control measure under COSWP — a written record confirming that all necessary safety precautions are in place before a high-risk operation begins. It is required for enclosed space entry, working aloft, hot work (welding, cutting), work over the side, and other high-risk tasks as defined in the vessel's SMS. The permit identifies the hazards, the persons involved, the control measures, and the responsible officer. Work must not begin until the permit is signed off. The permit is cancelled when the work is complete and the area is confirmed safe.

Under MLC 2006, the maximum hours of work are 14 hours in any 24-hour period and 72 hours in any 7-day period. The alternative regime is minimum rest: 10 hours in any 24-hour period and 77 hours in any 7-day period — the formulation that matches STCW Chapter VIII. MLC lets the flag state apply either the maximum-work or the minimum-rest regime (they are alternatives, not arithmetic equivalents); UK and REG practice follows the minimum-rest figures. Rest periods may be divided into no more than two periods, one of which must be at least 6 hours. Hours of work and rest records must be maintained and available for inspection by PSC.