Isle of Man issues notice on MLC amendments for connectivity and internet access

Eda Zenic -

The Isle of Man Ship Registry has issued Technical Advisory Notice 007-24 regarding amendments to the Maritime Labour Convention (MLC) that will take effect on December 23, 2024.

These amendments focus on two key requirements for ships: social connectivity and internet access for seafarers. Below is a detailed summary of the notice and the necessary actions for compliance.

1. Introduction to the MLC Amendments

The Maritime Labour Convention, which sets minimum standards for the welfare of seafarers, has undergone amendments that will be enforced from December 23, 2024. The most notable updates for shipowners include:

  • Social Connectivity (as per Standard A3.1)
  • Internet Access (as per Guideline B3.1.11)

The MLC amendments require that shipowners ensure seafarers have access to internet services for communication and social interaction, as these are deemed essential for the well-being of the crew, especially during long voyages.

2. Action Required by December 20, 2024

The Isle of Man Ship Registry requests all MLC-compliant shipowners to submit a revised DMLC Part II (Declaration of Maritime Labour Compliance) by December 20, 2024. This updated document must outline how the shipowner plans to meet the new MLC amendments, particularly those related to social connectivity and internet access.

  • Submission Process: Shipowners must submit the amended DMLC Part II to the Ship Registry at marine.mlc@gov.im by the deadline. Along with the submission, shipowners should list all vessels affected by the updated DMLC.
  • Required Content: The DMLC Part II should explicitly address how the shipowner plans to fulfill the requirements of social connectivity and internet access. This includes explaining how these services will be provided to seafarers as "reasonably practicable" per the Ship Registry’s guidelines. The primary focus should be on how ships will ensure communication options for crew members, including internet access.
    • The revised Section 9 of the DMLC Part II must be updated with this information. The amendment should be concise, but clear.
  • Approval Process: Once the amended DMLC Part II is submitted, the Ship Registry will review it. If approved, the Ship Registry will send a confirmation email, which must be kept onboard along with a draft of the amended DMLC Part II. This ensures that all vessels are in compliance with the new regulations.
  • Transition Period: To ease the administrative burden, ships already on the register as of December 23, 2024 can continue using their current DMLC Part I & II until their next MLC renewal survey. Shipowners can request an updated DMLC Part I & II during this survey. However, all ships must comply with the MLC amendments from the effective date, regardless of the DMLC renewal status.
    • Ships joining the register after December 23, 2024 must submit updated DMLC Parts I & II before registration.

3. Key Amendments to MLC

The amendments focus primarily on ensuring that seafarers have the opportunity to maintain social connections, both with their onboard colleagues and the outside world. The key amendments include:

Social Connectivity (Standard A3.1)

The MLC has introduced a new mandatory requirement for social connectivity. Shipowners must facilitate connections between crew members and the wider world, supporting their mental health and social well-being.

  • Onboard Social Interaction: Research has shown that strong social interaction among the crew is vital for mental health and safety culture. The Ship Registry expects shipowners to foster such interactions through social programs, activities, and engagement.
  • Recommendations for Implementation: The Ship Registry offers several recommendations for promoting onboard social interaction, such as appointing a voluntary social ambassador or establishing a social committee on each vessel. These groups can plan activities (e.g., parties, sports events, birthdays) and create a supportive environment for crew members.
    • Some examples of activities include table tennis, gaming, and celebrating religious or cultural occasions. The nature of these activities can vary depending on the crew's preferences and the vessel's operations.
  • Off-Vessel Social Connectivity: Beyond onboard interactions, shipowners are encouraged to continue providing traditional communication methods like telephone and postal services. These methods still play a significant role in maintaining connections for many seafarers.

Internet Access (Guideline B3.1.11)

The MLC amendment also mandates that shipowners provide internet access to seafarers, allowing them to maintain communication with family and friends while at sea.

  • Required Standards for Internet Access:
    • The internet connection must be of sufficient quality and speed to allow basic communication services such as web-based messaging, emails, social media, and internet banking.
    • There is no obligation to provide high-data applications like streaming, although the internet service should be reliable for essential communication.
  • Costs of Internet Access: Ideally, the internet should be free for seafarers, though a reasonable charge is permitted. The Ship Registry strongly encourages providing this service at no cost, as studies indicate that social connectivity is a critical factor for seafarers’ well-being, retention, and recruitment.
  • Maintenance and Inspections: Internet access should be inspected during the accommodation surveys conducted at least once every 7 days. If technical issues arise and internet access is temporarily unavailable, it is considered acceptable, provided the issue is resolved promptly.
  • Evolution of Technology: As internet technology improves, shipowners are expected to upgrade their facilities to meet growing demands for better connectivity and access. The ultimate goal is to provide social connectivity and internet access comparable to what shore-based workers have.

4. Compliance and Enforcement

Shipowners must ensure their vessels comply with these changes by December 23, 2024. Failure to comply could result in challenges during Port State Control inspections. Therefore, it is essential to update the DMLC and ensure that social connectivity and internet access are effectively implemented across the fleet.

Further Guidance

Shipowners are encouraged to consult the full policy document for detailed guidance and make any necessary amendments to their DMLC Part II to align with the updated MLC regulations.