UK updates requirements for ship's doctors

The UK Maritime and Coastguard Agency published MSN 1841 (M) Amendment 2 on September 24, 2024, to clarify requirements for medical practitioners, or "ship's doctors," aboard UK ships under the Maritime Labour Convention 2006.

The amendments update the criteria for ship's doctors and provide guidelines for their qualifications, particularly for international voyages involving large passenger counts.

1. Introduction/Background:

• The Merchant Shipping (Maritime Labour Convention) (Minimum Requirements for Seafarers etc.) Regulations 2014 implement the provisions of the MLC 2006 for the UK.
• Specifically, Part 9 of these regulations addresses medical care on board ships, including the requirement to have a ship's doctor for certain voyages.
• The regulation applies to all UK sea-going ships except:
  • Pleasure vessels
  • Fishing vessels
  • Ships of traditional build
  • Warships or naval auxiliaries
  • Ships not engaged in commercial activities

2. Requirement to Carry a Medical Practitioner on a Ship:

• Regulation 44(1) specifies that a UK ship carrying 100 or more persons on an international voyage of 72 hours or longer must have a qualified medical practitioner (ship’s doctor) on board.
• The rule applies strictly with no exemptions, meaning that all applicable ships must comply.

3. Qualifying Criteria for a Ship’s Doctor on a UK Ship:

• To work as a ship’s doctor on a UK ship, medical practitioners must meet specific qualifications:
  • UK Residents: They must be fully registered with the General Medical Council (GMC) and hold a license to practice medicine.
  • Non-UK Residents: If the doctor is not registered with the GMC, they must:
    • Be fully qualified and registered as a medical practitioner in their country of residence.
    • Be listed as a graduate from one of the schools in the World Directory of Medical Schools.
    • Demonstrate proficiency in English.
    • Participate in a structured program for Continuous Professional Development (CPD) and ongoing medical skills maintenance.

Ongoing Professional Education:

• Ship’s doctors must maintain their medical skills through recognized routes:
  • Doctors should participate in a recognized framework for medical appraisal and re-licensing by their statutory medical registration body (if available).
  • If no such statutory framework exists, doctors must engage in:
    • An audited CPD program, recognized by a relevant medical authority.
    • A company-endorsed system for professional auditing, which includes external peer assessments of clinical practices.

Additional Points:

• The amendment updates and clarifies the references and regulatory framework for ship's doctors, ensuring consistency with the UK’s interpretation of the MLC 2006.
• The list of medical schools required for non-UK doctors can be found on the World Directory of Medical Schools website.
• Shipowners are responsible for ensuring that any doctor employed on their ships meets these qualifications and continues to maintain the necessary professional standards.

All regulations can be found at legislation.gov.uk

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