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Direct Request (CEACR) - adopted 2024, published 113rd ILC session (2025)

Seafarers' Identity Documents Convention (Revised), 2003, as amended (No. 185) - Pakistan (Ratification: 2006)

Other comments on C185

Direct Request
  1. 2024
  2. 2019
  3. 2012

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Article 1 of the Convention. Definition of seafarers. In reply to its previous comments regarding the exclusion of the master and apprentices from the definition of seafarer, the Committee notes that the Government reiterates its indication that the Merchant Shipping Ordinance 2001 (MSO) is being amended to align it with the Convention. Welcoming the ratification by Pakistan of the Maritime Labour Convention, 2006, as amended (MLC, 2006) which contains the same definition of seafarer provided for in Convention No. 185, the Committee requests the Government to adopt the necessary measures to fully comply with Article 1 of the Convention.
Article 2. Issuance of seafarers’ identity documents (SIDs). In reply to its previous comments, the Committee notes the Government’s indication that seafarers have the right to an administrative appeal if their application for a SID is rejected, without referring to the relevant laws or regulations. The Committee accordingly requests the Government to indicate the measures taken to comply with Article 2(5).
Article 3. Content and form of SIDs. In reply to its previous comments, the Committee notes the Government’s indication that Pakistan has aligned the format of its SIDs with the Convention for machine-readable SIDs, i.e. the updated SID is now issued by the National Electronics Database and Registration Authority (NADRA). Noting however that the Government has not provided concrete information regarding alignment with the 2016 amendments to the Convention, the Committee requests it to specify the particulars contained in the new SID and to provide a specimen to the Office as soon as possible.
Articles 4 and 5. National electronic database. In reply to its previous comments, the Committee notes the Government’s indication that NADRA maintains a comprehensive database of all Pakistani seafarers as it is responsible for issuing machine-readable SIDs. It further notes that, while NADRA holds the primary data, Government Shipping Offices (GSOs) maintain supporting backend information accessible through the GSO portal. The Government is currently developing an online GSO portal integrated with the Pakistan Single Window Platform to enhance efficiency and accessibility of seafarer data. While noting this information, the Committee requests the Government to provide detailed elements regarding compliance with Annex II of the Convention and to indicate the measures taken or envisaged to comply with the requirements on quality control and evaluation provided for under Article 5.
Article 6. Facilitation of shore leave and transit and transfer of seafarers. In reply to its previous comment, the Committee notes the Government’s indication that seafarers’ transfers between vessels are a standard operational procedure initiated by shipowners as needed and facilitated by immigration or Federal Investigation Agency (FIA) authorities at ports. Similarly, shore leave for seafarers is granted by immigration or FIA between the hours of 7 a.m. and 7 p.m. subject to verification of permission from the vessel’s master, regardless of visa status. While noting this information, the Committee requests the Government to indicate the relevant national law or regulations which give effect to Article 6.
Article 7. Continuous possession and withdrawal. In reply to its previous comments, the Committee notes the Government’s reference to rules applicable to the seafarer’s service book (SSB) without indicating the provisions adopted to ensure that the SID remains in the seafarer’s possession at all times, as required by Article 7, paragraph 1. The Committee therefore requests the Government to specify the measures taken to implement this provision of the Convention.
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