Maritime Labour Convention, 2006 (MLC, 2006) - Lebanon (Ratification: 2018)

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

The Committee notes the Government’s first report on the application of the Maritime Labour Convention, 2006, as amended (MLC, 2006). The Committee notes that the amendments to the Code of the Convention approved by the International Labour Conference in 2018 entered into force for Lebanon on 26 December 2020. It also notes that a declaration of acceptance of the 2016 amendments to the Code has not been received and therefore Lebanon is not bound by these amendments. The Committee finally notes that the amendments to the Code of the Convention approved by the International Labour Conference in 2022 will enter into force for Lebanon on 23 December 2024. The Committee notes the efforts undertaken by the Government and the social partners to implement the Convention. Following a first review of the information and documents available, the Committee draws the Government’s attention to the following issues. If considered necessary, the Committee may come back to other matters at a later stage.

Article I. General questions on application. Implementing measures. The Committee notes that the provisions of the Convention are mainly implemented by Lebanese Law No. 235 of 22/10/2012 on the National Requirements and Implementation Procedures to implement the MLC, 2006 (Hereinafter: “MLC, 2006 Law No. 235”). The Committee notes that only a few laws and regulations applying the Convention have been adopted since its ratification. The Committee therefore requests the Government to adopt the necessary measures to give effect to the Convention.

Article III. Fundamental rights and principles. The Committee notes that the Government has ratified all the fundamental Conventions except the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87). In accordance with its approach followed when a country has not ratified some or all of the ILO fundamental Conventions and thereby is not subject to supervision in respect of these fundamental Conventions, the Committee seeks concrete information on how the country has satisfied itself that its laws and regulations respect, in the context of the MLC, 2006, the fundamental rights referred to in Article III. The Committee therefore requests the Government to provide information on how it has satisfied itself that its laws and regulations, in the context of the MLC, 2006, respect the fundamental rights referred to in Article III, more specifically in relation to the principles contained in the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87).

Article II, paragraph 1(f) and 2. Definitions and scope of application. Seafarers. The Committee notes the Government’s indication that, according to section 128 of the Merchant shipping Law of 18 February 1947 (hereinafter: “MSL 1947”), “seafarer” means any person employed on board a ship to undertake a sea voyage. The Committee notes the Government’s indication that all individuals working on board a Lebanese ship, including ordinary crew members, officers, the master, and the chief engineer, are considered as seafarers. The Committee recalls that under Article II, paragraph 1(f), seafarer means any person who is employed or engaged or works in any capacity on board a ship to which the Convention applies. This encompasses not only crew members stricto sensu, but also other persons working in any capacity on board ships, such as personnel of cruise ships (for example, catering and hotel staff). The Committee requests the Government to indicate the measures adopted or envisaged to ensure that the protection afforded by the Convention is guaranteed to all seafarers, as defined in Article II, paragraph 1(f). Noting that there was no specific information provided regarding cadets, the Committee also requests the Government to indicate whether cadets are regarded as seafarers under its national legislation and therefore fully enjoy the protection afforded by the Convention.

Article II, paragraphs 1(i), and 4. Definitions and scope of application. Ships. The Committee notes that section 1 of the MSL 1947 defines the term “ship” as any vessel that is fit for navigation, regardless of its cargo or designation, whether the navigation is for profit or not. The Committee however observes that this definition, in a text dating from 1947, does not seem to reflect the definition provided by the Convention to determine its scope of application. The Committee recalls that the MLC, 2006, defines a ship in Article II, paragraph 1(i), as “a ship other than one which navigates exclusively in inland waters or waters within, or closely adjacent to, sheltered waters or areas where port regulations apply”, and that this Convention applies to all ships, whether publicly or privately owned, ordinarily engaged in commercial activities, other than ships engaged in fishing or in similar pursuits and ships of traditional build such as dhows and junks (Article II, paragraph 4). The Committee accordingly requests the Government to provide detailed information on how it ensures that all ships within the meaning of the Convention are covered by its relevant legislation and, if necessary, to review the scope of application of section 1 of the MSL 1947 and of any other relevant provisions in order to ensure full implementation of the provisions of the Convention.

Article II, paragraphs 6 and 7. Definitions and scope of application. Ships under 200 gross tonnage. The Committee notes the Government’s indication that the Directorate General for Land and Maritime Transport (DGLMT) may apply some flexibility in applying particular requirements based on the gross tonnage of ships and voyages. The Committee recalls that Article II, paragraph 6 provides flexibility with respect to the application of “certain details of the Code” to a ship or particular categories of ships of less than 200 GT that do not voyage internationally. This flexibility can only be applied by the competent authority in consultation with the shipowners’ and seafarers’ organizations concerned for cases where it determines that it would not be reasonable or practicable to apply certain details of the Code at the present time and that the subject matter is dealt with differently by national legislation or collective agreements or other measures. The Committee underlines that Article II, paragraph 6 does not provide for the exclusion of a ship, or a category of ships, from the protection offered by the Convention. The Committee therefore requests the Government to provide detailed information on any flexibility granted concerning the application of the Convention to a ship or certain categories of ships, and to indicate how it ensures that the conditions provided under Article II, paragraph 6, are met.

Regulation 1.1 and Standard A1.1, paragraphs 2 and 3. Minimum age. Night work. The Committee notes that section 1(1) of MLC, 2006 Law, No. 235 provides that the employment, night work, engagement or work of seafarers under the age of 18 is prohibited where the work is likely to jeopardize their health or safety. The Committee recalls that night work of seafarers under the age of 18 shall in principle be prohibited (Standard A1.1, paragraph 2), subject to certain limited exceptions (Standard A1.1, paragraph 3). The Committee requests the Government to indicate the measures adopted to give effect to Standard A1.1, paragraphs 2 and 3.

Regulation 1.1. Standard A1.1, paragraph 4. Minimum age. Hazardous work. The Committee notes that, regarding seafarers under the age of 18, a relevant list of prohibited types of works have been provided by the Government, without indication on the applicable national provisions. The Committee requests the Governmentto specify the applicable national provisions in relation to the list of hazardous work and to precise whether consultations have been made with the shipowners’ and seafarers’ organizations concerned, as required under Standard A1.1, paragraph 4.

Regulation 1.2 and Standard A1.2, paragraph 5. Medical certificate. Right to have a further examination. Recalling that seafarers who have been refused a certificate or have had a limitation imposed on their ability to work shall be given the opportunity to have a further examination by another independent medical practitioner or by an independent medical referee, as required under Standard A1.2, paragraph 5, the Committee notes that this further examination is not provided for under section 1(2) of the MLC, 2006 Law No. 235, or under the Ministerial Decree No. 7802 dated 20 April 2002 to which the Government refers. The Committee requests the Government to indicate the measures adopted or envisaged to give effect to Standard A1.2, paragraph 5.

Regulation 1.4, paragraph 3, and Standard A1.4, paragraphs 8 and 9. Recruitment and placement. Advice to seafarers. Services based in countries in which the Convention does not apply. The Committee notes the Government’s indication that there are two private companies for seafarer recruitment and placement services operating in Lebanon. They are certified and licenced by the Directorate General of Land and Maritime Transport according to the Decision No. 36/2022. Noting that the Government has not provided information regarding the advice to provide to its nationals on the possible problems of signing on a ship that flies the flag of a State which has not ratified the Convention and regarding the responsibilities of shipowners who are using recruitment and placement services that operate in countries that have not ratified the Convention, the Committee requests the Government to indicate the measures adopted or envisaged to give effect to Standard A1.4, paragraphs 8 and 9.

Regulation 2.1 and Standard A2.1.Seafarers’ employment agreements. The Committee notes that sections 2(1) to 2(6) of the MLC, 2006 Law No. 235 are giving effect to the requirements of the Convention regarding the seafarers’ employment agreements, with the exception of its provisions relating to: (i) the clear information as to the conditions of their employment that can be easily obtained on board by seafarers, including the ship’s master (Standard A2.1, paragraph 2); (ii) the minimum notice periods (Standard A2.1, paragraphs 5 and 6). The Committeerequests the Government to indicate the measures adopted or envisaged to give effect to these requirements of the Convention.

Regulations 2.1 and 2.2 and Standards A2.1, paragraph 7 and A2.2, paragraph 7. Seafarers’ employment agreements and wages. Captivity as a result of acts of piracy or armed robbery against ships. In relation to the 2018 amendments to the Code, the Committee draws the Government’s attention to the following questions included in the revised report form for the Convention: (a) do laws or regulations provide that a seafarer’s employment agreement shall continue to have effect while the seafarer is held captive on or off the ship as a result of acts of piracy or armed robbery against ships?; (b) how are the terms piracy and armed robbery against ships defined under national legislation? (Standard A2.1, paragraph 7); and (c) do laws or regulations provide that wages and other entitlements under the seafarers’ employment agreement, relevant collective bargaining agreement or applicable national laws, including the remittance of any allotments, shall continue to be paid during the entire period of captivity and until the seafarer is released and duly repatriated or, where the seafarer dies while in captivity, until the date of death in accordance with national legislation? (Standard A2.2, paragraph 7).The Committee requests the Government to reply to the above-mentioned questions, indicating in each case the applicable national provisions.

Regulation 2.2 and Standard A2.2, paragraph 1. Wages. Regular payment. The Committee notes that section 2(7) of the MLC, 2006 Law No. 235 provides that all seafarers must be paid at regularly intervals and in full for their work in accordance with their employment agreements. The Committee recalls however that payments due to seafarers are made at no greater than monthly intervals and in accordance with any applicable collective agreement (Standard A2.2, paragraph 1). The Committee requests the Government to indicate the measures adopted or envisaged to give full effect to the Convention in this respect.

Regulation 2.3 and the Code. Hours of work and hours of rest. The Committee notes that section 3(3) of the MLC, 2006 Law No. 235 provides that both minimum hours of rest and maximum hours of work regimes are applied. The Committee recalls that Regulation 2.3, paragraph 2 and Standard A2.3, paragraph 2 require each country to fix either a maximum number of hours of work which shall not be exceeded in a given period of time, or a minimum number of hours of rest which shall be provided in a given period of time. It is up to the country to decide which of the two arrangements to choose. However, Standard A2.3, paragraph 2 should not be understood as giving shipowners or masters an option to choose between one or the other systems. The Committee therefore observes that section 3(3) of the MLC, 2006 Law No. 235 is not in conformity with Standard A2.3, paragraph 2. The Committee requests the Government to indicate the measures adopted or envisaged to give full effect to Standard A2.3, paragraph 2.

Regulation 2.3 and Standard A2.3, paragraphs 7 to 9. Hours of work and hours of rest. Drills and on-call work. Noting the Government’s indication that there are no collective agreements containing provisions on compensatory rest to be granted in case of call-outs to work or minimizing disturbance of rest periods during drills, the Committee recalls that in the absence of collective agreement or arbitration award, or if the competent authority considers the protection granted inadequate, it shall determine itself such provisions to ensure that seafarers have adequate compensatory rest period if the normal period of rest is disturbed by call-outs to work. The Committee therefore requests the Government to indicate the measures adopted or envisaged to give full effect to Standard A2.3, paragraphs 7 to 9.

Regulation 2.3 and Standard A2.3, paragraph 12. Hours of work and hours of rest. Records. The Committee notes the Government’s indication that section 3(2) of the MLC, 2006 Law No. 235 provides that the master or a person authorized by the master, must maintain records of seafarers’ daily overtime hours of work signed by the seafarers at regular intervals not exceeding the month. The Committee observes that this section concerns only overtime hours of work while Standard A2.3 paragraph 12 of the Convention requires also the record of seafarers’ daily hours of work. The Committee further notes the Government’s indication that according to section 3(5) of the same Law, a table with the shipboard working arrangements must be posted in an accessible place on-board the ship. The table must contain for every position at least: (a) the schedule of service at sea and service in port; and (b) the maximum hours of work and minimum hours of rest. The Committee observes that this provision deals with the schedule of service at sea but not the real working time made by the seafarer, as provided for under Standard A2.3 paragraph 12. The Committee requests the Government to indicate the measures adopted to give full effect to Standard A2.3, paragraph 12.

Regulation 2.4 and Standard A2.4, paragraph 3. Entitlement to leave. Prohibition of agreements to forgo annual leave. Exceptions. The Committee notes that the Government has not provided information on this issue. The Committee recalls that Standard A2.4, paragraph 3, prohibits any agreement to forgo the minimum annual leave with pay, except in cases provided for by the competent authority. Recalling the fundamental importance of paid annual leave to protect the health and well-being of seafarers and to prevent fatigue, the Committee requests the Government to indicate the measures adopted or envisaged to give effect to Standard A2.4, paragraph 3.

Regulation 2.5 and Standard A2.5.2. Repatriation. Financial security. The Committee notes that section 14 of MLC, 2006 Law No. 235 is entitled “MLC, 2014’s amendments to the Code implementing regulation 2.5”, and that this section provides that Lebanese ships shall provide a financial security to ensure that seafarers are duly repatriated in accordance with the 2014 amendments to the Code of the Convention. However, the circumstances covered by this financial security are not related to the abandonment of seafarers. The Committee recalls that, pursuant to Standard A2.5.2, the Government shall ensure the provision of an expeditious and effective financial security system to assist seafarers in case of their abandonment. Noting that the Government has provided a copy of a model certificate of financial security containing the information required in Appendix A2-I of the Convention (Standard A2.5.2, paragraph 7), the Committee requests the Government to indicate the measures adopted or envisaged to give full effect to Standard A2.5.2.

Regulation 2.7 and Standard A2.7, paragraph 3. Manning Levels. Food and catering. The Committee notes the Government’s reference to section 7 of MLC, 2006 Law No. 235 according to which Lebanese ships must have a sufficient number of seafarers employed on board to ensure that ships are operated safely, efficiently and with due regard to security under all conditions, in accordance with the principles of international conventions and in particular the IMO requirements, taking account concerns about seafarers’ fatigue. However, the Committee observes that the Government does not indicate how the competent authority, when determining manning levels, takes into account all the requirements of Regulation 3.2 and Standard A3.2 concerning food and catering. The Committee therefore requests the Government to indicate the measures adopted or envisaged to give effect to Standard A2.7, paragraph 3.

Regulation 2.8 and the Code. Career and skill development and employment opportunities. The Committee notes the Government’s reference to section 8 of MLC, 2006 Law No. 235 according to which the Lebanese Maritime Administration will adopt national policies aimed at strengthening the competencies, qualifications and employment opportunities of Lebanese seafarers and to encourage career and skill development. Clear objectives will be established for vocational guidance, education and training and to promote employment in the maritime sector. The Committee requests the Government to provide information on any developments in this regard.

Regulation 3.1 and Standard A3.1. Accommodation and recreational facilities. The Committee notes the Government’s reference to section 9(1) of MLC, 2006 Law No. 235 according to which shipowners must provide and maintain decent accommodations and recreational facilities for seafarers working or living on board, or both, consistent with promoting the seafarers’ health and well-being. The Committee also notes that section 9(2-7) of MLC, 2006 Law No. 235 gives only partial effect to some requirements under Standard A3.1. The Committee requests the Government to provide further information on how full effect is given to the following requirements: (i) accommodation (Standard A3.1, paragraph 6(a)–(f)); (ii) the availability of individual sleeping rooms for each seafarer (Standard A3.1, paragraph 9(a)); (iii) the minimum floor area in single berth seafarers’ sleeping rooms (Standard A3.1, paragraph 9(f)); (iv) the minimum floor area on passenger ships and special purpose ships (Standard A3.1, paragraph 9(i)); (v) the minimum floor area on ships other than passenger ships and special purpose ships (Standard A3.1, paragraph 9(k)); (vi) the minimum floor area for seafarers performing the duties of ship’s officers on passenger ships and special purpose ships (Standard A3.1, paragraph 9(l)); (vii) adjoining sitting rooms (Standard A3.1, paragraph 9(m)); and (viii) the fact that the clothes locker should be a minimum of 475 litres (Standard A3.1, paragraph 9(n)). As regards the implementation of Standard A3.1, paragraphs 10 to 13, 18 and 19, the Committee observes that the Government has not provided information on the applicable national provisions. The Committee accordingly requests the Government to provide detailed information on the measures adopted or envisaged to implement these requirements of the Convention.

Regulation 3.2 and Standard A3.2. Food and catering. The Committee notes that the Declaration of Maritime Labour Compliance Part II (DMLC, Part II), provided by the Government, contains relevant information on the following issues: (i) training and minimum age of ship’s cooks (Standard A3.2, paragraphs 3 and 8); (ii) exception to the requirement to have a ship cook on board (Standard A3.2, paragraph 5); (iii) non-fully qualified cook (Standard A3.2, paragraph 6); and (iv) frequent documented inspections (Standard A3.2, paragraph 7). However, the Committee notes that the Government has not indicated the applicable national provisions that are implementing Regulation 3.2 and the Code. The Committee requests the Government to indicate the measures adopted or envisaged to give full effect to these requirements of the Convention.

Regulation 4.1 and Standard A4.1, paragraph 1(b). Medical care on board and ashore. Protection comparable to workers ashore. The Committee notes the Government’s reference to section 10 of MLC, 2006 Law No. 235, which contains specific provisions with respect to medical care on board ship and ashore. However, the Committee notes that the Government has not provided any indication on the measures guaranteeing that seafarers are given health protection and medical care as comparable as possible to that which is generally available to workers ashore, including prompt access to the necessary medicines, medical equipment and facilities for diagnosis and treatment and to medical information and expertise (Standard A4.1, paragraph 1(b)). The Committee requests the Government to indicate the measures taken or envisaged ensuring that seafarers are given health protection and medical care as comparable as possible to that which is generally available to workers ashore, as required under Standard A4.1, paragraph 1(b).The Committee also requests the Government to provide information on the preventive measures adopted for seafarers working on board Lebanon ships (Standard A4.1, paragraph 1 (e)).

Regulation 4.1 and Standard A4.1, paragraph 4(d). Medical care on board and ashore. Medical advice by radio or satellite. The Committee notes that section 10(2) of the MLC, 2006 Law No. 235 is giving effect to Standard A4.1, paragraph 4 with provisions of a general nature requiring shipowners to adopt relevant measures on these issues. The Committee notes that this section provides that medical advice by radio or satellite communication should be provided, and that the Government refers in its report to the measures indicated in the example of DMLC, Part II. However, the Committee recalls that Standard A4.1, paragraph 4 provides that national laws and regulations shall be adopted to give effect to its requirements and that paragraph 4(d) of this Standard provides that the competent authority shall ensure by a prearranged system that medical advice by radio or satellite communication to ships at sea, including specialist advice, is available 24 hours a day; medical advice, including the onward transmission of medical messages by radio or satellite communication between a ship and those ashore giving the advice, shall be available free of charge to all ships irrespective of the flag that they fly. The Committee requests the Government to provide further information on the laws and regulations adopted to give full effect to Standard A4.1, paragraph 4, and on how paragraph 4(d) of the same Standard is implemented in practice.

Regulation 4.2 and Standard A4.2.1. Shipowners’ liability. The Committee notes that section 10(4) of MLC, 2006 Law No. 235 gives effect to Standard A4.2.1, paragraph 1 concerning the right to material assistance and support from the shipowner with respect to the financial consequences of sickness, injury or death occurring while the seafarer is employed under a seafarer employment agreement. However, the Committee notes that section 10(4) of MLC, 2006 Law No. 235 is of a general nature and does not give effect to the detailed requirements under Standard A4.2.1, paragraphs 2 to 7, concerning, for example, the shipowner’s obligation to pay full wages as long as the sick or injured seafarers remain on board or until the seafarers have been repatriated and to pay wages in whole or in part from the time when the seafarers are repatriated or landed until their recovery or, if earlier, until they are entitled to cash benefits under the legislation of the Member concerned (Standard A4.2.1, paragraph 5). The Committee also notes that the Government’s reference to section 16(2) and (3) of the example of DMLC Part II, which limits a shipowner’s liability for covering medical and other expenses arising from a seafarer’s injury or illness, as well as wage payments after the seafarer is no longer on board, to a period of no less than 16 weeks. However, the Government has not provided the relevant national laws or regulations that are providing this limitation, as required under Standard A4.2.1, paragraphs 2 and 4. The same observation can be made regarding section 16(4) of the DMLC II, according to which shipowner is excluded from liability in case of: (i) injury happened otherwise than in the ship’s service; (ii) injury or sickness due to a conscious misconduct of the deceased seafarer; and (iii) illness intentionally kept hidden when engaged (Standard A4.2.1, paragraph 5). The Committee accordingly requests the Government to indicate the measures adopted or envisaged to give full effect to Standard A4.2.1, paragraphs 2-7.

Regulation 4.2 and Standard A4.2.1, paragraphs 8–14, and Standard A4.2.2. Shipowners’ liability. Financial security. Form and consultation. The Committee notes that sections 10(4) and 15(1) of MLC, 2006 Law No. 235 give effect to these provisions of the Convention. The Committee requests the Government provide information on the form taken by the system of financial security and whether it was determined after consultation with the shipowners’ and seafarers’ organizations concerned.

Regulation 4.3 and the Code. Health and safety protection and accident prevention. The Committee notes the detailed information contained under paragraph 11 of the DMLC II concerning the measures adopted by the shipowner to ensure compliance with the requirements on the Lebanese ship. However, the Committee observes that the Government has not provided information on any national laws and regulations and other measures, including the development and promulgation of national guidelines for the management of occupational safety and health, adopted to protect seafarers that live, work and train on board ships flying its flag as required by the Convention. The Committee recalls that under Standard A4.3, paragraphs 1 and 2, Members are required to develop concrete measures, such as policies and programmes, and on-board programmes for the prevention of accidents and injuries, as well as requirements for the reporting and investigation of on-board occupational accidents, which detail the respective obligations of shipowners, masters, seafarers and others concerned. The Committee requests the Government to provide information on measures adopted or envisaged to give full effect to the provisions of the Convention, in particular, on: (i) the development, after consultation with representative shipowners’ and seafarers’ organizations, of national guidelines for the management of occupational safety and health to protect seafarers that live, work and train on board ships flying its flag, and to provide a copy of them when available (Regulation 4.3, paragraph 2); (ii) the development of on-board programmes for the prevention of occupational accidents, injuries and diseases (Standard A4.3, paragraph 1(c)); (iii) the reporting, investigation and statistics on occupational accidents, injuries and diseases (Standard A4.3, paragraphs 5 and 6); and (iv) the obligation to require the shipowners to conduct risk evaluation for occupational safety and health on board ship (Standard A4.3, paragraph 8). The Committee reminds the Government that it can take into consideration the guidance provided in ILO Guidelines for implementing the occupational safety and health provisions of the Convention in the national measures adopted in the future to give full effect to Regulation 4.3 and Standard A4.3.

Regulation 4.4 and the Code. Access to shore-based welfare facilities. Welfare board. The Committee notes section 10(6) of MLC, 2006 Law No. 235 according to which all seafarers working on board ships have the right to easily access to the available existed welfare facilities and services on the shore, irrespective of nationality, race, colour, sex, religion, political opinion or social origin and irrespective of the flag State of the ship on which they are employed or engaged or work and during ships’ stay in Lebanese Ports. It also notes that welfare facilities are available in four ports and that section 10(8) of MLC, 2006 Law No. 235 provides that welfare board shall be established at ports at national level, as appropriate. The Committee requests the Government to provide further information with respect to these facilities and welfare boards that have been developed.

Regulation 4.5 and the Code. Social security. The Committee notes that, at the time of ratification of the Convention, Lebanon declared that the protection provided by Standard A4.5, paragraphs 1, 2 and 10 covered the following branches: sickness benefit; maternity benefit; family benefit and old-age benefit. The Committee notes that, section 10(9) of MLC, 2006 Law No. 235 provides that the Lebanese Maritime Administration, in accordance with national law, and within available means, shall take steps in cooperation and coordination with the other competent official sectors, to achieve progressively comprehensive social security for Lebanese seafarers, no less favourable than that enjoyed by shoreworkers resident in the country. The Committee requests the Government to provide information on any progress made on this issue. The Committee observes that the Government does not communicate information on the relevant national legislation giving full effect to the social security requirements. Recalling that Standard A4.5, paragraph 3, requires each Member to provide social security coverage to all seafarers ordinarily resident in its territory, regardless of the flag of the ship on which they work, the Committee requests the Government to indicate the measures adopted or envisaged under which seafarers ordinarily resident in Lebanon who work on board ships flying a foreign flag are protected in case of sickness, old age, maternity and family benefit. The Committee also requests the Government to provide information on the modalities related to affiliation to social security schemes, payment of contributions and benefits. The Committee recalls that although the primary obligation rests with the Member in which the seafarer is ordinarily resident, under Standard A4.5, paragraph 6, Members also have an obligation to give consideration to the various ways in which comparable benefits will, in accordance with national law and practice, be provided to seafarers in the absence of adequate coverage in the nine branches of social security. The Committee requests the Government to provide information on the measures adopted or envisaged to give effect to Standard A4.5, paragraph 6.

Regulation 5.1 and the Code. Flag State responsibilities. The Committee notes the Government’s indication that section 11(1) of MLC, 2006 Law No. 235 provides that the Lebanese Maritime Administration shall have an effective system for the inspection and certification of labour conditions on board Lebanese Ships to ensure the implementation of the standards contained in the MLC, 2006. However, the Committee observes that the Government has not provided information on the establishment of such system. The Committee requests the Government to provide information on the basic structure and objectives of Lebanese’s system (including measures to assess its effectiveness) for the inspection and certification of maritime labour conditions in accordance with Regulations 5.1.3 and 5.1.4 to ensure that the working and living conditions for seafarers on ships that fly Lebanese flag meet, and continue to meet, the standards of the Convention (Regulation 5.1.1, paragraphs 2 and 5; Standard A5.1.1, paragraph 1; Regulation 5.1.2, paragraph 2).

Regulation 5.1.1 and Standard A5.1.1, paragraph 2. Flag State responsibilities. Copy of the MLC, 2006, on board. The Committee notes that the Government does not provide information on the legislative or regulatory provisions requiring all ships that fly its flag to have a copy of the Convention available on board. The Committee requests the Government to report on how it ensures compliance with this requirement of the Convention.

Regulation 5.1.3 and the Code. Flag State responsibilities. Maritime labour certificate and declaration of maritime labour compliance. The Committee notes the Government’s reference to section 11(4) of Law No. 235 according to which the Lebanese Maritime Administration will ensure and issue the Maritime Labour Certificate complemented by DMLC. Sub-section 5 provides that the Lebanese Maritime Administration shall maintain a system of inspection of the conditions for seafarers on Lebanese ships by its qualified inspectors, which shall include verification that the measures relating to working and living conditions as set out in the DMLC II, where applicable, are being followed, and that the requirements of this Convention are met. The Committee observes the absence of information concerning legislation giving effect to Standard A5.1.3. In view of the lack of information concerning legislation in this regard, the Committee requests the Government to specify the provisions governing: (a) the maximum validity period of the maritime labour certificate (Standard A5.1.3, paragraph 1); (b) requirements relating to intermediate inspection (Standard A5.1.3, paragraph 2); (c) renewal of the certificate (Standard A5.1.3, paragraphs 3 and 4); (d) requirements relating to the issuance of an interim maritime labour certificate (Standard A5.1.3, paragraphs 5 to 8); (e) requirements relating to the posting on board ship and availability of the maritime labour certificate and the DMLC (Standard A5.1.3, paragraphs 12 and 13); (f) the circumstances under which a maritime labour certificate ceases to be valid (Standard A5.1.3, paragraphs 14 and 15); and (g) the circumstances under which a maritime labour certificate shall be withdrawn (Standard A5.1.3, paragraphs 16 and 17). The Committee observes, however, that the DMLC, Part I submitted by the Government only provides references to implementing legislation, without providing any details on the content of the national requirements. The Committee recalls that Standard A5.1.3, paragraph 10(a) provides that the DMLC, Part I shall not only “identify the national requirements embodying the relevant provisions of this Convention by providing a reference to the relevant national legal provisions” but also provide, “to the extent necessary, concise information on the main content of the national requirements”. The Committee therefore requests the Government to adopt the necessary measures to fully implement Standard A5.1.3, paragraph 10.

Regulation 5.1.4 and the Code. Flag State responsibilities. Inspection and enforcement. The Committee notes the Government’s reference to section 11(5) of MLC, 2006 Law No. 235 cited above. The Committee observes that this provision is of a general nature and is not giving effect to the detailed requirement under Standard A5.1.4. The Committee notes the Government’s indication that measures adopted to guarantee that inspectors have a status and conditions of service ensuring that they are independent of changes of government and of improper external influences are currently under development. The Committee also notes the Government’s indication that the Directorate General for Land and Maritime Transport (DGLMT) may apply some flexibility in applying particular requirements based on the gross tonnage of ships and voyages, e.g. the requirement for certification and inspection of working and living condition on a ship is not mandatory for ships under 500 GT not engaging in international voyages or voyages between foreign ports. Recalling that all ships covered by the MLC, 2006 are subject to inspection for all the requirements of the Convention, the Committee requests the Government to indicate the measures adopted to meet the requirements of Regulation 5.1.4 and Standard A5.1.4, and to specify in particular the manner in which it is ensured that inspectors have the training, competence, terms of reference, powers, status and independence necessary or desirable so as to enable them to carry out their duties (Standard A4.1.5, paragraph 3), as well as the procedures followed to receive and investigate complaints (Standard A5.1.4, paragraph 5).

Regulation 5.1.6 and the Code. Marine casualties. The Committee notes that section 11(8) of the MLC, 2006 Law, No. 235 provides that the Lebanese Maritime Administration should conduct a formal investigation into any serious incident involving a Lebanese ship leading to injury or loss of life. The Committee notes the Government’s indication that the applicable national provisions is to be developed. The Committee recalls that, in accordance with Regulation 5.1.6, an official inquiry “shall be held” into any serious marine casualty, leading to injury or loss of life that involves ships flying your country’s flag, and that the final report of the inquiry shall normally be made public. The Committee requests the Government to indicate the measures adopted or envisaged to give effect to Standard A5.1.6.

Regulation 5.2.2 and Standard A5.2.2. On-shore complaint-handling procedures. The Committee notes the Government’s indication that on-shore complaint-handling procedures are under development. The Committee requests the Government to provide information on any progress made on this issue and to indicate the measures adopted or envisaged in this respect.

[The Government is asked to reply in full to the present comments in 2027.]