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For a number of years the Committee has been commenting on the implementation of the requirement under Article 2(a)(i) of the Convention that there should be laws or regulations for ships registered in the territory laying down safety standards, including hours of work, so as to ensure the safety of life on board ship. The Committee notes from the Government's report that this matter is now governed by the Merchant Shipping (Safe Manning, Hours of Work and Watchkeeping) Regulations, 1997.
The Committee notes that, while Regulations Nos. 7, 8 and 9 do address the issue of hours of work on board ship, they do not appear to ensure the safety of life on board ship, as required by the Convention, since they are subject to the proviso so far as is reasonably practicable. On the other hand, Regulation No. 11 does provide that watchkeeping arrangements must be at all times adequate for maintaining safe navigational and engineering watches.
The Committee recalls the particular importance attached to this requirement of the Convention, as indicated in its earlier observations and in the comments of the Trades Union Congress. The safety requirement calls for legislation in respect of hours of work relating not only to watchkeepers (see paragraph 96 of the 1990 General Survey of the Convention). The Committee would be grateful if the Government would provide information enabling it to determine whether, in law and in practice, the Regulations can be regarded as adequate to that purpose, and if it would indicate any further measures taken or proposed in this regard.