Who proposes, who approves and who withdraws minimum safe manning, and the five items the document carries (IMO Resolution A.1047(27))

The minimum safe manning document states the minimum number and grades of persons a ship must carry when it proceeds to sea. The Administration issues the document, but the numbers in it are first drawn up by the company that operates the ship. IMO Assembly Resolution A.1047(27) is the text that sets out that division of roles.

The resolution was adopted in 2011 and revoked the earlier resolutions A.890(21) and A.955(23). The resolution itself is a recommendation, not a convention. Port State control, however, regards compliance with the document as evidence of safe manning. A ship that sails with fewer persons than the document lists has thrown that evidence away.

This article follows the operative text and Annexes 1 to 5 of the resolution. Who proposes what, who checks what before approving, what the document contains, and when a new proposal is due, in that order.

The resolution is a recommendation, but port State control treats the document as evidence

2. RECOMMENDS that Governments, in establishing the minimum safe manning levels for ships flying their country’s flag, observe the principles set out in Annex 1 and the procedures set out in Annex 5 and take into account the guidelines set out in Annexes 2 and 3;

4. URGES FURTHER Governments, when exercising port State control functions under international conventions in force with respect to foreign ships visiting their ports, to regard compliance with minimum safe manning documents as evidence that such ships are safely manned;

The verbs are RECOMMENDS and URGES. The resolution recommends that Governments observe the principles and urges them, in port State control, to treat compliance with the document as evidence. The obligation to issue the document itself comes from SOLAS regulation V/14, which the preamble of the resolution cites.

Each annex has a different job. Annex 1 holds the principles, Annex 2 the factors for the determination, Annex 3 the responsibilities of companies and Administrations, Annex 4 the contents and model form of the document, and Annex 5 the procedure. The sections below follow that order.

Twelve factors go into the determination

1.1 The minimum safe manning of a ship should be established taking into account all relevant factors, including the following: .1 size and type of ship; .2 number, size and type of main propulsion units and auxiliaries; .3 level of ship automation; .4 construction and equipment of the ship; .5 method of maintenance used; .6 cargo to be carried; .7 frequency of port calls, length and nature of voyages to be undertaken; .8 trading area(s), waters and operations in which the ship is involved; .9 extent to which training activities are conducted on board; .10 degree of shoreside support provided to the ship by the company; .11 applicable work hour limits and/or rest requirements; and .12 the provisions of the approved Ship’s Security Plan.

This is the list in Annex 2. Factors attached to the ship itself, such as size and level of automation, come first. Factors attached to the way the ship is operated, such as frequency of port calls, trading area and the degree of shoreside support, come after. Item .11 is the work hour limits and rest requirements. Rest hours are not a rule to be kept after the manning has been set; they are an input when the manning is set.

Paragraph 1.3 of the same annex asks, except in ships of limited size, for enough qualified deck officers that the master does not have to keep regular watches, by adopting a three-watch system. The same sentence is repeated for the chief engineer. Paragraph 1.4 adds the number of personnel needed to meet peak workload situations.

The company drafts the proposal and answers for six things

1.1 The Administration may require the company responsible for the operation of the ship to prepare and submit its proposal for the minimum safe manning of a ship in accordance with a form specified by the Administration.

This is the first sentence of Annex 3. The party that proposes is the company responsible for the operation of the ship. The form is specified by the Administration.

What the company has to do while preparing the proposal is listed in paragraph 1.2 as six items. An assessment of tasks and duties, implementation of fitness for duty provisions and the record of hours, an assessment of numbers and grades, submission of the proposal, keeping the manning adequate at all times, and a new proposal on changes. The submission item is the one that defines what the proposal contains.

.4 prepare and submit to the Administration a proposal for the minimum safe manning based upon the assessment of the numbers and grades/capacities in the ship’s complement required for its safe operation, for its security and for protection of the marine environment, justifying the proposal by explaining how the proposed ship’s complement will deal with emergency situations, including the evacuation of passengers, where necessary;

The proposal is not a sheet of numbers. It carries justifying the proposal by explaining how the proposed ship's complement will deal with emergency situations. The company has to explain how that complement will handle an emergency. On a passenger ship that includes the evacuation of passengers.

Annex 5 breaks that explanation into steps. Split the operational functions into tasks, record for each task its duration, frequency, the competence it needs and its importance, work out how many tasks one person can carry in a work period, and then check that the resulting workload stays within the rest hour requirements.

The Administration approves only after checking two things

2.1 A proposal for the minimum safe manning of a ship submitted by a company to the Administration should be evaluated by the Administration to ensure that: .1 the proposed ship’s complement contains the number and grades/capacities of personnel to fulfil the tasks, duties and responsibilities required for the safe operation of the ship, for its security, for protection of the marine environment and for dealing with emergency situations; and .2 the master, officers and other members of the ship’s complement are not required to work more hours than is safe in relation to the performance of their duties and the safety of the ship and that the requirements for work and rest hours, in accordance with applicable national regulations, can be complied with.

There are two evaluation criteria. First, whether the numbers and grades can fulfil all the tasks. Second, whether that complement can comply with the work and rest hour requirements. The two are joined by and. A proposal that covers every task but breaks rest hours fails on the second criterion.

Where the Administration cannot approve the proposal, paragraph 2.3 has it require an amendment. Paragraph 2.4 says the Administration should approve and issue the document only when it is fully satisfied that the complement follows the principles of the resolution and is adequate in all respects. Once approved, the document is not fixed for good.

2.5 The Administration may withdraw the minimum safe manning document of a ship if the company fails to submit a new proposal for the ship’s minimum safe manning when changes in trading area(s), construction, machinery, equipment or operation and maintenance of the ship have taken place which affect the minimum safe manning.

2.6 The Administration should review and may withdraw, as appropriate, the minimum safe manning document of a ship which persistently fails to be in compliance with rest hours requirements.

Two grounds for withdrawal. One is a change without a new proposal. The other is persistent failure to comply with rest hour requirements. The rest hour records are the individual seafarer’s documents and, at the same time, the basis on which that ship keeps its manning document.

2.7 The Administration should consider the circumstances very carefully before allowing a minimum safe manning document to contain provisions for less than three qualified officers in charge of a navigational watch, while taking into account all the principles for establishing safe manning.

A document that lists fewer than three officers in charge of a navigational watch gets a separate, careful review. This points the same way as the three-watch sentence in Annex 2.

The document carries five items and an English translation

Annex 4 lists five items the document should contain as a minimum. The particulars of the ship, the table of numbers and grades, the formal statement by the Administration, any limitations on validity, and the dates of issue and expiry with signature and seal. The third item is the sentence that gives the document its effect.

.3 a formal statement by the Administration that, in accordance with the principles and guidelines set out in Annexes 1 and 2, the ship named in the document is considered to be safely manned if, whenever it proceeds to sea, it carries not less than the number and grades/capacities of personnel shown in the document, subject to any special conditions stated therein;

The condition is whenever it proceeds to sea. Every time the ship sails it has to carry not less than the numbers and grades in the table. It is not a condition met once and closed; it attaches again at every departure. subject to any special conditions means the special conditions written in the document are read with it.

Item in the document	Content
Particulars of the ship	Name, port of registry, distinctive number or letters, IMO number, gross tonnage, main propulsion power, type, trading area, whether the machinery space is unattended, the company as defined in the ISM Code
Table of personnel	Grade/capacity, the STCW regulation it corresponds to, number of persons, any special conditions
Formal statement	The Administration’s sentence that the ship is considered safely manned when it sails with not less than the table
Limitations on validity	Limitations tied to the particulars of the individual ship and the nature of its service
Issue and expiry	Date of issue, any expiry date, signature for and seal of the Administration

2 It is recommended that the minimum safe manning document be drawn up in the form corresponding to the model given in the appendix to this Annex. If the language used is not English, the information given should include a translation into English.

The model form in the appendix lays the table out in three columns. Grade or capacity, the STCW regulation for that grade, and the number of persons. Where the language of the document is not English, an English translation is included. The document is read by port State control officers.

When something changes, the company submits a new proposal

.6 prepare and submit to the Administration a new proposal for the minimum safe manning of a ship in the case of changes in trading area(s), construction, machinery, equipment, operation and maintenance or management of the ship, which may affect the safe manning.

This is the last item of paragraph 1.2 in Annex 3. A change in trading area, construction, machinery, equipment, the method of operation and maintenance, or the management of the ship calls for a new proposal. The test is which may affect the safe manning. A change that may affect the manning is enough. Section 3 of Annex 5 likewise has the company advise the Administration of such changes and submit a new proposal.

Paragraph 2.5, seen above, is the reverse side of this duty. If a change has taken place and no new proposal follows, the Administration may withdraw the document. Section 4 of Annex 5 adds that the Administration should periodically review the manning arrangements. On the company side, the moment the managing company changes or the trading area widens is the moment a new proposal is due.

Worth confirming

This article covers the operative text and Annexes 1 to 5 of Resolution A.1047(27). The resolution is a recommendation, and under paragraph 1.2 each Administration may keep arrangements adapted to technical developments and special types of ships. The proposal form, the approval procedure and the validity of the document for a particular ship are found in the rules of its flag State.

The table of personnel is read together with the STCW regulation numbers. Whether a person holding the certificate for the grade in the table is actually in that post is the point port State control compares. A complement that matches in number but not in the certificate for the grade has not met the condition of the document.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

• IMO · Resolution A.1047(27) Principles of minimum safe manning

Continue with the related operational guidance

• The two conditions on manning levels and where catering crew sit (MLC Regulation 2.7)
• Seafarer rest hour limits per 24-hour and 7-day window and how violations are judged