The coming into force of the Maritime Labour Convention 2006 (MLC 2006) has brought with it a wide range of areas with which owners have to comply. While some such as hours of work and rest have been well publicised others such as Regulation 3.2 on Food and Catering have not been, and shipowners could end up falling foul to Port State Control (PSC) inspections according to David Steele, director of Food Inspection and Training Ltd (FIT).
MLC 2006 was rolled out on 20 August last year and comes into force worldwide on 20 August 2014.
“Since FIT’s launch nearly two years ago, my observation is that most shipowners don’t fully understand what Regulation 3.2 really is all about, since I initiated the training and auditing of vessels, I have yet to inspect one ship that is anywhere near what Regulation 3.2 stands for,” Steele told Seatrade Global.
“Most shipowners or their representatives, think that when they get the DMLC part 1, that they are safe. We are viewing this from a maritime catering perspective and most owners are not aware of what they need to do to comply with MLC 3.2.”
In practice this means that the ship’s cook must have Food Hygiene safety training to Level 2 and the shipowner must have a Food Safety Management system (HACCP).
Food and catering compliance are certainly on the agenda in MLC2006 inspections and since the convention started 68 ships have been investigated and 24 cases related to food and water. One well-publicised case recently was the Panamanian-flagged, Turkish vessel Munzur detained in the UK for multiple safety and accommodation failings, among them food and water related.
Generally though detention of a vessel for food and water related violations of MLC2006 would only likely happen if the violations were of a serious nature. “[I am] not quite sure yet how much the owner would have to be in violation to be detained, quite serious I would expect, MLC does not want to detain a vessel, rules are that once an inspection has been carried out, and found to be in breach, it can be issued with a notice of intent,” Steele explained.
The owner would then be given time between ports of call to rectify violations. “I would expect the ship owner could rectify these matters quite swiftly, with the proof of training and the food safety management system in place, this can take eight hours of training for the cook, and at least two days to put in place the HACCP system,” he said.