From 1 September 2024 to 30 November 2024, Black Sea MoU carried out a Concentrated Inspection Campaign (CIC) focusing on Crew Wages and Seafarer Employment Agreements in accordance with the Maritime Labour Convention, 2006 (MLC, 2006).
The campaign also included relevant questions pertaining to financial security provisions introduced under the 2014 amendments to the MLC, 2006. It involved the member Authorities of the BS MoU that have ratified the MLC, 2006. This CIC was conducted under the campaign coordination of the Maritime Administration of Bulgaria.
As informed, it was conducted in conjunction with the Paris and Tokyo Memoranda, as well as other regional PSC Regimes, utilizing the Guidelines and Questionnaires of the Paris and Tokyo Memorandums. The member authority of Georgia used these resources for training purposes, given that the MLC, 2006 had been ratified but will enter into force there on 14 February 2025.
The Campaign in numbers
Over the course of the CIC period, involving all types of ships, a total of 635 inspections were carried out. Of these, 553 inspections were performed using the CIC questionnaire, and a ship was subjected to only one CIC inspection during the campaign period.
According to data from the Black Sea Information System (BSIS), 53 ships were detained in total, of which 45 detentions resulted from inspections with CIC questionnaires.
Four ships were detained as a direct result of the CIC concerning deficiencies related to crew wages and seafarer employment agreements under the MLC, 2006, reflecting a CIC topic-related detention rate of 0.74%.
Key deficiencies identified
The most notable deficiencies found during the campaign were associated with:
- the absence of signed Seafarer Employment Agreements (SEA) (42.2%); and
- delays in wage or salary payments exceeding monthly intervals (24.4%).
Flag state analysis
During the campaign, vessels registered under the flags of 44 different States were inspected under the CIC scope. The greatest number of inspections were carried out on ships flying the flags of Panama (138 inspections, 25.0%), Liberia (77 inspections, 13.9%), and the Marshall Islands (39 inspections, 7.1%).
The detained ships displaying CIC-related detainable deficiencies in the region were flagged by Belize, Cameroon, Saint Kitts and Nevis, and Vanuatu.
Inspections by ship type
According to the type of ship, the highest number of CIC inspections were conducted on bulk carriers (206 inspections, 37.3%), followed by general cargo/multi-purpose ships (149 inspections, 26.9%), oil tankers (74 inspections, 13.4%), and oil/chemical tankers (69 inspections, 12.5%), comprising 498 total CIC inspections at a rate of 90.1%.
Age analysis of inspected ships
It is noteworthy that older ships, particularly those 25 years and older, comprised seventy-five percent of inspected vessels. No detentions were observed among ships younger than 15 years, and no non-compliant CIC inspections were recorded for new ships aged 0–5 years.
The results of the campaign will be further analysed, and the findings will be presented at the 25th meeting of the Black Sea Port State Control Committee, after which the report will be submitted to the International Maritime Organization.
To remind, RISK4SEA, a specialized platform focused on providing advanced analytics, data, and Key Performance Indicators (KPIs) related to Port State Control (PSC) in the maritime industry, has also announced the results and the CiC intensity Index on Crew Wages and Seafarer Employment Agreements.
