The number of people on board a yacht is a topic that has been discussed everywhere from the highest halls of the International Maritime Organization (IMO) to the most obscure seaside taverns. It seems that everyone who makes a living on the water has an opinion on this subject. How many is enough? How much crew is too much?
The requirements for minimum safe manning originate in various regulations including the Safety of Life at Sea Convention (SOLAS), Seafarer’s Training Certification and Watchkeeping (STCW) Code, IMO resolutions, several International Labour Organization (ILO) conventions, International Telecommunications Union (ITU) guidelines, World Health Organization (WHO) circulars, and numerous national laws.
The underlying principle in all of these rules is to establish the minimum number of people on board to safely operate the yacht.
In this process, the assigning authority for minimum safe manning is the administration, also known as the flag-state. This is the country in which the yacht is registered and the flag that flies on the stern. The statutory applicability of minimum safe manning affects all seagoing vessels, except warships and recreational vessels not engaged in trade (i.e. private yachts).
In the yachting world, each administration defines its own policy for minimum safe manning. Each individual commercial yacht or, where allowed, those private yachts conducting limited charters will be issued a document outlining the minimum number of crew required on board. This column outlines the policies for the most common flags seen on yachts, listed alphabetically.
Antigua and Barbuda
While relatively new to yachting, Antigua and Barbuda is recognized as one of the largest ship registries in the world. Yachts engaged in trade are considered commercial. As such, those yachts must possess a Minimum Safe Manning Document (MSMD) issued by the flag. Its guidelines are based upon IMO Resolution A.1047 “Principles of Safe Manning” and also the requirements on hours of rest in ILO Convention 180, the STCW Convention, and the Maritime Labour Convention.
The Seafarers and Manning Department at the Bahamas Maritime Authority is responsible for ensuring that all seafarers employed onboard Bahamas ships/units are trained and certified in accordance with international and national requirements. An MSMD is issued to every ship/unit to verify its compliance with the manning requirements of Section 184 of the Bahamas Merchant Shipping Act. Further guidance for the minimum manning on yachts is outlined in BMA Information No. 115 and the Bahamas Yacht Code.
The newest member to the family of yachting registries, Jamaica issues a Minimum Safe Manning Certificate (MSMC) to all charter yachts of 80 gross tons or more. Under this flag, charter yachts are registered as commercial or private charter. Manning scales are similar to those found with the United Kingdom, but with nuances for the level of license, number of personnel needed, and length of voyage. An extensive Manning Policy has been published as guidance.
The Maltese Administration will issue an MSMC for commercial yachts of more than 24m in length following receipt and review of the application for a safe manning document. The application may be supplied with the owner’s proposed manning levels and copies of related certification. When determining the minimum manning levels on board, Malta takes a similar approach to other registries, including consideration of:
St. Vincent and the Grenadines
This flag amended its safe manning policy in its last revision of its Safety Code of Practice for Pleasure Yachts Engaged in Trade. Previously, an MSMD was required only for commercial yachts above 500gt. For yachts less than this size, it was the owner’s discretion to determine the number of crew on board.
With the new, amended code, the requirement for an MSMD was lowered to all commercial yachts of 24m in length or more.
United Kingdom (All Red Ensigns, BVI, Cayman Islands, et al)
While each individual flag of registry under the Red Ensign has the authority to assign the minimum manning levels, overall guidance is provided in Section 26 of the Large Commercial Yacht Code (LY3).
Based upon the type of yacht (sail or motor), length, tonnage, and area of operation, the flag will issue an MSMD to the yacht. As a specific example under the Cayman Islands flag, for pleasure yachts engaged in trade, the MSMD will be issued in accordance with LY3, as an internationally acceptable equivalence to SOLAS. The issue of an MSMD is mandatory for all pleasure yachts engaged in trade over 500gt, however it is Cayman Islands policy to provide an MSMD for all pleasure yachts of 24m and over, certified in accordance with the LY3 Code.
United States of America
For yachts registered under the U.S. flag, the U.S. Coast Guard (USCG) assigns the minimum safe manning criteria for inspected vessels. Any yacht subject to inspection under 46 US Code will have the minimum complement of officers and crew necessary for the safe operation of the vessel outlined on the Certificate of Inspection (COI).
It is important to note that there is a considerable regulation still being implemented around the world that will drastically affect minimum safe manning scales. This is the Maritime Labour Code (MLC). Because existing regulations primarily focus on watchstanders, the MLC will now require flag administrations to consider all seafarers on board. This will include interior staff, chefs, supernumeraries, and their working and rest hours.
It will be interesting to see how the various flag-states interpret the new manning requirements and make them applicable to their respective fleets. History shows that as technology advances, physical manpower decreases. Yet somehow, the amount of actual work always seems to increase, only to be shared by even fewer people.
Capt. Jake DesVergers is chief surveyor for International Yacht Bureau (IYB). Contact him through www.yachtbureau.org.