Maritime Fatigue: Finding the Equilibrium for Safe Voyages
- Captain Cal Callahan
- Mar 16
- 2 min read
Fatigue management is a critical component of safe vessel operations, impacting crew performance, decision-making, and overall maritime safety. In Australia, commercial vessels fall into two primary categories, each governed by distinct regulatory frameworks:
Australian Regulated Vessels (ARVs)
These vessels, including some tug and barge operations, comply with international maritime conventions under the International Maritime Organization (IMO). They are regulated through Marine Order 28, which incorporates the Standards of Training, Certification, and Watchkeeping for Seafarers (STCW) and Safety of Life at Sea (SOLAS) conventions into Australian maritime law.
Under Marine Order 28, seafarers on Australian Regulated Vessels must adhere to strict rest period requirements:
A minimum of 10 hours of rest in any 24-hour period
A minimum of 77 hours of rest over seven days
Rest periods may be divided into a maximum of two periods, with at least one being six hours or longer
The interval between consecutive rest periods must not exceed 14 hours
Australian Domestic Commercial Vessels
These vessels operate under the Marine Safety (Domestic Commercial Vessels) National Law 2012. Complies with the National Standard for Commercial Vessels (NSCV) which fatigue is regulated by Marine Order 504 (MO504). Unlike Australian Regulated Vessels, Near Coastal Vessels are not required to comply with STCW or SOLAS but must implement fatigue risk management measures tailored to their specific operations.
While Marine Order 504 does not mandate a formal Fatigue Risk Management Plan (FRMP), vessel owners and operators must conduct a fatigue risk assessment as part of their Safety Management System (SMS). AMSA provides guidelines to help identify and manage fatigue risks, ensuring that appropriate controls are in place. Key risk factors include:
Crew members working more than 12 hours per day
Work weeks exceeding 60 hours
Less than 10 continuous hours of rest between shifts
Night work, particularly between 2 a.m. and 6 a.m.
Schedules that prevent at least two consecutive nights of sleep per week
Lack of 24 continuous hours off per week
By allowing vessel owners to develop a customised fatigue management approach, Marine Order 504 ensures flexibility while maintaining safety standards.
Are You Ready for the New Regulations in Fatigue Management?
The fatigue management regulations coming into effect in June 2025 provide an opportunity for small vessel operators to prioritise crew health and safety. By following the steps outlined above, you can ensure your operation is compliant when AMSA surveyors request to see how you manage fatigue within your vessel’s Safety Management System.
Fatigue is a manageable risk. With the right planning and strategies, you can minimise its impact on your vessel’s operations.
For more information, visit the AMSA website or refer to the Small Vessels Manual, Second Edition, Chapter 3: Safe Working Practices (page 79) or Chapter 4 Watchkeeping (page 89).
Capt. Cal
Sail your own course.