Operational Guide · Registers & Logbooks

# Crew Fatigue: The IMO 2026-2027 Review Process

Not yet a new requirement, but the first formal step towards one: the HTW sub-committee has launched a review of the effectiveness of hours of work and rest rules, with conclusions expected in 2027.

fatigue HTW 12 hours of work and rest STCW MLC

## Operational Explanation

The HTW (Human Element, Training and Watchkeeping) 12 sub-committee, meeting from 23 to 27 February 2026, launched a formal scoping exercise on the effectiveness of the current rules on seafarers' hours of work and rest, set out in STCW and MLC. The aim of the exercise is to assess whether the current limits (a minimum of 10 hours of rest in 24, of which at least 6 consecutive, and 77 hours in 7 days) adequately reflect the real management of fatigue on board, or whether they require a substantial revision.

The work is coordinated with the III (Implementation of IMO Instruments) sub-committee, given that the practical effectiveness of rest rules depends largely on their application and enforcement, not only on their text. Completion of the scoping exercise is expected in 2027: this is therefore a preparatory stage, not an immediate new obligation, but it is the most concrete signal so far of a possible future revision of the regulatory framework on fatigue.

## Regulatory Reference

HTW 12 (23-27 February 2026): launch of a formal scoping exercise on the effectiveness of the hours of work and rest rules set out in STCW Regulation VIII/1 and MLC Regulation 2.3, in coordination with sub-committee III. Completion expected in 2027; no regulatory change has yet been adopted.

## Scope of Application

Every Company and every seafarer subject to the STCW/MLC hours of work and rest requirements; the scoping exercise does not yet introduce additional obligations, but signals a possible future revision to monitor.

## Procedure / How to Complete It

1. Monitor developments in the HTW scoping exercise across subsequent sessions, until completion expected in 2027.
2. In the meantime, verify that the recording of hours of work and rest on board accurately reflects the real situation, not just the formal minimum required.
3. Proactively assess, at Company level, the adequacy of manning relative to the actual workload, anticipating a possible future regulatory tightening.
4. Maintain open communication between crew and Company on signs of fatigue, regardless of formal compliance with the minimum limits.
5. Coordinate with the Master and heads of department to identify recurring patterns of rest limit breaches, even when isolated or justified by operational circumstances.

## Practical Example

Example: a Company, informed of the launch of the HTW scoping exercise, carries out a voluntary internal review of manning on its highest-intensity operational routes, without waiting for the outcome of the IMO review expected in 2027.

## Real Cases

Managing fatigue on board has long been recognised as a risk factor that numeric rest-hour limits alone do not fully resolve: a seafarer can formally comply with the minimum of 10 hours of rest in 24 and still accumulate chronic fatigue due to fragmented rest or the intensity of the workload during waking hours. The HTW scoping exercise arises precisely from this awareness, assessing the real effectiveness of the rules beyond mere formal compliance.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Recording of rest hours managed as a mere documentary formality, without reflecting the real management of fatigue on board | Formal compliance that does not prevent the accumulation of chronic fatigue in the crew | Treat the recording of rest hours as a real fatigue management tool, not just a compliance document
No internal monitoring of developments in the HTW scoping exercise by the Company | Unpreparedness for a possible regulatory revision expected in 2027 | Monitor developments in subsequent HTW sessions and proactively assess manning adequacy

## PSC Observations

Compliance with STCW/MLC hours of work and rest limits remains an established PSC control, verified through onboard records; the HTW scoping exercise does not yet introduce new elements of PSC verification, being at a preparatory stage.

## Operational Tips

- Don't wait for the outcome of the HTW scoping exercise (expected in 2027) to review the real adequacy of manning relative to workload.
- Treat the recording of rest hours as a fatigue management tool, not just a form to be filled in correctly.
- Maintain an open communication channel between crew and Company on signs of fatigue, even when formal limits are being met.

## Checklist

- Developments in the HTW scoping exercise monitored across subsequent sessions
- Recording of rest hours verified as representative of the real situation on board
- Manning adequacy proactively assessed against real workload
- Open communication channel on fatigue signs maintained between crew and Company
- Recurring patterns of rest limit breaches identified and analysed, even if isolated

## FAQ

What is the scoping exercise launched by HTW 12?
A formal assessment, launched at the HTW 12 session (23-27 February 2026), of the effectiveness of the current STCW/MLC rules on hours of work and rest, with completion expected in 2027.
Does anything already change in the rest hour requirements?
No, the scoping exercise is a preparatory and assessment phase; it does not yet introduce changes to the current limits of STCW Regulation VIII/1 and MLC Regulation 2.3.
With which other IMO sub-committee is this work coordinated?
With sub-committee III (Implementation of IMO Instruments), given that the practical effectiveness of rest rules also depends on their application and operational enforcement.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

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