Inspection of living quarters, storerooms and complaints procedures

Why this sits with the Master

The obligation to inspect living quarters and hear complaints falls personally on the Master — not the officer of the watch, not the bosun. Under the Maritime Labour Convention 2006 (MLC) as enacted in UK law through the Merchant Shipping (Maritime Labour Convention) (Minimum Requirements for Seafarers etc.) Regulations 2014, the Master is responsible for ensuring seafarers' living conditions remain fit for purpose throughout the voyage. This is not a delegation item; the Master owns it.

The inspection cycle

MLC Standard A3.1 requires regular inspections of seafarer accommodation. In practice, UK flag guidance (reflected in the syllabus underpinned by MSN 1858) expects inspections to be carried out at defined intervals — at least monthly is the accepted norm — covering crew cabins, mess rooms, galleys, sanitary spaces, and stores used by crew. The Master should conduct, or formally arrange, the inspection and record it.

The logical sequence is:

1. Plan and announce — adequate notice allows crew to prepare spaces while still giving a representative picture of normal conditions.
2. Walk through systematically — accommodation spaces first (cleanliness, ventilation, heating/cooling, lighting, vermin), then galley and mess (hygiene, food storage temperatures, condition of equipment), then sanitary spaces (drains, hot water, cleanliness), then bonded stores and general storerooms (stowage security, condition, no fire hazards).
3. Involve a crew representative — MLC requires that a seafarers' representative may accompany the Master. This protects both parties: it provides a witness and ensures the inspection is seen as transparent rather than punitive.
4. Record findings immediately — deficiencies noted in the Official Log Book. Any item requiring corrective action is logged with a target completion date. Unresolved deficiencies become a flag-state inspection risk and, more importantly, evidence of neglect if harm follows.
5. Close out actions — re-inspect or sign off each corrective action. The loop must close.

Complaints procedure

MLC Standard A5.1.5 requires every ship to have an on-board complaints procedure. The Master must ensure seafarers know it exists and can access it without fear of victimisation. The procedure must:

• Allow a complaint to be made initially at the shipboard level (typically to the head of department, then to the Master).
• Allow the seafarer to be accompanied by a colleague or representative.
• Allow the seafarer to bypass the Master and complain directly to the flag state or port state authority if the Master is the subject of the complaint, or if the complaint remains unresolved.
• Protect the seafarer against retaliation — the Master must make this explicit and enforce it.

The Master records the complaint, the response, and the outcome in the Official Log Book. Where the complaint concerns conditions that potentially breach MLC, the flag state administration may need to be notified. Attempting to suppress or discourage a complaint is itself a breach of MLC and a serious leadership failure.