From 1 September 2024 to 30 November 2024, the Memorandum of Understanding on Port State Control in the Black Sea Region (BS 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.
The campaign 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. This campaign 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 have been ratified but will enter into force there on 14 February. The campaign shows the following preliminary results.
Over the course of the CIC period, involving all types of ships, a total of 635 inspections were carried out. Of these inspections, 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 were the result of inspections with CIC questionnaires and 4 of them were detained as a direct result of the CIC concerning deficiencies related to crew wages and seafarer employment agreement under the MLC,2006, reflecting a CIC topic related detention rate of 0.74%.
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%).
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 with 138 inspections (25.0%), Liberia with 77 inspections (13.9%) and the Marshall Islands with 39 inspections (7.1%). The detained ships displaying CIC-related detainable deficiency(s) in the region were flagged by Belize, Cameroon, Saint Kitts and Nevis, and Vanuatu.
According to type of ship, the highest number of CIC were conducted on bulk carriers with 206 inspections (37.3%), followed by general cargo/multi-purpose ships with 149 inspections (26.9%),
oil tankers with 74 inspections (13.4%) and oil/chemical tankers with 69 inspections (12.5%), which
comprises 498 total CIC inspections with a rate of 90.1%.
It is noteworthy that older ships, particularly those 25 years and older, comprised the seventy-five percent, while no detentions were observed among ships younger than 15 years old and no noncompliant CIC inspections were recorded for new ships aged 0-5.
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.