As the International Maritime Organization (IMO) prepares to open discussions at the 12th session of its Sub-Committee on Human Element, Training and Watchkeeping (HTW 12) on fatigue and hours of work and rest, MarinePALS CEO Captain Pradeep Chawla is urging regulators to face a simple reality: ships schedules are busier , administrative burden due to the regulations is heavier and inspections are tougher than ever, yet crew numbers onboard have steadily declined.

Captain Pradeep Chawla said: “Over the years, we have improved safety enormously, we have better navigation systems, better communications, better engines and stronger environmental protection systems. Conventions such as SOLAS, MARPOL, STCW and the Maritime Labour Convention are far more detailed than they once were. Inspection regimes are stricter. Monitoring is tighter and it’s all really positive, but at the same time we have quietly reduced the number of people on board.”

He warned: “Every new requirement comes with another logbook, another record, another checklist. None of these things are unreasonable on their own, but together they add up, and the number of hands available to carry that load has not increased but decreased.”

The cry from the seafarers across the world is “Enough is enough” about the tasks that they can manage with existing manning levels.

Drawing on five decades in the industry, including 17 years at sea and more than 30 years ashore leading QHSE and training functions, as well as participating in IMO discussions and accident investigations, Captain Chawla said this latest review at HTW 12 must not repeat past cycles of debate without progress: “We have discussed safe manning many times before. This time, the IMO must be prepared to examine the link between workload, fatigue and manning levels honestly. If we are serious about fatigue, we must be serious about manning.”

Rather than calling for a blanket increase in crew numbers across all vessel types, Captain Chawla has proposed a set of practical principles to guide regulatory reform:

• A non-competitive global minimum: All flag states should agree not to issue manning certificates below a firm baseline. A Master and three navigation watchkeepers should be considered essential as a minimum.

• Zonal differentiation of sea areas: Open Ocean operations are not the same as congested coastal waters. Requirements should be stricter in waters closer to shore and in high-traffic areas.

• Port intensity as a determining factor: The number of port calls within a seven-day period must influence minimum manning. A vessel calling multiple ports in quick succession faces very different pressures from one on long ocean passages.

• Ship type and trade profile taken together: A short-sea chemical tanker trading in Northern Europe does not experience fatigue in the same way as a VLCC crossing oceans. Regulations should recognise that operational difference.

• Active monitoring by flag administrations: With modern tracking platforms and AI systems, it is possible to monitor port calls and trading patterns. Flag states should use this data to trigger reviews of manning adequacy.

• Stricter control of exemptions: Exemptions should not become routine. Penalties for deliberate non-compliance or misleading declarations should be strengthened to ensure fairness across the industry.

Captain Chawla added: “The industry always wants a level playing field. If the same rules are applied consistently by all flags, owners will comply. The difficulty arises when interpretation varies and commercial advantage enters the picture. We have discussed safe manning many times before. It cannot simply be buried again because it is difficult. The discussion this time around needs to be detailed without defensiveness.The task load of the seafarers must be acknowledged and addressed.”

He appealed to regulators: “After every major accident, we say ‘this is unacceptable’, but unless we address the underlying pressures of workload, fatigue, inconsistent enforcement then we will keep revisiting the same conversation. The seafarers are telling us something very clearly, so we should listen. Seafarers’ lives matter.”