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.
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
- Monitor developments in the HTW scoping exercise across subsequent sessions, until completion expected in 2027.
- 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.
- Proactively assess, at Company level, the adequacy of manning relative to the actual workload, anticipating a possible future regulatory tightening.
- Maintain open communication between crew and Company on signs of fatigue, regardless of formal compliance with the minimum limits.
- 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
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
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