Maritime Labour Convention Compliance: How to Stay Inspection-Ready and Protect Your Crew

My name is Davide Ramponi, I’m 20 years old and currently training as a shipping agent in Hamburg. On this blog, I take you with me on my journey into the exciting world of shipping. I share my knowledge, my experiences, and my progress on the path to becoming an expert in the field of Sale and Purchase – the trade with ships.

Today’s topic is one that every shipowner, operator, and crewmember needs to understand: the Maritime Labour Convention (MLC 2006). Often referred to as the “Seafarers’ Bill of Rights,” this international treaty sets the standard for crew welfare on board vessels.

But MLC compliance isn’t just about ticking boxes. It’s about ensuring fair treatment, decent working conditions, and legal safety. At the same time, non-compliance can lead to detention, reputational damage, and serious legal consequences.

So—how do you stay MLC-compliant in practice? What are the most common weak spots? And how can you ensure your vessel passes a Port State Control inspection without surprises?

Let’s unpack the essentials. 👨‍✈️⚖️

🌍 What Is the Maritime Labour Convention (MLC 2006)?

The Maritime Labour Convention, adopted by the International Labour Organization (ILO) in 2006, entered into force in 2013. It consolidates and updates over 65 existing maritime labour instruments into one comprehensive treaty.

📜 MLC’s Main Purpose:

• Protect the rights of seafarers

• Create a level playing field for shipowners

• Establish minimum standards for working and living conditions on board

🌐 As of 2024, the MLC is ratified by over 100 countries, covering more than 90% of the world fleet.

💬 Nicknamed “The Fourth Pillar of Maritime Regulation” (alongside SOLAS, MARPOL, and STCW), MLC is a core compliance requirement for international shipping.

📌 What Are the Key MLC Compliance Areas?

The MLC is organized into five titles, each covering a different area of seafarer welfare:

Title 1: Minimum Requirements for Seafarers

• Minimum age (not under 16, or 18 for night work)

• Medical fitness

• Training and certification

• Recruitment free of charge

Title 2: Conditions of Employment

• Written contracts of employment

• Clear terms including wages, working hours, and repatriation rights

• Minimum 2.5 days paid leave per month

Title 3: Accommodation, Recreational Facilities, Food

• Minimum cabin size, privacy, ventilation

• Access to sanitation, recreation, and clean food

• Regular inspection of living conditions

Title 4: Health Protection and Medical Care

• Onboard and ashore medical access

• Occupational safety and accident prevention

• Health protection training and PPE

Title 5: Compliance and Enforcement

• Flag State inspections

• Port State Control (PSC) enforcement

• Complaint procedures

📋 Bottom line:

If your vessel is flagged in or enters a ratifying country, MLC rules apply—and your vessel can be inspected and detained if found non-compliant.

🛠️ Common MLC Compliance Gaps (And How to Avoid Them)

Even well-run ships can face trouble during an MLC inspection—often due to documentation issues or minor oversights that raise red flags.

⚠️ Gap 1: Missing or unclear employment contracts

• Every seafarer must have a signed contract that they can understand

• Contracts must reflect actual wages, duties, working hours, and repatriation terms

✅ Tip: Use ILO model contracts or those approved by your flag state. Keep copies onboard and ashore.

⚠️ Gap 2: Inaccurate wage records or late payments

• MLC requires timely wage payments, ideally monthly

• Crew must receive a pay slip with wage breakdown and currency info

✅ Tip: Use digital payroll tools and keep at least three months of wage records onboard.

⚠️ Gap 3: Poor accommodation standards

• Port inspectors often check mattress condition, cabin size, lighting, ventilation, toilets

• Even minor signs of neglect can lead to deficiency reports

✅ Tip: Include cabin inspections in your regular onboard maintenance checklist. Encourage crew to report problems early.

⚠️ Gap 4: Broken complaint systems

• The MLC requires a clear, confidential complaint mechanism

• Crew must be able to raise issues without retaliation

✅ Tip: Post the complaints process in a visible location and conduct drills so crew understand their rights.

🔍 Port State Control: How MLC Is Enforced in Practice

You can’t talk about MLC compliance without discussing Port State Control (PSC)—the enforcement arm that checks vessels entering national waters.

🚢 What PSC Inspectors Look For:

• Valid MLC Certificate and Declaration of Maritime Labour Compliance (DMLC)

• Signed seafarer contracts and wage records

• Living quarters and sanitation

• Crew knowledge of complaint procedure

• No signs of mistreatment, forced labor, or unsafe conditions

🛑 Failure to comply = potential vessel detention.

💡 Pro tip: 

PSC officers often interview seafarers without officers present. If your crew isn’t happy or feels unprotected, it will come out.

📚 Best Practices for Onboard MLC Compliance

Let’s look at how to stay ready every day, not just during inspections.

1. 📄 Keep Documents Updated and Accessible

• DMLC Part I and II

• Seafarer contracts

• Medical certificates

• Wage slips and leave records

📌 Checklist: Keep at least one full employment file per crewmember onboard.

2. 🧼 Maintain Accommodation and Sanitary Facilities

• Regular cleaning and inspection logs

• Functional air conditioning, lighting, and showers

• Access to hot meals and clean drinking water

🛏️ Small details like working fans or fresh bedding matter to crew morale—and PSC.

3. 🧠 Educate Your Crew

• Conduct MLC onboarding briefings

• Post complaint steps and hotline numbers

• Appoint a designated person (DPA) for crew concerns

💬 Encourage open communication—MLC compliance is a team effort.

4. 🩺 Prioritize Health and Medical Readiness

• Ensure onboard medical supplies are stocked

• Assign a trained medical officer or crew member

• Log all injuries, treatments, and health checks

🧯 Don’t forget PPE and mental health resources—they count, too.

🌟 Real-World MLC Compliance in Action

Example 1: MOL’s Digital Crew Contract Platform

Mitsui O.S.K. Lines digitized its crewing systems to ensure MLC compliance across 700+ ships. Crews can view contracts, payslips, and leave records via app—transparent, traceable, and MLC-friendly.

💬 Lesson: 

Technology makes compliance easier—for owners and seafarers.

Example 2: Crew-Led Complaint Resolutions on a Bulk Carrier

A Filipino deck crew raised concerns about food quality. Thanks to an onboard MLC process, the issue was logged, addressed by the master, and resolved within 48 hours.

💬 Lesson: 

Empowered crews + working systems = happy people and safe ships.

🧭 Compliance Checklist: Your Quick Guide to MLC Readiness

✅ Daily

• Clean cabins and toilets

• Check food quality and quantity

• Maintain fresh air, water, and lighting

📅 Weekly

• Log crew hours and wages

• Check complaint system functionality

• Review maintenance of accommodation

🗂️ Monthly

• Review IHM files and contracts

• Run crew feedback or anonymous surveys

• Update medical supplies and logs

⚖️ Final Thoughts: MLC Compliance is Good Seamanship

The Maritime Labour Convention isn’t just a legal framework—it’s a blueprint for fair and decent seafaring. Crews who feel respected and safe perform better, stay longer, and contribute to smoother voyages.

🎯 Key Takeaways:

• MLC 2006 sets minimum global standards for crew welfare

• Common risks include contract errors, poor accommodation, and lack of complaint handling

• PSC inspectors actively enforce MLC—detention is real

• Simple routines, documentation, and communication keep you inspection-ready

Are your vessels MLC-compliant? How does your team support crew well-being on board?

💬 Share your thoughts in the comments — I look forward to the exchange!

---

---