Guidance

MSN 1838 (M) Amendment 2 Maritime Labour Convention, 2006 Minimum Age

Published 24 September 2025

Summary

This notice provides information about the minimum age for seafarers and the protection of young seafarers (under 18 years) working on board UK ships. 

• the minimum age for working on a UK seagoing ship is 16 years of age.
• those under the age of 18 years must not be assigned work which is likely to jeopardise their health and safety, unless they are fully qualified in the relevant skills or are working under supervision.
• the employer must carry out a risk assessment with regard to the particular risks to young persons. 
• those under the age of 18 years may not work at night unless as part of recognised training.
• in this context, “night” means a period of at least nine hours including the hours between midnight and 5 a.m. (local time)
• the minimum hours of rest are specified for seafarers under 18 years of age.
• certain types of work should not be undertaken by young persons on the grounds that such work is likely to jeopardise their health and safety.

Relationship with the Merchant Shipping (Maritime Labour Convention) (Minimum Requirements for Seafarers etc) Regulations 2014 (“the MLC Minimum requirements regulations”).

• part 2 of the MLC Minimum requirements regulations needs to be read together with this merchant shipping notice. This notice contains details of the exceptions which apply to the night work prohibition under those regulations. Failure to comply with those obligations may be a criminal offence under the regulations.
• to assist the reader, paragraph 12 identifies the regulation in the MLC Minimum requirements regulations which refers to this notice and identifies the relevant paragraph of this notice.

Amendment 2 amends references and contact details.

1. Introduction

1.1 The Merchant Shipping (Maritime Labour Convention) (Minimum Requirements for Seafarers etc.) Regulations 2014 (the “MLC Minimum Requirements Regulations”) prohibit any person under the age of 16 years from working on a ship and any person under the age of 18 from working at night on a ship (with exceptions as set out in section 4 below). This applies whether the seafarer is employed or self-employed.

1.2 The Merchant Shipping and Fishing Vessel (Health and Safety at Work) (Employment of Young Persons) Regulations 1998 (SI 1998/2411) (“the Young Persons Regulations”) prohibit young persons from undertaking certain types of work which are likely to jeopardise their health and safety.

1.3 This Merchant Shipping Notice provides information to shipowners and employers on the prohibited types of work and in addition sets out mitigating measures for other types of work which are also considered likely to jeopardise the health and safety of young persons – see paragraphs 3, 4 and 5 and Annex 1 of this Merchant Shipping Notice.  This information has been agreed following consultation with shipowners and seafarers’ representatives.

1.4 In addition, the Merchant Shipping (Maritime Labour Convention) (Health and Safety) (Amendment) Regulations 2014 amend, among others, the Young Persons Regulations and the Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 (the “General Duties” Regulations) (SI 1997/2962) so that shipowners owe a duty of care in respect of health and safety to seafarers, in addition to the duty of care which employers owe to workers.

1.5 Together the Regulations form part of a package which implements the Maritime Labour Convention 2006.

2. Background

2.1 The Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 (the “General Duties” Regulations) (SI 1997/2962) (as amended) require the shipowner and employers to assess the risks to seafarers’ and workers’ health and safety, irrespective of their age, as a result of the work being undertaken, and to introduce measures to either remove those risks entirely or, where that is not possible to reduce those risks as far as was reasonably practicable.

2.2  The health and safety of young persons is particularly at risk because of their general lack of awareness of risks, due to their immaturity and inexperience. The Young Persons Regulations supplement and expand the provisions of the General Duties Regulations by setting out specific measures to be taken in respect of the particular risks to young persons at work. This Merchant Shipping Notice provides advice to shipowners/employers on their responsibilities in relation to those workers and specifies the types of work which are regarded as potentially hazardous to young persons, jeopardising their health or safety, and which should not be undertaken by them. The Notice also advises on what mitigating measures should be in place to enable such work to be undertaken.

2.3 For the purpose of the MLC Minimum Requirements Regulations and the Young Persons Regulations, a young person is someone aged between 16 and 18 years of age. Persons under 16 years of age are classified as children and are prohibited from working on sea-going ships.

3. The Merchant Shipping (Maritime Labour Convention) (Minimum Requirements for Seafarers etc.) Regulations 2014  

3.1 Seafarer to be of minimum age (Regulation 4)

3.1.1 No seafarer may be employed or engaged or work on board a UK sea-going ship under the age of 16 years.

3.1.2 Work experience on a ship is considered by the Maritime and Coastguard Agency to constitute work and accordingly the same limits apply. However, “work shadowing” where children observe but do not participate in any work on ships is permitted, subject to the risk assessments having been undertaken and appropriate safety measures put in place.

3.2 Young Persons on Night Duty (Regulation 5)

3.2.1 In addition, the MLC Minimum Requirements Regulations prohibit those under the age of 18 being employed or engaged to work at night on a ship except in specified circumstances, which are when: 

• effective training of the seafarer, in accordance with established programmes and schedules would be impaired, or

• the specific nature of the duty or of a recognised training programme requires that the seafarers perform duties at night, and the work involved in those duties is specified in this notice as not being detrimental to the health and well-being of seafarers under the age of 18 (see paragraph 4.3).

3.2.2 Night means a period:

• the duration of which is not less than nine consecutive hours, and

• which starts no later than midnight and ends no earlier than 5.a.m. (local time)

3.2.3 Work carried out at night as part of the following recognised training programmes and schedules of training is not detrimental to the health and well-being of seafarers under the age of 18 (see paragraph 4.1.2 above and regulation 5(2)(b) of the MLC Minimum Requirements Regulations:

• any Deck Officer training under STCW Regulations II/1, II/2 and II/3;
• any Engineer Officer training under STCW Regulations III/1, III/2 and III/3;
• any Navigational watch Rating training under STCW Regulation II/4;
• any Engine Room watch Rating training under STCW Regulation III/4 ;
• any training of Ratings as AB, Deck or Engine under STCW Regulation III/5;
• any training of Electro-technical Officers under STCW Regulation III/6;
• any training of Electro-technical Ratings under STCW Regulation III/7;
• any training of Radio personnel under STCW Regulation IV/2;
• any training for alternative certification under STCW Regulation VII.

3.2.4 This list of training programmes has been agreed following consultation with the shipowners’ and seafarers’ organisations concerned.

4. The Merchant Shipping and Fishing Vessel (Health and Safety at Work) (Employment of Young Persons) Regulations 1998

4.1 Persons on whom duties are imposed - risk assessment

4.1.1 References in this section to duties in the Young Persons Regulations should be read as including the extension of those duties imposed on the shipowner by the MLC H&S Regulations as discussed in para 1.4.

4.1.2 As with the General Duties Regulations, the Young Persons Regulations place duties on the employer or, where the employer is not “in control of the matter” because he does not have responsibility for the operation of the ship, additionally on any person who is in control of the matter.

4.1.3 In carrying out the risk assessment required by regulation 7 of the General Duties Regulations, the Young Persons Regulations require the employer to take particular account of the risks which might arise to young persons as a result of their inexperience, lack of awareness of risks, immaturity etc. In this context the Young Persons Regulations specify the following areas for particular attention:

• the fitting out and layout of working areas;
• the nature, degree and duration of exposure to physical, biological and chemical agents;
• the form, range and use of work equipment and the way in which it is handled;
• the organisation of processes and activities;
• the extent of the health and safety training provided or to be provided to the young persons concerned; and
• risks from agents, processes and work listed in the schedule to the regulations.

4.1.4 Annex 1 provides advice on the risks covered by the schedule and ways of avoiding or reducing them.

4.1.5 In the context of risk assessment, employers are required to ensure that no young persons are engaged in work specified below, as it is likely to jeopardise their health or safety. Such prohibited work is any work:

• which is objectively beyond their physical or psychological capacity;
• involving harmful exposure to agents which are toxic, carcinogenic, cause heritable genetic damage or harm to the unborn child, or which in any other way chronically affect human health;
• involving harmful exposure to radiation;
• involving the risk of accidents which it may be assumed cannot be recognised or avoided by young workers owing to their insufficient attention to safety or lack of experience or training; or involving a risk to health from -

i) extreme cold or heat

ii) noise

iii) vibration

iv) optical radiation

v) electromagnetic fields.

4.1.6 Employers are also required to inform young persons of any risks to their health and safety identified in these areas. This is in addition to any information supplied under the General Duties Regulations with regard to the general risk assessment for all workers.

4.1.7 The assessment of risks to young persons under these regulations may be carried out as an integral part of the assessment process required by the General Duties Regulations, or as a separate exercise. It might be helpful to consider developing generic risk assessments for the employment of young people. These will be pertinent where young people typically undertake a series of tasks or duties. A generic risk assessment would need to be revised to address additional work not covered by the original assessment or if an individual young person might face greater risks e.g. as a result of a medical condition.

4.1.8 Exceptions are allowed to the above restrictions and prohibition where the activity in question is indispensable for vocational training and is performed under the supervision of a competent person. This means, for example, that a trainee who is following a structured training programme and is working alongside an experienced person or under direct supervision, may, as a part of that training, carry out activities which fall within the criteria listed. This in no way detracts from the principle that the employer has a duty to ensure the health and safety of the young person at work at all times. Appropriate controls must be in place which reduces any risk to the minimum that is reasonably practicable.

4.1.9 The competent person appointed to assist the employer with health and safety under the General Duties Regulations must under those regulations be provided with any information relevant to that role.  This should include being notified of any young persons employed on the ship and of any risks identified specifically in relation to them under regulation 5.

4.2 Rest periods for young persons

4.2.1 Regulation 6 stipulates minimum daily and weekly rest periods and rest breaks for young workers.  

4.2.2 The basic principle is that young persons should be provided with a minimum of 12 consecutive hours rest in every 24-hour period; and a rest period of at least 2 days in every week.  Where a young person’s daily working time is more than four and half hours, they should be provided with a rest break of at least 30 minutes which should be consecutive if possible.

4.2.3 It is recognised that if applied rigidly, the minimum rest requirements could restrict the employment of young persons on board ship, since they cannot be fitted into the operating schedules of many ships. There is therefore provision for the daily and weekly rest periods to be interrupted where periods of work are split up over the day or of short duration; and for the 2-day weekly rest period to be reduced to no less than 36 hours where this is justified by technical or organisational reasons.

4.2.4 In addition, derogations are built into the regulations where the young person concerned is working to a properly agreed schedule of duties. This may either be a schedule complying with the merchant shipping rules on hours of work, or another “relevant agreement”. Annex 2 gives guidance on “relevant agreements”. In either case, where such a schedule or other relevant agreement is in place, the rest periods above do not apply provided that schedule or agreement provides for compensatory rest time and that the employer ensures that the hours worked do not put at risk the health and safety of the young person.

4.2.5 Time spent training constitutes working time. This includes time spent undergoing formal instruction at college or on training courses away from the ship, as well as training received on board. It does not include private study time either on board or ashore.

5. The Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 (“The General Duties” Regulations)

5.1 Health surveillance

5.1.1 Under the General Duties Regulations the employer is required to provide for health surveillance of workers where appropriate. Chapter 7 of the Code of Safe Working Practices for Merchant Seafarers provides guidance on when surveillance is appropriate.

5.1.2 Where the risk assessment carried out under regulation 5(2) of the General Duties Regulations identifies a risk to the health and safety of young persons, or where any young person is required to work at night (other than in exceptional circumstances), the young persons concerned are entitled to free assessment of their health and capacities before starting work and regular monitoring thereafter. This monitoring is required only so long as night work continues, unless there are other factors arising from the work which may have long term consequences to health. 

5.2 General Health and Safety

5.2.1 When considering young persons working on board, shipowners and employers should have regard to all current health and safety regulations produced by the Maritime and Coastguard Agency as well as the related Merchant Shipping Notices and Marine Guidance Notes.

5.2.2 Measures should also be taken by the shipowner and the employer to bring to the attention of young persons information concerning the prevention of accidents and the protection of their health on board ships. Such measures could include adequate instruction in courses, official accident prevention publicity intended for young persons and professional instruction and supervision of young persons.

5.2.3 Education and training of young persons both ashore and on board a ship should include guidance on the detrimental effects on their health and well-being of the abuse of alcohol and drugs and other potentially harmful substances, and the risk and concerns relating to HIV/AIDS and of other health risk related activities.

5.3 Other Requirements Applying to Young Persons:

5.3.1 Young persons’ Medical certificates - any young person employed on a UK ship must be in possession of a current medical fitness certificate. This means a fitness certificate which complies with the requirements of the Merchant Shipping (Medical Certification) (Maritime Labour Convention) Regulations 2010. Such certificates are valid for 1 year for those under the age of 18. Further information is contained in Merchant Shipping Notice 1886 (M+F) and MSN 1887(M).

5.3.2 Record of young persons - the master is required to hold a record, as part of the List of Crew, of any young persons engaged as workers on the ship together with their dates of birth and date of engagement on the ship. A summary of the provisions of the Merchant Shipping and Fishing Vessels (Health and Safety at Work) (Employment of Young Persons) Regulations 1998 must be included in the folder enclosing the list of crew.

5.3.3 A recommended format for the List of Young Persons is available. Copies can be downloaded from the MCA website at https://www.gov.uk/government/publications/list-of-young-persons. Alternatively ship or company versions may be produced providing they replicate the wording in the MCA recommended version.

5.3.4 Further guidance for the well-being of young persons:

• if, after a seafarer under the age of 18 years has served on a ship for at least four months during their first foreign-going voyage, it becomes apparent that they are unsuited to life at sea, they should be given the opportunity of being repatriated at no expense to themselves from the first suitable port of call in which there are consular services of the flag State, or the State of nationality or residence of the young seafarer.

• further guidance on specific risks is available on the HSE website: http://www.hse.gov.uk/youngpeople/risks/ 

6. References to this Notice in the Merchant Shipping (Maritime Labour Convention) (Minimum Requirements for Seafarers etc) Regulations 2014

6.1 Regulation 5(2)(b) (young persons on night duty). Paragraph 4 of this Notice specifies work at night which is not detrimental to the health and well-being of seafarers under the age of 18.  

7. More information

Seafarer Safety and Health Branch
Bay 2/17 Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0)203 81 72000

Email: mlc@mcga.gov.uk

Website: www.gov.uk/mca

Please note that all addresses and telephone numbers are correct at time of publishing.