Guidance

MSN 1886 (M+F) Amendment 3 medical examination system - appointment of approved doctors and medical and eyesight standards

Published 16 October 2025

Summary

This Notice contains the mandatory fitness standards specified by the Secretary of State under the Merchant Shipping (Maritime Labour Convention) (Medical Certification) Regulations 2010, as amended (“the MLC 2010 Regulations”) and the Merchant Shipping (Work in Fishing Convention) (Medical Certification) Regulations 2018 (“the FV 2018 Regulations”);

• the qualifications required by a medical practitioner as defined in regulation 2 of both the 2010 and 2018 Regulations;

• guidance on forms to be used by medical practitioners and medical referees in keeping records and making returns.

The medical fitness and eyesight standards are consistent with STCW 78 including the Manila amendments and the ILO/IMO Guidelines on the medical examinations of seafarers.

The requirements do not apply to those working on pleasure vessels (not used commercially).

Relationship with the Merchant Shipping (Maritime Labour Convention) (Medical Certification) Regulations 2010, as amended

• The MLC 2010 Regulations need to be read in conjunction with this Merchant Shipping Notice, as it sets out some of the key details which supplement the legal obligations in those Regulations. Failure to comply with those obligations may be a criminal offence under the Regulations.
• In order to assist with this Paragraph 8 contains an index which clearly sets out and/or identifies the provisions in this Notice which relate to the relevant provision in the Regulations.

Relationship with the Merchant Shipping (Work in Fishing Convention) (Medical Certification) Regulations 2018

• The FV 2018 Regulations need to be read in conjunction with this Merchant Shipping Notice, as it sets out some of the key details which supplement the legal obligations in those Regulations. Failure to comply with those obligations may be a criminal offence under the Regulations.
• In order to assist with this Paragraph 9 contains an index which clearly sets out and/or identifies the provisions in this Notice which relate to the relevant provision in the Regulations.

This MSN has subsequently been amended and is issued as Amendment 3 to update the list of current MCA approved CAD Testing Centres. The addresses and contact details for all MCA approved CAD Test Centres can be found in Annex B.

1. Introduction

1.1 The Merchant Shipping (Maritime Labour Convention) (Medical Certification) Regulations 2010, (referred to in this Notice as “the MLC 2010 Regulations”) and the Merchant Shipping (Work in Fishing Convention) (Medical Certification) Regulations 2018 (“the FV 2018 Regulations”) implement the medical certification provisions of the Maritime Labour Convention 2006 and the ILO Work in Fishing Convention (No. 188) for the UK.

1.2 They also implement, for merchant seafarers, the requirements of clause 13 of the Social Partners’ Agreement set out in the Annex to Council Directive 1999/63/EC of 21 June 1999 (the Seafarers’ Working Time Directive)1.

1.3 The provisions set out in this notice also comply with Regulation I/9 and Standard A.I/9 of the IMO’s International Convention on Standards of Training, Certification and Watchkeeping (STCW), to which the UK is a signatory and the International Convention on Standards of Training, Certification and Watchkeeping for Fishing Vessel Personnel (STCW(F), which the UK has not yet ratified.

Terminology

1.4 In this notice,

• the fisherman or seafarer being examined or in respect of whom a decision is made about their fitness to work at sea or to fish is referred to as “the candidate”;
• “Ship” includes “fishing vessel”.
• “Master” includes skipper.
• “go to sea”, “sea service” etc includes work on a fishing vessel regardless of area of operation.

2. Application - General

2.1 The MLC 2010 Regulations and the FV 2018 Regulation together require persons working on sea-going UK ships and all UK fishing vessels wherever they may be, to hold a medical fitness certificate. MCA also has the power to enforce the requirement to hold a valid medical certificate in respect of seafarers on non-UK ships and fishing vessels when in a UK port or UK waters.

Application to ships other than Fishing Vessels (MLC 2010 Regulations reg 6)

2.2 For vessels other than fishing vessels, the MLC 2010 Regulations apply to seafarers working on sea-going vessels.

2.3 “seafarer” means any person, including a master, who is employed or engaged or works in any capacity on board a ship and whose normal place of work is on a ship. Guidance is given on MCA’s interpretation of the term “seafarer” for the purpose of these Regulations in Marine Guidance Note MGN 471(M).

Sea-going ship

2.4 For the purposes of the MLC 2010 Regulations, “sea-going” in relation to a United Kingdom ship means

(a) a ship which operates outside the waters specified as Category A, B, C and D waters in Merchant Shipping Notice 1837(M), or

(b) a ship to which the Merchant Shipping (Survey and Certification) Regulations 1995 (as amended) apply and in respect of which no exemption under regulation 2(2) of those Regulations applies;

(c) a ship to which regulation 4 of the Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 1998 (as amended) applies, and which falls within the description given in paragraph (3) of that regulation; or

(d) a high speed craft in respect of which a permit to operate outside waters of Categories A, B, C or D has been issued in accordance with regulation 8 of the Merchant Shipping (High Speed Craft) Regulations 2004 (as amended).

Exclusions

2.5 The requirements of the MLC 2010 Regulations do not apply to pleasure vessels, fishing vessels (but see section 2.6 – 2.8) or to offshore installations whilst on their working stations.

2.6 The MLC 2010 Regulations do not apply to those working on vessels operating solely in inland waterways (waters of categories A, B, C or D) – although to obtain a boatmaster’s license for inland waterway operations, a medical certificate is required. See MSN 1853(M) section 16.

2.7 Government ships such as those operated by the MOD Fleet which are not ordinarily engaged in commercial maritime operations are not covered by the MLC 2010 Regulations, although it is expected that they will generally comply with the Standards.

Application to Fishing Vessels (FV 2018 Regulations reg 5)

2.8 In respect of fishing vessels ONLY, the FV 2018 Regulations apply to UK fishing vessels wherever they may be. Fishermen working on non-UK vessels in UK ports are required to have a medical fitness certificate in accordance with the requirements of ILO 188 Articles 10 to 12.

2.9 “Fisherman” means every person including the skipper employed or engaged in any capacity on board any fishing vessel, but does not include a person solely engaged as a pilot for the vessel. The FV 2018 Regulations apply to those operating in inland waterways as well as sea-going vessels.

2.10 “Existing fisher” for this purpose is defined as those who can evidence that they have already been working on vessels of 10 metres and under for at least four weeks between 30 November 2021 and 30 November 2023 (as per MSN 1915).

2.11 The requirement to hold a medical certificate applies as follows:

	VESSEL	OPERATING PATTERN	DATE MEDICAL CERTIFICATE REQUIRED	VALID CERTIFICATE
1.	FV of any length	Subject to inspection in a foreign port	31 May 2019	ENG 1
2.	FV of 24m in length and over	At sea for more than 7 days	31 May 2019	ENG 1
3	FV 24m in length and over to which 1. and 2. do not apply	N/A	30 November 2019	ENG 1
4	FV under 24m in length	At sea for more than 72 hours	30 November 2019	ENG 1
5.	FV under 24m in length	Operating more than 200 miles from the coastline of the UK or beyond the Continental shelf	30 November 2019	ENG 1
6.	FV over 10m but under 24m in length to which 1., 4. and 5. do not apply	N/A	30 November 2023	ENG 1/ML52
7.	New entrants on Fishing vessels under 24m in length to which 1, 4 and 5 do not apply	N/A	30 November 2023	ENG 1/ML52
8.	Existing fishers on fishing vessels of 10m or less, to which 1, 4 and 5 do not apply	N/A	No medical required as of 27 March 2024	as per MSN 1915

3. Statutory Standards of medical fitness for all seafarers and fishermen (MLC 2010 Regulations reg 8(1)(d); FV 2018 Regulations reg 5)

3.1 Approved Doctors are required to determine a candidate’s fitness by reference to the statutory medical and eyesight Standards set out in Annex A to this Notice (also available to download from the Government site https://www.gov.uk/topic/ships-cargoes/m- notices). The Standards provide for flexibility to reflect relative risk; this enables Approved Doctors to take some account of particular circumstances, such as distance from medical care, and normal duties and requirements for crew members.

3.2 Candidates for an ML5 (MSF 4112) medical certificate are also subject to the medical and eyesight standards at Annex A.

Medical fitness Standards

3.3 It is clearly not possible to cover every medical condition within the specified Standards. As a general principle the Approved Doctor should be satisfied in each case that no disease or defect is present which could either be aggravated by workingat sea or represent an unacceptable risk to the health of the candidate, the health or safety of other crew members or the safety of the ship.

3.3.1 Apart from the purely medical aspects, the occupational circumstances which apply at sea should be fully considered, especially in any borderline case. Particular factors which should be taken into account are:

a) the potentially hazardous nature of working at sea and fishing, which call for a high standard of health and continuing fitness;

b) the restricted medical facilities likely to be available at sea. Few ships carry doctors, medical supplies are limited and unless a ship is in port there will be delay before full medical treatment is available;

c) the possible difficulty of providing/ replacing required medication. As a rule, a candidate should not be accepted for service if the loss of a necessary medicine could precipitate the rapid deterioration of a medical condition;

d) the confined nature of life on board ship and the need to be able to live and work in a closed community;

e) the limited crew complements which mean that illness of one crew member may place a burden on others or impair the safe and efficient working of the ship;

f) the potential need for crew members to play a role in an emergency or emergency drill, which may involve strenuous activity in adverse conditions;

g) in case crew members need to join and leave ships by air, they should be free from any condition which precludes air travel or could be seriously affected by it, such as pneumothorax or conditions which predispose to barotrauma.

3.3.2 The Approved Doctor should be satisfied that no condition is present which is likely to lead to problems during the voyage and no treatment is being followed which might cause adverse side effects. It would be unsafe practice to allow a candidate to go to sea with any known medical condition where there was the possibility of serious exacerbation requiring expert treatment. Where medication is acceptable for working at sea, the individual should arrange for a reserve stock of the prescribed drugs to be held in a safe place, with the agreement of the ship’s master.

Eyesight Standards

3.4 The Approved Doctor must also ensure that the candidate meets the visual acuity and colour vision Standards. The UK’s Standards for visual acuity comply with the international standards laid down in the IMO Convention on the Standards of Training, Certification and Watchkeeping (STCW 78 as amended). Candidates will be tested for each eye separately and must meet both the higher standard required with visual aids (where needed), and a minimum standard without visual aids, in order to ensure that in an emergency they have adequate vision to carry out emergency procedures safely. For colour vision, candidates are screened using Ishihara plates. It is essential that candidates applying for Certificates of Competency as deck or dual career (merchant/fishing) officers have full colour vision.

A deck applicant who fails the Ishihara plate test may arrange for their colour vision to be re-tested at an MCA approved CAD test centre (listed at Annex B). The CAD test centre will charge a fee for the CAD test, which is payable directly to the test centre. Failure in this test will mean that a medical certificate may only be issued with a restriction precluding lookout duties at night. Trainee Deck officers however will be made permanently unfit. Other deck candidates applying for their first MCA Certificate of Competency (CoC), Able Seafarer Deck Certificate of Proficiency or Rating Certificate who have failed the Ishihara plate test will only be considered if they have subsequently passed the MCA Holmes Wright B (HWB) lantern test orCAD test and hence carry no restriction on their seafarer medical certificates precluding lookout duties.

• existing deck seafarers who have failed the Ishihara plate test but passed the MCA HWB lantern test and have evidence of this will still be considered to meet the colour vision standards and do not need to undertake a CAD test.

• existing deck seafarers who have failed the Ishihara plate test and passed the HWB lantern test but do not have evidence of this will need to take the MCA CAD test. If they do not take the test, or fail it, they may continue working in their current roles. They will be given an ENG 1 noting that they do not meet the colour vision standards with an appropriate restriction.

• existing deck seafarers who wish to qualify for an MCA CoC for the first time, or a higher CoC, will have to meet the colour vision standards (i.e. Ishihara plates or MCA CAD test passed, or provide evidence that they have previously passed the MCA HWB lantern test). Their seafarer medical certificate must not have any restriction on lookout duties.

Categories of medical fitness

3.5 The following categories are applied in assessing whether or not a candidate is fit in terms of the medical and eyesight standards:

Category 1:    Fit for sea service, with no restrictions

Category 2:    Fit for sea service but with restrictions

Category 3:    Temporarily unfit for sea service. The Approved Doctor must specify the duration of the period of unfitness.

Category 4: Permanently unfit for sea service. This category will normally be considered to last for a minimum of five years and may only be changed at a later date if an Approved Doctor is presented with medical evidence of the reversal of the original medical condition. Review by a medical referee may also be required.

3.5.1 Restrictions: The Approved Doctor may issue a “Fit” certificate with restrictions on the geographical locations or duties in which the candidate is medically fit to work at sea – for example, the restriction “not fit for emergency duties” where the candidate has physical fitness limitations. This restriction will be written on the face of the ENG 1 certificate, and is a notification to any shipowner, employer, the master, and to the issuing authority for any Certificate of Competency issued. There are a small number of restrictions which may preclude the issue of certain certificates of competency. MCA will advise.

3.5.2 Conditions: The Regulations also provide for the Approved Doctor to set conditions for the issue of a medical fitness certificate. A condition is a formal notification from the Approved Doctor to the candidate of measures that must be taken in order for their medical fitness to be maintained. This should be put in writing but should not be written on the ENG 1 certificate since it should be confidential between the doctor and the candidate. It will however, on occasion, be necessary for the candidate to make their employer or master aware of the condition agreed, for example where the candidate is required to take regular medication which must be carried on board.

Issue of ENG 1 medical certificate (MLC 2010 Regulations reg 8, FV 2018 Regulations reg 6)

3.6 If the Approved Doctor considers the candidate is fit to perform the duties they are to carry out and meets the medical and eyesight Standards, the Approved Doctor will issue a medical fitness certificate (form MSF 4104 known as the ENG 1) under Category 1 or 2.

3.6.1 If the Approved Doctor considers the candidate is temporarily unfit for a period of more than three months (Category 3) or permanently unfit (Category 4) or issues any certificate subject to a restriction (Category 2), they must issue the candidate with a Notice of Failure/Restriction (form MSF 4106), known as the ENG 3. The period of unfitness may range from a few weeks (e.g. to allow simple investigations to be undertaken) to a year or more (e.g. pending treatment). The candidate may use the ENG 3 to apply for a review of the Approved Doctor’s decision (“appeal”). However, candidates considered temporarily unfit (Category 3) for a period of 3 months or less do not have a right of review.

3.6.2 The Approved Doctor should normally explain to the candidate the medical reasons for the refusal of a certificate or the inclusion of a restriction, as this will help the candidate to understand whether to apply for a review of the decision. (The exception would be if the Approved Doctor considers that such disclosure would be harmful to the candidate’s health.)

Replacement certificates (MLC 2010 Regulations reg 17/FV 2018 Regulations reg 13)

3.6.3 Once issued, the ENG 1 certificate is the property of the candidate. If a certificate is lost or damaged, the Approved Doctor who issued the original certificate may be asked, at their discretion, to issue a replacement certificate. The replacement certificate will be valid for the remaining validity of the original certificate.

3.6.4 The Approved Doctor may make an administrative charge for a replacement certificate. They will notify MCA of the candidate’s name, date of birth and the serial number of the original ENG 1 and the new certificate issued.

3.6.5 However, if a significant period of time has passed since the medical examination was carried out, the Approved Doctor may consider that a new examination is required so that they can issue a new certificate, which may be valid for up to two years, in which case the full statutory fee for a medical examination will be payable.

3.6.6 Only the Approved Doctor who issued the original certificate can issue a replacement without conducting a full examination.

Validity of ENG 1 (MLC 2010 Regulations reg 9/FV 2018 Regulations reg 7)

3.7 The medical fitness certificate will specify the date that the medical examination was carried out and the expiry date of the certificate. Under the Regulations, the maximum validity period for any person over 18 is 2 years, and for candidates under 18 years old, 1 year. If there is a medical reason, an Approved Doctor may issue a certificate valid for a period of less than 2 years.

4. Suspension and cancellation of a certificate (MLC 2010 Regulations reg 13/FV 2018 Regulations reg 10)

4.1 If an Approved Doctor has reasonable grounds for believing that:

a) there has been significant change in the medical fitness of a person while holding a valid certificate; or that

b) the person is not complying with the terms of a condition of issue of the certificate; or that

c) they did not have full details of the person’s condition at the time of examination, and if they had done so he could not reasonably have considered that the seafarer met the required standards; or that

d) the medical fitness certificate was not issued in accordance with the Regulations; the Approved Doctor may suspend or cancel the certificate.

4.2 The certificate may be suspended until the person holding it has undergone a further medical examination, or for a specified period, or permanently cancelled, depending on circumstances. The Approved Doctor has the right under the Regulations to require the holder to surrender their medical certificate, and if it is not returned may inform the MCA’s Medical Administration Team, who will take appropriate action.

4.3 A person whose medical fitness certificate is suspended for more than three months or cancelled has a right of review (“appeal”) of that suspension or cancellation.

5. Application for a review (“appeal” – MLC 2010 Regulations reg 14; FV 2018 Regulations reg 11)

5.1 Any candidate (including any person applying for their first ENG 1) found permanently unfit (Category 4), temporarily unfit (Category 3) for over 3 months, or fit only for restricted service (Category 2), or whose certificate is cancelled or suspended for more than 3 months by an Approved Doctor, has a right of review by an independent medical referee appointed by the Secretary of State for the Department for Transport.

5.2 There is no right of review against a condition set by an Approved Doctor (see paragraph 3.5.3) or against a decision of temporary unfitness (Category 3) for 3 months or less.

5.3 If the candidate wishes to apply for a review, they should be advised to complete the application form which forms part of the Notice of Failure/Restriction (ENG 3) which will be issued by the Approved Doctor and send it to the MCA’s Medical Administration Team at the address at the end of this Merchant Shipping Notice. The application should be made within one month of the date of the Notice of Failure/Restriction (ENG 3). The MCA’s Medical Administration Team will then arrange for the decision to be reviewed by a medical referee.

5.4 In signing the application for review, the candidate is also giving consent for the Approved Doctor to release his or her ENG 2 report form and any other information provided to the Approved Doctor (including supplementary medical reports, GP letters, or any other information that led to the Approved Doctor’s decision) to the Medical Referee. If the candidate wishes to submit additional medical evidence in support of their application they should be advised to arrange for this to be sent to the Medical Referee before the appointment date.

5.5 The role of the medical referees, who work to the same medical and eyesight Standards as the Approved Doctor, is:

• to ensure that the diagnosis has been established beyond reasonable doubt, in accordance with the medical evidence on which the Approved Doctor reached their decision and, if necessary with the assistance of a report from a Consultant in the appropriate specialty,

• to determine whether the medical and eyesight Standards, especially those with a discretionary element, have been properly interpreted; and

• to consider the possibility of a person previously declared permanently unfit returning to sea in some capacity.

5.6 Where a medical referee has determined that a candidate is permanently unfit to go to sea, MCA will not normally allow a further application for review from that person within five years of that determination.

5.7 In cases not specifically covered by the statutory medical and eyesight Standards, or in cases where the Approved Doctor has assessed the candidate as “permanently unfit” and exceptional medical considerations apply, the medical referee may decide an appropriate fitness category after obtaining relevant information from the Approved Doctor who made that assessment and any further evidence presented to them.

5.8 The medical referee should reach a decision within 2 months of the date on which the review was lodged with the MCA. If there is a reason for the decision to take longer, this must be agreed with the MCA.

5.9 The Chief Medical Adviser of the MCA must be notified of the result of the review on form MSF 4109. An anonymised report of each case will be subject to peer review each year, for quality assurance purposes.

6. MCA Approved Doctors

6.1 Medical practitioners approved by the MCA to carry out statutory medicals for seafarers and fishermen must meet the following minimum criteria:

• if based in the United Kingdom, be fully registered with the General Medical Council of Great Britain and hold a valid Licence to Practice;
• if based outside the United Kingdom,

a) be qualified from one of the medical schools listed in the Avicenna Directory (see The World Directory of Medical Schools );

b) be entitled to practise in the country or territory in which that practitioner is based;

c) satisfy the MCA that they are subject to a programme that ensures maintenance of their medical skills;

d) have a good command of the English language.

6.2 For further information about approved doctors, see Annex C to this notice.

7. Records to be kept by the approved doctor

7.1 The Approved Doctor is required to keep full clinical notes of any detailed medical examination, and records including a completed medical report form (ENG 2) must be retained for 10 years. Any records relating to health surveillance under the terms of the Merchant Shipping (Health and Safety at Work) Regulations 1997, and related legislation must be retained for up to 40 years. Approved Doctors are also required to send statistical returns to the MCA on examinations carried out. These statistics are published by the MCA. Form MSF 4103 must be used for this purpose. MCA will supply the form when requesting the return. These records may be subject to clinical and administrative audit by the MCA to ensure that Approved Doctors are following MCA medical Standards and procedures correctly.

8. References to this Notice in the Merchant Shipping (Maritime Labour Convention) (Medical Certification) Regulations 2010 (as amended)

8.1 Regulation 2: The qualifications required by a medical practitioner, as defined in regulation 2, to apply to be approved to conduct seafarer medical examinations are specified in section 6.

8.2 Regulation 8(1)(d), regulation 12(3) and regulation 13(1)(c): The medical Standards specified by the Secretary of State to which a medical practitioner must have regard when examining a seafarer in accordance with the Regulations are those set out in Annex A. Guidance on the application of those standards is given in Section 3 of this notice.

8.3 Regulation 14(5), (6) and (7): The medical Standards specified by the Secretary of State to which a medical referee must have regard when examining a seafarer in accordance with the Regulations are those set out in Annex A. The form of a medical fitness certificate is specified in paragraph 3.6.1.

8.4 Regulation 16(2): The forms to be used by medical practitioners and medical referees in keeping records and making returns required by regulation 16(1) (in respect of medical examinations and reviews) are specified in paragraph 7.

9. References to this Notice in the Merchant Shipping (Work in Fishing Convention) (Medical Certification) Regulations 2018

9.1 Regulation 6(1)(d), regulation 9(1)(c) and 10(1)(c): The medical Standards specified by the Secretary of State to which a medical practitioner must have regard when examining a seafarer in accordance with the Regulations are those set out in Annex A. Guidance on the application of those standards is given in Section 3 of this notice.

9.2 Regulation 11(5), (6) and (7): The medical Standards specified by the Secretary of State to which a medical referee must have regard when examining a seafarer in accordance with the Regulations are those set out in Annex A. The form of a medical fitness certificate is specified in paragraph 3.6.1.

9.3 Regulation 12(2): The forms to be used by medical practitioners and medical referees in keeping records and making returns required by regulation 12(1) (in respect of medical examinations and reviews) are specified in paragraph 7.

10. More information

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

Telephone: +44 (0)203 81 72835

Email: seafarer.sh@mcga.gov.uk

Website: www.gov.uk/mca

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