Owners of UK-flagged fishing vessels are responsible for basic health and safety on board their boats, safe working practices and safety equipment.
The Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 includes measures to encourage improvements in the safety and health of workers at sea. Owners must also ensure their crews follow safe working practices and that all equipment on board is properly installed and maintained.
This guide explains health and safety provisions and how to ensure crew working practices are safe by complying with regulations for safe manning levels and working times. You will also find information on the safe use and maintenance of work equipment and fishing gear, as well as emergency and lifesaving equipment.
The guide also outlines risk assessment of hazards and provides a list of organisations that can supply further information on safe working practices for fishing vessels.
Fishing vessel health and safety
Under the Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 Regulations, it is your duty to protect the health and safety of workers and others affected by their activities. MGN 587 (F) Amendment 1 contains information and guidance on responsibilities of the fishing vessel owner (which includes the manager), skipper and all fishermen for health and safety on board UK fishing vessels.
There are certain fundamentals you can follow to ensure health and safety on a fishing vessel, for example:
- risk avoidance - combating risks at source by replacing dangerous practices, substances or equipment with less or non-dangerous ones
- risk evaluation - taking action to reduce unavoidable risks
- individual work patterns and procedures - workplace design and equipment to alleviate monotonous work
- procedural adaptation - using new technology and other changes to improve working practices, equipment and the working environment
- vessel management - logical approach that takes account of health and safety at every level
- protective measures - prioritise collective measures over individual
- training and information - appropriate and relevant for all workers
Safe watchkeeping, navigation and avoiding accidents
Fishing vessel operators should follow recommendations on keeping a safe navigation watch.
Keeping watch on fishing vessels
The requirements are set out in the MCA document, MGN 313 (F) - keeping a safe navigational watch on fishing vessels.
Safety recommendations for watchkeeping include the following provisions:
seafarers keeping watch must be competent to do so
a proper lookout must be kept at all times
lookouts must be capable of checking the vessel’s position
activities of all other vessels in the area should be monitored
seafarers should have had enough rest before a watch
television and similar distractions should not be available to crew on watch
Wheelhouse visibility safety requirements are specified in the MCA’s MGN 314 (F) document, wheelhouse visibility onboard fishing vessels.
Safety principles for wheelhouse visibility for fishing vessels include:
- as little obstruction as possible to wheelhouse view from bow structures
- clear view ahead from steering position for all new fishing vessels
- arrangements to improve visibility where necessary - eg through use of lookouts
- taking account of effects of ice and fishing gear on forward visibility
Navigation in restricted visibility conditions
Safety requirements for navigating fishing vessels in conditions of reduced visibility are set out in the MCA document MGN 369 (M+F) Navigation in restricted visibility.
The recommendations include guidance on:
- proper conduct of vessels in restricted visibility conditions
- determining risk of collision in close quarters
- correct avoiding actions
- compliance with steering and sailing rules
- determining safe speeds and a close-quarters situation in conditions of restricted visibility
Electronic navigation equipment should not be relied upon exclusively. Navigators should cross-check position-fixing readings using other methods, and be aware of factors affecting the accuracy of the equipment. MGN 379 (M+F) Navigation: use of electronic navigation aids provides more information about the correct use of navigational equipment by watch-keepers.
Automatic Identification Systems (AIS) for Fishing Vessels
All fishing vessels of 15m length overall must fit AIS which shall meet IMO performance standards (Class A).
IMO Resolution A.1106(29) “Guidelines for the on-board use of Automatic Identification Systems” contains further information on the use of AIS.
AIS shall remain on and operational at all times and may only be switched off where the skipper considers this necessary in the interests of the safety and security of the vessel. It is an offence to switch off AIS unless the safety and security of the vessel would be affected.
The regulations which set out this requirement for fishing vessels are the Merchant Shipping (Vessel Traffic Monitoring and Reporting Requirements) (Amendment)Regulations 2011.
These Regulations amended the Merchant Shipping (Vessel Traffic Monitoring and Reporting Requirements) Regulations 2004.
Further information on AIS requirements for fishing vessels can be found here.
Avoiding accidents from fatigue or overwork
Fishing vessel operators can reduce the chance of accidents on vessels caused by fatigue or overwork.
Causes of fatigue among fishing crews include:
- frequent port turnarounds
- regular 12 hours or more working days
- adverse weather conditions
Reduced concentration and performance are among the physical effects of fatigue.
Vessel operators should know how to detect signs of fatigue - such as changes in mood and alertness. Practical measures to alleviate the problem include drinking water, regular breaks and taking naps.
Working time regulations for sea fishermen
Safety regulations governing working time regulations for fishing vessel crews are summarised in the MCA document MSN 1884 ILO work in fishing convention working time.
The regulations include:
- working time of a seafarer not to exceed 48 hours in a seven-day period, averaged over 52 weeks
- rest hours should not be less than ten hours per 24 hour period, or 77 hours per week
- seafarers should have at least four weeks’ annual leave
- exceptions may be made for technical or operational reasons, eg in emergencies
Special arrangements should be made for seafarers on night duties, eg:
- entitlement to free health assessment
- organisation of rest breaks
- keeping a record of hours worked and breaks taken
Protecting the crew
Fishing vessel operators must follow regulations on the safe use of work equipment. The regulations also apply to all self-employed persons on fishing vessels. Guidance on how to comply with the merchant shipping and fishing vessel regulations on work and lifting equipment can be found on the MCA website.
Lifting and non-lifting equipment
Lifting equipment on board vessels is covered by the Lifting Operations and Lifting Equipment (LOLER) regulations. You can find out more information in MGN 332 (M+F) Amendment 1 Lifting operations and lifting equipment and MGN 619 Information on the application of LOLER and PUWER for fishing vessels.
Fishing vessels are not classed as work equipment - except where parts of their structure support lifting equipment or form part of it. Such parts must be assessed under these regulations.
Non-lifting tools, machinery and equipment used at work are covered by the Provision and Use of Work Equipment (PUWER) regulations. You can find out more information in MGN 331 (M+F) Amendment 1 Provision and use of work equipment.
Non-lifting equipment used on fishing vessels must be:
- suitable for the work being carried out
- adapted for purpose
- capable of being used by workers without risk to their health and safety
- accompanied by an instruction manual, if CE marked
Fishing vessel operators must arrange regular inspections of equipment, to determine whether seafarers face health and safety risks, for example from component failure.
The inspections should take place often enough to pick up any deterioration caused by exposure of the equipment to adverse conditions.
Lifting equipment must be inspected:
- after installation and before first use
- after assembly at a new site or location
- every six months for equipment designed to lift people
- every 12 months for other lifting equipment
Protective equipment regulations for seafarers are listed in MSN 1870 Amendment 2 Personal protective equipment standards.
General advice on the supply and use of working and protective gear (personal protective equipment (PPE)) on fishing vessels can also be found in MGN 311(F): Working and protective gear for fishermen.
The regulations make it compulsory for seafarers to use personal protective equipment (PPE) - whether provided by the vessel operator or belonging to the seafarer - during work operations involving risk.
Design standards for PPE are also set out in this guidance, together with recommendations on storage and maintenance.
Seafarers employed on fishing vessels must be trained in how to use PPE consistent with their duties.
Owners also have a responsibility to build PPE use into risk assessments of working practices. PPE, (with the exception of PFDs, see below) should, for example, only be used if risks identified by risk assessment cannot be reduced to acceptable levels.
Use of personal flotation devices (PFDs) unless the risk of going overboard has been eliminated.
Fishing vessel crews must wear personal flotation devices (PFDs) at all times while on open deck at sea unless they have conducted a written risk assessment and eliminated the risk of going overboard. Guidance on acceptable PFDs is contained in MSN1870 Amendment No.2. Lifejackets and PFDs should be regularly checked to ensure they are still functional.
Note: PFDs worn around the waist that require a secondary donning action are not acceptable.
Protecting fishermen from noise, vibration and hazardous substances
Safety regulations exist to protect fishing vessel crews from noise and exposure to dangerous goods carried on board.
Exposure to noise
Fishing vessel operators must comply with control of noise at work regulations, covering areas such as:
- daily noise exposure levels
- exposure limit levels - daily and weekly
- health surveillance of crew hearing
- impulsive noise - eg noises of short duration, occurring irregularly.
Operators also have a duty to control noise on vessels, as explained in the MCA document MGN 352 (M+F) Amendment 1 control of noise at work regulations 2007. The regulations include:
- derogations for ships on public service, eg search and rescue
- risk assessments identifying sources of noise, level of risk and steps required from employers to reduce the risk to crew
- providing hearing protection equipment for crew
- crew information and training procedures on minimising the risk from noise
Protection from exposure to hazardous substances
Safety regulations to protect fishing vessel crews from exposure to carcinogens and mutagens are listed in the MCA document MGN 624 (M+F) Health and safety at work (carcinogens and mutagens).
The regulations include advice on:
- risk assessments required by employers for exposure to carcinogens and mutagens
- definitions of carcinogens and mutagens
- rules surrounding exposure to radiation
- health risk assessment of crew - especially those at high risk
- measures to prevent or reduce exposure
Exposure to carbon monoxide
Carbon monoxide detectors are mandatory on all fishing vessels, for information please download the following codes:
|Length category||Code of Practice|
|Fishing vessels of less than 15m Length Overall||Code of Practice for Small Fishing Vessels of less than 15m Length Overall and the accompanying MSN 1871 (F) Amendment 2.|
|Fishing vessels of 15m length overall to less than 24m registered length vessels||MSN 1872 Amendment 1: Safe working for construction and use of fishing vessels|
|Fishing vessels of 24m registered length and over||The Code of Practice for the Construction and Safe Operation of Fishing Vessels of 24m Registered Length and Over (MSN 1873 Amndt 1 (F))|
The MCA has issued a safety alert, warning operators and crews to be aware of the dangers of carbon monoxide (CO) poisoning on fishing vessels.
Petrol generators on board vessels should be checked to ensure:
- the equipment provides enough power for accommodation and lighting
- ventilation for the generator is adequate (more is needed for burners and stoves)
- alarms are fitted to warn sleeping crewmembers of the risk of CO poisoning
- escape routes are available for the crew in an emergency
Protection from vibration in equipment
Operators must take carry out risk assessments of hazards associated with vibration in equipment and introduce procedures to protect crews. Safety requirements to protect seafarers from vibration are set out in the MCA document MGN 353 (M+F) The Merchant Shipping and Fishing Vessels (Control of Vibration at Work) Regulations 2007.
MGN 353 contains information about controlling the symptoms, causes and management of the risk of Hand-Arm Vibration (Annex A) and Whole-Body Vibration (Annex B).
The Code of Safe Working Practices for Merchant Seafarers Chapter 12.16 also provides details on health surveillance and health monitoring regarding vibration.
There are special safety regulations governing trawling procedures - and also for fishing vessels operating outside British ports, and in submarine exercise areas.
Marking fishing gear
For guidance on the marking of fishing gear, retrieval and notification of lost gear please read this guidance from the Marine Management Organisation.
Safety requirements for trawling are listed in MGN 415: Fishing vessels: the hazards associated with trawling, including beam trawling and scallop dredging.
Hazards of trawling include:
- equipment failure
- snagging of gear and loss of stability
To minimise trawling hazards, vessel operators should ensure:
- crew familiarity with trawling equipment and procedures
- closure of weathertight doors when not in use
- procedures are in place for recovering fouled gear
Operating outside European ports
Fishing vessels operating outside European ports should follow the safety guidance in the MCA document MGN 414: Fishing vessels - overseas management.
Operators can face difficulties operating outside familiar European ports, for example off the west coast of Africa. Difficulties can include access to spares, repair facilities and technical support.
Measures owners can take to improve crew safety in these areas include:
- ensuring vessel surveys are up to date
- introducing a management system to monitor and help vessels operating outside European waters
- having a strategic plan - eg controlling the use of resources and contingencies for unexpected departures from operating plans
- clearly establishing the authority of the master with the owner before departure
- making provision for repairs - including on-board repairs using spares and possible local repairs arranged by a local agent
- ensuring all equipment is well maintained and that crews are familiar with operating procedures
Operating in submarine exercise areas
Fishing vessels operating in submarine exercise areas should be familiar with the safety guidance in the MCA document MGN 12 (F) Fishing vessels operating in submarine exercise areas
Operators of vessels in such areas should be familiar with the measures taken by the Royal Navy (RN) to minimise risks to fishing vessels, eg:
- SUBFACTS radio broadcasts, identifying exercise areas through broadcasts on frequencies specified in the Admiralty List of Radio Signals (ALRS)
- submarine commanders’ code of practice for dived submarines to reduce risk to fishing vessels through avoidance strategies
- use by the RN of a fishing vessel safety ship (FVSS) during exercises If a fishing vessel experiences a total power failure in a submarine exercise area - and is therefore silent and undetectable to submarine sonar - operators should alert the Coastguard immediately. They should also consider marking and releasing fishing gear for later collection.
The MCA has issued supplementary guidance to the submarine exercise areas which can be found in MGN 12(F) Amendment 1.