MLC 2006 work-rest hours for superyacht crews — a practical checklist

Every superyacht flying a Maritime Labour Convention (MLC 2006) flag has to demonstrate that its crew are getting the minimum rest the convention requires. Nobody objects to the principle. What catches yachts out is the record-keeping — especially in the heat of a charter season when hours drift, entries get patchy, and the port state control (PSC) boarding notice arrives on a Tuesday morning with the audit set for that afternoon.

This is a practical checklist. It covers what MLC 2006 Regulation 2.3 actually requires, the two hard hour limits, the pitfalls that show up on yacht rotations specifically, and the shape of the evidence PSC inspectors expect to see.

What MLC 2006 Regulation 2.3 requires

The Maritime Labour Convention establishes minimum rest periods for seafarers. Every crew member must receive either minimum hours of rest or maximum hours of work — the flag state chooses which framework applies, and the yacht records accordingly. Most superyacht flag states (Marshall Islands, Cayman, Malta, UK Red Ensign) use the rest-hours framework.

The two limits

Under the rest-hours framework, a crew member is entitled to:

• At least 10 hours of rest in any 24-hour period. These 10 hours may be split into no more than two periods, one of which must be at least 6 hours in length, and the interval between consecutive periods of rest must not exceed 14 hours.
• At least 77 hours of rest in any 7-day period. Averaged across a rolling 7-day window; not a calendar week.

A yacht recording work hours instead of rest hours computes the complement: no more than 14 hours of work in 24 hours, and no more than 91 hours of work in 7 days.

Common pitfalls on superyachts

Every seasonal yacht encounters the same handful of edge cases. They’re not always violations — but if they’re not recorded and documented, they read like violations to a PSC inspector.

1. Charter turnovers that overrun

Guests off, cabin turnover done, provisioning aboard, and the stew’s day-off starts — but a broken washing machine or a re-provisioning trip breaks the rest window. The hour is recorded honestly, but no exception note is attached, so the rolling 7-day total silently drops below 77.

2. Rotation crew arriving mid-passage

Rotation crew fly in and immediately stand watch. The MLC rest-hour clock resets on arrival — if the previous vessel or airline travel is not treated as work, the first 24-hour window looks abnormally low on rest.

3. Emergency call-outs

A generator alarm at 03:00 pulls the second engineer out for two hours. Rest is broken; the window is not compliant. This is specifically permitted under MLC 2006 as an emergency exception, but it must be recorded as an exception with the reason.

4. Anchor watch on the Med run

Deck crew who are “on standby” but not actively engaged — the yacht records them as resting. If the PSC inspector asks whether they were actually free to sleep, the answer needs to match the log.

5. Extended day of departure

Guests board at 18:00, dinner service runs to 01:00, tender wash-down finishes at 02:30. If nobody records the extended day with a properly signed non-conformance note, it just looks like a failed compliance day.

What PSC inspectors actually look for

A PSC inspector under MLC verification will ask for the work-rest record for a representative period (usually the previous 30 days), for one or two selected crew members. What they expect:

• Per-crew records, not aggregated ones. An exception flagged on the deckhand is not an exception on the engineer.
• Signed by the crew member. A record without a signature is a piece of paper, not a record. Digital signatures are accepted as long as they attribute an individual crew member.
• Exception notes for non-compliant days. A day that dips below 77 hours in the 7-day window is not automatically a violation — but it needs an attached note explaining why (emergency, guest embarkation, generator incident, whatever) and evidence that master’s review took place.
• A rolling 7-day view, not a calendar-week view. Inspectors know the difference. Yachts that show a calendar- week Excel are told to come back with a rolling view.
• Master’s review. The captain has reviewed the exceptions, agreed the crew was in fact well-rested or that corrective action is planned, and countersigned. This is what demonstrates the yacht is managing compliance, not just recording data.

A practical monthly checklist

Run through this at the same time you close the month’s accounting:

• Every crew member has 30 days of daily entries. No gaps — gap means “didn’t work,” and PSC will ask why a crew member was on the yacht but not working.
• Every daily entry is signed. Unsigned entries are not evidence.
• Every day flagged non-compliant has an exception note attached. Note has the reason, the person who authorised the exception, and the corrective action (if any).
• The 7-day rolling total is visible and computed correctly. Not a calendar-week sum.
• Master has reviewed and countersigned exceptions.
• The month’s summary can be exported as a signed PDF suitable for handing to a PSC inspector without further work.

What this looks like in MYACHT

MYACHT’s watchkeeping and work-rest module handles all of the above out of the box — per-crew logs, work-rest auto- computation, exception flagging with attached notes, rolling 7-day view, master’s review workflow, and a PSC-format PDF export. The exports are the same shape inspectors are used to seeing; you can see the pattern on our sample exports page, or read more about the compliance module on the modules index.

Compliance is not the point of running a yacht. Being ready when you’re boarded is.