MLC 2006 Amendments: Seafarer Welfare, Internet Access, Food, PPE and Fair Treatment
An overview of the 2022 Maritime Labour Convention amendments effective from 23 December 2024, the Joint ILO–IMO Guidelines on fair treatment of detained seafarers, and practical compliance considerations for shipowners, Masters and maritime technical managers.
Regulatory Background: MLC Amendments and Fair Treatment of Seafarers
The Maritime Labour Convention, 2006 (MLC, 2006) establishes international minimum requirements for seafarers' working and living conditions, including employment, accommodation, food, health protection, welfare and repatriation.
Amendments adopted in 2022 entered into force on 23 December 2024. They address several areas of seafarer welfare, including social connectivity, food and drinking water, onboard complaints, medical care, repatriation and other protections. The requirements applicable to a particular ship depend on the relevant Convention provisions, the flag Administration and applicable national implementation.
A separate international instrument, the Joint ILO–IMO Guidelines on Fair Treatment of Seafarers Detained in Connection with Alleged Crimes, addresses the treatment of seafarers facing criminal investigation or detention in a foreign jurisdiction. These guidelines provide recommendations for fair treatment and due process; they are not themselves a new binding convention.
For shipowners, operators, Masters and technical managers, the practical task is to distinguish mandatory MLC requirements from non-binding guidance, recommendations and other applicable national laws or international instruments.
1. Fair Treatment of Seafarers Detained in Connection with Alleged Crimes
Seafarers may face criminal investigation or detention following maritime casualties, pollution incidents, collisions, cargo events or other alleged offences. The Joint ILO–IMO Guidelines on Fair Treatment of Seafarers Detained in Connection with Alleged Crimes provide an international framework for addressing their treatment and procedural rights.
The guidelines are intended to promote fair treatment, respect for human rights and due process. Their recommendations should be read alongside applicable domestic law, consular arrangements, relevant international obligations and the circumstances of the particular case.
Due Process and Legal Representation
Seafarers should be treated fairly and in accordance with applicable law. Access to legal representation, interpretation, consular assistance and other procedural safeguards should be addressed in accordance with the relevant legal framework.
Notification and Communication
Relevant authorities and responsible parties should follow applicable notification requirements and the guidelines' recommendations concerning communication with the flag State, home State, shipowner and appropriate welfare representatives.
Evidence Preservation
Prompt collection and preservation of relevant evidence can support a fair investigation and may help reduce unnecessary prolonged detention. Interviews and evidence gathering must follow applicable legal safeguards.
Welfare and Subsistence
Food, accommodation, medical assistance and other subsistence arrangements should be addressed under applicable law, contractual obligations and relevant guidelines. Responsibility for wages and expenses depends on the circumstances and governing requirements.
Family and Welfare Support
Communication with family members and access to appropriate welfare support are important considerations. Visitation arrangements remain subject to applicable law, detention conditions and the relevant authorities' procedures.
Avoiding Unnecessary Delay
The guidelines encourage timely proceedings and appropriate evidence-gathering arrangements. Decisions about detention and release remain matters for the competent authorities under the applicable legal system.
Practical Considerations for Shipowners and Operators
- Establish an incident-response procedure for cases involving seafarers detained or investigated abroad.
- Identify the relevant flag-State, consular, legal and welfare contact arrangements.
- Preserve relevant voyage, maintenance, cargo, safety and operational records following an incident.
- Ensure that communications with investigators are coordinated with appropriate legal advice and applicable procedures.
- Review contractual, insurance and applicable legal arrangements concerning crew support, wages and subsistence.
Regulatory distinction: The Joint ILO–IMO Guidelines should not be described as imposing an identical set of directly enforceable obligations on every port State, shipowner or seafarer in every jurisdiction. Their legal effect must be distinguished from binding international instruments and applicable domestic law.
2. Social Connectivity and Internet Access On Board
Social connectivity was an important subject of the 2022 MLC amendments, which entered into force on 23 December 2024. The amendments address seafarers' access to social connectivity and the provision of internet access on board, as far as reasonably practicable, subject to the applicable Convention provisions.
Internet access supports communication with family and friends, access to information and seafarers' wellbeing during extended periods at sea. Implementation must take account of the ship's operating circumstances, connectivity availability, applicable requirements and any permitted charges.
Onboard Internet Access
The applicable MLC provisions address internet access for seafarers as far as reasonably practicable. Shipowners should assess feasible connectivity arrangements and the circumstances affecting their provision.
Reasonable Charges
Internet access may be provided free of charge. Where charges are imposed, they must be reasonable under the applicable requirements. Any charging arrangements should be transparent to seafarers.
Port Connectivity
Access to affordable connectivity in ports can support seafarer welfare. The relevant provisions and guidance should be distinguished from recommendations to improve connectivity at terminals and anchorages.
Cybersecurity and Network Separation
Internet connectivity should be planned alongside shipboard cybersecurity controls. Separation between crew-facing networks and critical operational technology networks is a risk-management measure, not a standalone requirement created by the MLC amendments.
Shipboard Implementation Considerations
- Review the ship's available communication systems and connectivity options.
- Establish a practical onboard internet-access arrangement consistent with the applicable requirements.
- Communicate any permitted charges and access conditions clearly to the crew.
- Consider access arrangements for different crew groups, operating schedules and periods at sea.
- Assess cybersecurity risks associated with crew internet access and maintain suitable separation from critical operational systems.
- Review relevant company procedures and applicable flag-State instructions.
The phrase "as far as reasonably practicable" is important. It should not be interpreted as an unconditional guarantee of continuous, unlimited or free internet access in every operating circumstance.
3. Food, Catering and Drinking Water — MLC Regulation 3.2
MLC Regulation 3.2 and Standard A3.2 address food and catering on board ships. The requirements are intended to ensure that seafarers receive food and drinking water of appropriate quality and quantity, taking account of the number of persons on board, their needs and the circumstances of the voyage.
Under the applicable MLC requirements, food and drinking water must be provided free of charge to seafarers during their period of engagement, subject to the Convention's terms. Catering arrangements must also address nutrition, variety, hygiene and the qualifications of responsible catering personnel.
Free Food and Drinking Water
Food and drinking water must be supplied without charge to seafarers during their period of engagement in accordance with the applicable MLC provisions.
Nutrition and Variety
Food supplies should be adequate, varied and nutritious, with attention to the number of seafarers, the nature and duration of the voyage and applicable dietary needs.
Cultural and Religious Needs
Catering arrangements should take account of the different cultural and religious backgrounds of seafarers and their reasonable dietary requirements.
Hygienic Preparation
Food must be stored, prepared and served under hygienic conditions. Galley cleanliness, food handling and appropriate storage practices are important parts of safe catering management.
Master or Designated Officer Inspections
The applicable MLC provisions require frequent, documented inspections by or under the authority of the Master, addressing food and drinking water supplies, spaces used for their handling and storage, and catering equipment as specified by the Convention.
Catering Personnel
Catering operations should be managed by appropriately trained personnel in accordance with the applicable requirements. Relevant training and hygiene practices should be supported by appropriate records.
Drinking Water Quality and Monitoring
Drinking water safety requires suitable production, bunkering, storage and distribution arrangements. The water must be fit for human consumption, and applicable national, flag-State, public-health and shipboard requirements must be considered.
- Review potable-water production, bunkering and storage arrangements.
- Inspect accessible tanks, distribution systems and associated equipment within the agreed inspection scope.
- Review applicable water-quality records and laboratory results where required or available.
- Establish whether physical, chemical or microbiological testing is required under the applicable standards and circumstances.
- Record deficiencies, corrective actions and follow-up measures in accordance with shipboard procedures.
The MLC requirements should not be taken as prescribing one universal testing interval or identical test panel for every vessel. Testing frequency and parameters depend on the applicable water-quality standards, flag-State requirements, public-health instructions and the ship's water system.
4. Repatriation and Protection of Abandoned Seafarers
MLC Regulation 2.5 and the related provisions address seafarers' right to repatriation and the responsibilities associated with returning seafarers home when the applicable conditions arise. The MLC abandonment framework also addresses cases where shipowners fail to meet specified obligations.
Amendments adopted in 2022 strengthened aspects of seafarer protection and international cooperation. The precise obligations depend on the applicable MLC provisions, the facts of the case, the State concerned and the relevant national implementation.
Repatriation Arrangements
Responsible parties should maintain procedures for identifying repatriation entitlements, coordinating transport and addressing applicable travel and subsistence arrangements.
Abandonment Response
Relevant authorities and other responsible parties should follow the applicable MLC abandonment procedures, including mechanisms for assistance and financial security where required.
Records and Coordination
Accurate employment records, contact details, wage information and repatriation documentation can support timely coordination when a seafarer requires assistance.
Replacement Crew
Any new engagement following an abandonment or other disruption must be handled under the applicable employment, welfare and MLC requirements. Protection depends on the individual circumstances and applicable law.
Practical Company Preparations
- Maintain current crew employment and emergency contact records.
- Identify the company contacts responsible for repatriation and crew welfare.
- Review applicable financial-security arrangements for abandonment and repatriation.
- Establish procedures for communicating with flag-State, port-State, consular and welfare contacts where appropriate.
- Retain records of actions taken and communications relating to crew assistance.
5. Personal Protective Equipment and Health and Safety
MLC Regulation 4.3 and the related Code provisions address occupational safety and health on board ships. The applicable framework requires attention to workplace risks, prevention measures, protective equipment and safe working arrangements.
Personal protective equipment must be suitable for the work and the risks involved. Equipment that is incorrectly sized may compromise protection, mobility, comfort and the ability to perform tasks safely.
Appropriate Fit
PPE selection should take account of the individual seafarer and the intended task. A suitable range of sizes helps ensure that equipment fits the people required to use it.
Task-Specific Protection
Protective equipment should be selected according to the identified hazards, applicable safety procedures and the manufacturer's instructions.
Women Seafarers
PPE arrangements should meet the actual needs of all crew members, including women seafarers. Equipment should not be assumed suitable solely because a nominal size or generic model is available.
Inspection and Replacement
PPE should be checked for damage, deterioration, contamination and fit. Defective or unsuitable equipment should be addressed under the vessel's safety and maintenance procedures.
Practical PPE Verification
- Check whether appropriate sizes are available for the seafarers who need the equipment.
- Verify that PPE is suitable for the identified hazards and intended tasks.
- Review issue, inspection, replacement and training arrangements where applicable.
- Record reported shortages, poor fit or defective equipment and the corrective actions taken.
The MLC regulatory basis is occupational safety and health. The practical requirement for appropriate sizing should be assessed against the applicable provisions, national rules, risk assessment and the equipment concerned rather than described as a separate universal PPE-size table in the MLC.
6. Shipboard Compliance Review and Inspection Preparation
Shipowners, operators and technical managers should maintain procedures that allow applicable MLC requirements to be implemented, monitored and evidenced. The precise scope of inspection depends on the vessel, its flag, applicable certification arrangements and the purpose of the review.
An internal review can help identify missing records, unsuitable onboard arrangements or matters requiring corrective action. It does not replace a required statutory inspection, a competent authority's decision or any formal MLC certification process.
Welfare Procedures
Review procedures for seafarer welfare, communication, complaints, emergency assistance and relevant company responsibilities.
Food and Water Records
Check documented inspections, catering arrangements, potable-water records and the corrective actions associated with identified deficiencies.
Internet and Connectivity
Review the ship's onboard connectivity arrangements, any applicable charges, crew information and associated cybersecurity controls.
PPE and Safety
Examine PPE availability, suitability, condition, sizing, maintenance and the arrangements for reporting shortages or defects.
Repatriation and Abandonment
Verify that relevant contacts, records and procedures are available to support applicable repatriation and crew-assistance arrangements.
Applicable Regulatory References
Identify the relevant MLC provisions, amendments, flag-State instructions, national laws and any applicable inspection or certification requirements.
7. Distinguishing Mandatory Requirements from Guidance
An effective regulatory assessment should identify the legal status of each instrument and avoid treating every recommendation as a directly enforceable statutory obligation.
MLC Convention and Applicable Code
Binding requirements apply through the Convention and its applicable Code provisions, subject to the Convention's scope, ratification, implementation and relevant national law.
2022 MLC Amendments
The amendments entered into force on 23 December 2024. Their specific requirements should be read in the amended Convention and Code rather than inferred from general summaries.
Joint ILO–IMO Fair-Treatment Guidelines
The guidelines provide recommendations for the fair treatment of detained seafarers. They should be considered alongside binding legal obligations, applicable domestic law and relevant procedures.
Cybersecurity Practices
Network separation and related controls should be assessed under applicable cybersecurity requirements, safety-management arrangements and risk assessments. They should not be misrepresented as direct MLC internet-access provisions.
Compliance principle: Before making an operational or statutory decision, consult the current official Convention text, applicable amendments, relevant flag-State instructions and the competent authority's requirements.
8. Practical MLC Welfare Compliance Checklist
The following checklist is a practical planning aid for shipboard management and internal compliance reviews. It is not an official IMO or ILO checklist and does not replace the full MLC text or applicable national requirements.
Seafarer Welfare and Fair Treatment
- Review procedures for responding to seafarer detention or investigation abroad.
- Confirm that appropriate legal, consular and welfare contact information is available.
- Maintain procedures for preserving relevant incident records and evidence.
- Review applicable crew assistance, repatriation and abandonment arrangements.
Social Connectivity
- Review feasible onboard internet and social-connectivity arrangements.
- Check whether any applicable internet charges are reasonable and communicated clearly.
- Assess crew-facing connectivity alongside relevant cybersecurity controls.
Food and Drinking Water
- Confirm that food and drinking water are provided without charge as required by the MLC.
- Review food quantity, variety, nutrition and hygienic preparation and storage.
- Confirm that applicable frequent inspections are documented.
- Review water-quality records and determine whether additional testing is required under applicable standards.
PPE and Occupational Safety
- Confirm that appropriate PPE is available for the work and hazards concerned.
- Check equipment fit, condition and availability for all crew members.
- Record reported defects, shortages and corrective actions.
Documentation and Follow-Up
- Identify the specific MLC provisions and national requirements applicable to the vessel.
- Record deficiencies, responsible persons and agreed corrective actions.
- Retain relevant inspection and compliance records in accordance with applicable requirements.
Official Regulatory References
The following official sources should be consulted to confirm the precise legal provisions and their current applicability. Always check for subsequent amendments, national implementation measures and instructions issued by the relevant authorities.
ILO — Maritime Labour Convention, 2006
The Convention and its applicable Code provide the
primary reference for seafarer working and living
conditions, including food, catering, occupational
safety, repatriation and welfare.
Visit the International Labour Organization
ILO — 2022 MLC Amendments
Consult the official ILO material on the amendments
adopted in 2022 and their entry into force on
23 December 2024, including the amended provisions
and implementation information.
Consult official ILO resources
IMO — Fair Treatment of Seafarers
Consult official IMO Legal Committee and related
publications for information concerning the Joint
ILO–IMO Guidelines on fair treatment of seafarers
detained in connection with alleged crimes.
Visit the International Maritime Organization
Flag Administration and National Law
The relevant flag Administration, port-State authorities and national legal framework should be consulted for implementation requirements, inspection procedures, certification and any applicable additional obligations.
Independent Marine Technical Consultancy
PAMS Pacific Admiralty Maritime Services provides independent marine surveying, technical inspections, engineering consultancy and regulatory compliance support for maritime stakeholders.
Depending on the agreed scope, technical assignments may include vessel condition assessment, inspection of accessible equipment and arrangements, review of relevant technical records, identification of observed discrepancies and preparation of independent technical reports.
MLC compliance involves employment, welfare, administrative and statutory matters that may require the involvement of shipowners, crewing managers, legal advisers, flag Administrations or other competent parties. Any PAMS technical engagement must be limited to the agreed scope and the matters for which the consultancy is competent and authorized.
An independent technical review does not replace statutory inspection, MLC certification, legal representation, prescribed testing or a decision reserved to a competent authority.
Frequently Asked Questions
What is the Maritime Labour Convention, 2006?
The Maritime Labour Convention, 2006 (MLC, 2006) establishes international minimum standards for seafarers' working and living conditions, including employment, accommodation, food, health and safety, welfare and repatriation. Its application depends on the Convention and the relevant national implementation.
When did the 2022 MLC amendments enter into force?
The 2022 amendments to the MLC, 2006 entered into force on 23 December 2024. Shipowners and operators should consult the amended Convention text and applicable flag-State instructions to determine the specific requirements relevant to their ships.
Are the Joint ILO–IMO Guidelines on detained seafarers legally binding?
The Joint ILO–IMO Guidelines provide recommendations concerning the fair treatment of seafarers detained in connection with alleged crimes. They are not themselves a new binding convention. Their application should be considered alongside applicable international obligations, domestic law and the circumstances of the individual case.
Does the MLC require shipowners to provide onboard internet?
The applicable MLC provisions address social connectivity and access to internet facilities on board as far as reasonably practicable. The specific arrangements depend on the Convention provisions and circumstances. The requirement should not be interpreted as an unconditional guarantee of continuous internet service in every situation.
Must onboard internet access be free of charge?
Internet access may be provided free of charge. Where charges are imposed, they must be reasonable under the applicable requirements. Shipowners should make relevant access conditions and charges clear to the seafarers concerned.
Must food and drinking water be provided free to seafarers?
Under the applicable MLC requirements, food and drinking water must be provided free of charge to seafarers during their period of engagement. Food and catering arrangements must also meet applicable requirements for quantity, quality, nutrition, variety and hygiene.
Are food and drinking water inspections required?
The applicable MLC provisions require frequent, documented inspections by or under the authority of the Master, covering food and drinking water supplies and the relevant storage, handling and catering arrangements specified by the Convention. Additional water testing depends on applicable standards and circumstances.
Does the MLC require a specific drinking-water test frequency?
A single universal testing frequency should not be inferred from the MLC alone. The required parameters and frequency depend on applicable water-quality standards, flag-State requirements, public-health instructions and the ship's production, storage and distribution arrangements.
What does the MLC say about repatriation?
MLC Regulation 2.5 and related provisions address the right to repatriation and the responsibilities associated with returning seafarers home when the applicable conditions arise. The relevant Convention provisions, national implementation and individual circumstances determine the precise obligations.
Why is correctly sized PPE important for seafarers?
PPE must be suitable for the work and hazards concerned. Appropriate sizing helps ensure that equipment provides its intended protection and does not unnecessarily restrict movement or safe performance. Equipment selection should address the actual needs of all crew members, including women seafarers.
Is separating crew internet networks from operational technology an MLC requirement?
Network separation is a cybersecurity risk-management measure that may be appropriate to protect critical shipboard operational technology. It should be assessed under applicable cybersecurity requirements and risk management arrangements, rather than presented as a standalone requirement created by the 2022 MLC amendments.
Can an independent marine survey replace MLC certification or legal advice?
No. An independent technical review can document observations and identify matters within its agreed scope, but it does not replace MLC certification, a required statutory inspection, legal representation or a decision reserved to a competent authority.
What official sources should be checked for current MLC requirements?
Consult the official ILO MLC, 2006 text and applicable amendments, relevant IMO publications concerning the Joint ILO–IMO fair-treatment guidelines, and the instructions of the relevant flag Administration. Check applicable national law and subsequent amendments before making operational or statutory decisions.
Can PAMS provide independent technical inspection services?
PAMS Pacific Admiralty Maritime Services provides independent marine surveying, technical inspections, engineering consultancy and regulatory compliance support. The scope of each engagement is agreed according to the technical requirements, available information and the work PAMS is competent and authorized to perform.
PAMS Pacific Admiralty Maritime Services
PAMS Pacific Admiralty Maritime Services is an independent marine technical consultancy based in Malate, Manila, Philippines. Its technical scope includes marine surveying, vessel and cargo condition assessment, engineering consultancy, technical inspections and regulatory compliance support.
Technical assignments are defined according to the commissioning party's requirements, the applicable regulatory framework and the information available for assessment. PAMS is an independent consultancy and does not replace competent authorities, statutory certification bodies, legal advisers or prescribed approval processes.
Need Independent Marine Technical Support?
Contact PAMS Pacific Admiralty Maritime Services to discuss independent marine surveying, technical inspections, engineering consultancy or regulatory compliance support for your maritime project.