The Japanese Safety Board has published a revealing and fully illustrated account of an alarming event which took place earlier this year, when a “small” containership – in reality a sizeable enough vessel – loomed out of the pre-dawn darkness in the Inland Sea and smashed into a sea wall at 15 knots.

The lone watchkeeper, sitting in the pilot chair, had fallen asleep. This latest “fatigue-related” accident can be added to a long list of similar incidents from around the world which seems to cast serious doubts about the operational safety of many modern merchant ships.

The UK Marine Accident Investigation Branch, which has catalogued a lengthening list of such accidents in recent years, has become convinced that this worrying development is connected to the simple shortage of people aboard many small ships, with mate and master working watch and watch and no lookout posted at night. There is, however a reluctance among administrations where there is a substantial small ship component, to “rock the boat” and require an additional watchkeeper or more manpower, citing competitive pressures.

So it might be considered significant that the two biggest port state control organisations – the Tokyo and Paris MOUs - are soon to embark upon a three month intensive inspection of compliance with hours of rest regulations. There is, it appears, more than one way of applying pressure to a reluctant industry!

It is anticipated that more than 10,000 of these inspections, concentrating upon the hours of rest records (which can of course be checked against logbook and other operational data) will be carried out during this period, as the port state inspectors go about their normal business in Eastern and European ports alike.

Despite the warnings which have been given to alert the shipping industry in these areas, it will be surprising if there is not a marked increase in detentions caused by a failure to comply with these regulatory requirements. Since hours of rest requirements were first implemented both port and flag states have reported that a substantial part of the industry appears to treat these in a markedly cavalier fashion, with reporting forms “flogged” or even completed in advance of the event.

The near impossibility of a ship operating a “two-watch” system staying legal has also been frequently commented upon both by professional institutions and regulators alike. But blind eyes are too often being employed to ignore this practice, aboard ships which can barely cope with normal operational demands upon the few available crew members. Most will probably get away with it, which perhaps encourages both masters afloat and managers ashore to play this percentage game. They probably just hope that if somebody falls asleep, they are woken up by a watch alarm and not a concrete breakwater.

But aside of the enhanced scrutiny of the port state inspectors, it is well worth noting that 1 January next year will also see changes to the manning requirements, in particular the ISM Code. This significant change will require ships to be “appropriately manned in order to encompass all aspects of maintaining safe operations on board”. Just a few extra words, but this amendment means that compliance with minimum safe manning may not be sufficient when taking into account the operational requirements of the ship. It also complements the Maritime Labour Convention 2006 (now beginning to bite) which requires “all operational aspects” to be considered when manning levels are reviewed.

Goodness knows it is overdue, but through all these pressures, the industry, doubtless kicking and screaming, might be forced by impatient regulators into manning its ships adequately. We live in hope.