Manila amendments to the STCW

As examples: The 24 hour period should start at midnight; The 24 hour period should commence at the time a seafarer starts work immediately after having any period of rest of one hour or more; The period should start from the seafarers' first period of work on each calendar day Apparently, such variations in the interpretation can lead to substantial differences in the number of non-conformances detected and recorded, which then may potentially lead to a fatigue and subsequent accidents caused by the related human error factor.

In accordance with mentioned above it could be still stated that fatigue is being considered as a significant contributory factor to many incidents in the shipping industry since the policy of monitoring of rest and work hours, that was designed as a very important tool to fght with fatigue, is not effective enough. Moreover, in a real life it creates problems with proper understanding of approach for calculation of rest and work hours, analysis of the workload and real fatigue caused by the Job.

And last but not least, existing form of record keeping of hours of work and rest creates a lot f paper work for the crew and Ship managers and take of their times that could be spend for more important issues. In the meantime, the fatigue prevention policy cannot be ideal since measurement of fatigue is extremely difficult due to the large variability of causes.

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In accordance with Guidance on Fatigue Mitigation and Management there are many ways to categorize tne causes 0T Tatlgue. 10 ensure tnorougnness ana to prov10e good coverage 0T most causes, they have been categorized into 4 general factors: Crew-specific Factors; Management Factors (ashore and aboard ship); Ship-specific Factors; Environmental Factors.

Even if all of these factors can be considered with the same weighting coefficient in determination of level of fatigue, the most important factors will be still related to the crew specific factors such as Sleep and Rest, Quality, Quantity and Duration of Sleep, Sleep Disorders/Disturbances, Rest Breaks, Biological Clock/Circadian Rhythms, Psychological and Emotional Factors, including stress, Fear, Monotony and Boredom, Health, Diet, Illness, Stress, Skill, knowledge and training as it relates to the Job,

Personal problems, Interpersonal relationships, Ingested Chemicals, Alcohol, Drugs (prescription and non-prescription), Caffeine, Age, Shift work and Work Schedules, Workload (mental/physical), Jet Lag, etc. In view of the above stated it should be concluded that matter of fatigue is not only related not only to the shipping industry and consequently prevention of fatigue has been already addressed in other industries, such as aviation for instance.

In accordance with the 'Fatigue in Aviation' of Federal Aviation Administration, causes of atigue can range from boredom to circadian rhythm disruption to heavy physical exertion'. In simple terms, fatigue can be simply defined as wearisomeness, which in most cases caused by the lack of rest. Weariness, at the same time, may vary even for the crew maintaining the same tasks on different type of ships or in a different area of trading. Thus it seems to be logical that industry must use various methods for 'measuring fatigue of their workers, but not standardising their hours of work and rest.

At the same time modification of existing fatigue prevention policy should be more ocused on implementation of new technical devices in line with the proven objective approach that will not create extra paperwork but will really measure fatigue and improve effectiveness of fatigue prevention. As an example of new methodology for detecting attention lapses or impaired ability of the crew to perform their tasks measuring technique so called Blink Rate (electrooculography) can be considered being good alternative to the current paper exercises.

Ponder and Kennedy in their research in 1927 have concluded that blinks are controlled by the central nervous ystem rather than peripheral processes; for this periodic, spontaneous blink, the rate of blinking is closely related to 'mental tension' of the subject at the time, and that in all probability the movements constitute a kind of relief mechanism whereby nervous energy, otherwise unutilized, passes into a highly facilitated path 0. A. Stern, 1994). There are some other technologies that help to define the level of fatigue at the start o a s ITt or contlnuously tnrougnout task perTormance.

In researcn I-atlgue RISK Management in Aviation Maintenance: Current Best Practices and Potential Future Countermeasures, the following technologies are presented as possible systems that facilitate fatigue measurement psychomotor performance tests that are usually installed on a handheld device or and typically measure the person's speed of response to a stimulus. Voice analysis also may be considered as a method to detect fatigue in operational personnel, particularly in settings where verbal communication occurs via radio or telephone.

Different monitoring systems for measurement of alertness have been as well developed for the road transport industry, and several odels of vehicles now come equipped with systems designed to detect drowsy drivers. (Hobbs, 2011) Several of technical innovations are already being widely used in different industries and shows possibility to move from paper calculation and bureaucratic approach in fatigue management to innovational and objective approach of fatigue management. History shows that several regulations adopted before in aviation industry later were transferred into the shipping industry to assist in improvement of safety management.

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