St. Kitts & Nevis – revised MLC requirements

Notice to: Ship Owners / Managers/ Operators / Surveyors / Auditors :

C24028 | 13 June 2024

The St. Kitts and Nevis International Ship Registry has issued the following circulars:

• MC 51 13 (rev3) 
  • Procedures and guidance for certification for the Maritime Labour Convention, 2006 (MLC 2006).
• MC 130 24
  • Revised template of the Declaration of Maritime Labour Compliance Part I (DMLC Part I).
• MC 130 24 
  • Revised requirements under MLC for ships below 500 GT.

Key points to note are:

MC 51 13

This circular should be read in conjunction with MC 130 24 & MC 131 24. It includes:

• Application.
• Guidance on the definition of Shipowner.
• Exemptions & substantial equivalencies.
• Recognised Organisations & Inspectors.
• Inspection and Certification.
• On board Complaint Procedures.
• Financial Security.
• Seafarer Recruitment and Placement Services.
• Cooks, Food & Catering.
• Health Protection & Medical Care.
• Hours of Work and Hours of Rest.
• Yachts.
• Erratum
• Documents available on the website.

The Circular makes the following ‘strong recommendations:

• Shipowners should aim for full compliance with the requirements as the processes for obtaining an exemption are lengthy.
• Shipowners of vessels less than 500GT should voluntarily apply for a Maritime Labour Certificate to reduce possible problems with PSC.

An Interim Maritime Labour Certificate may be issued by an RO for a period not exceeding six (6) months. Interim certificates will not be extended or re-issued.

The initial inspection report, conducted by the RO, is to be retained onboard as long as the ship remains registered with St. Kitts & Nevis.

MC 130 24

The Administration has amended several clauses of the DMLC part I, viz:

• 4. Seafarer Employment Agreements.
• 11. Health, safety and accident prevention.
• 15. Financial Security for repatriation.
• 16. Financial Security for shipowners’ liability.

A revised DMLC part I template is included as an Annex to the circular, it has a validity of 5 years.

All existing DMLC Part I’s issued before the Circular came into force, or any DMLC Part I’s which do not bear an expiry date are to be renewed at the MLC Renewal Survey/Audit.

MC 131 24

All commercially operated ships, regardless of size and engaged in international voyages or operating from a port, or between ports, in a country other than St. Kitts and Nevis, must have a DMLC Part I and financial security documents. These documents are to be sent to the Administration and confirmation of receipt is to be obtained.

All ships flying the flag of St. Kitts and Nevis are to carry onboard a DMLC Part I to demonstrate valid insurance cover under the Maritime Labour Convention, 2006. The Administration encourages Shipowners, Ship Managers and Ship Operators to apply to them, to issue a DMLC Part I for their ships.

Failure to comply with these requirements may lead to a restriction of movement notice being issued. Such restrictions may not be lifted until the Administration acknowledges the financial security documents.

Act now

Ship Owners/ Managers/ Operators/Surveyors/Auditors should take note of the contents of the circulars and ensure the DMLC part I is renewed at the MLC Renewal Survey/Audit if required, and that ships below 500 GT send the DMLC Part
I and financial security documents to the Administration.