MLC 2006 inspection and the ship's medical care

How the MLC is built

The MLC has Articles and Regulations, then a Code in two parts. Part A contains mandatory Standards. Part B contains Guidelines, which States must give due consideration to but which are not mandatory in themselves. The Regulations are grouped in five Titles; Title 4 is health protection, medical care, welfare and social security, and Title 5 is compliance and enforcement.

Flag inspection and certification (Title 5)

Regulation 5.1.3 applies the certificate to ships of 500 gross tonnage or over engaged on international voyages, or operating from a port, or between ports, in another country; other ships may be certified at the shipowner’s request.

The 16 areas listed in Appendix A5-I are: minimum age; medical certification; qualifications of seafarers; seafarers’ employment agreements; use of any licensed or certified or regulated private recruitment and placement service; hours of work or rest; manning levels; accommodation; on-board recreational facilities; food and catering; health and safety and accident prevention; on-board medical care; on-board complaint procedures; payment of wages; financial security for repatriation; and financial security relating to shipowners’ liability.

Medical care on board (Regulation 4.1)

Standard A4.1 sets the minimum national requirements:

Guideline B4.1.1 adds the practical detail:

• Ships that can normally reach qualified medical care within eight hours should have a designated seafarer with approved medical first-aid training; all other ships a seafarer with approved training in medical care, including practical training such as intravenous therapy.
• Those designated should take refresher courses at about five-year intervals.
• The medicine chest, its contents, the medical equipment and the medical guide should be inspected at intervals not exceeding 12 months by responsible persons designated by the competent authority, checking labelling, expiry dates, storage conditions and directions for use, and that equipment works.
• The competent authority should take account of the latest edition of the International Medical Guide for Ships when setting the medical guide and the chest contents.
• Where a dangerous cargo is not covered by the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods (MFAG), the information, antidotes and protective equipment should be on board.
• Ships should carry an up-to-date list of radio stations, and coast earth stations if they have satellite communication, through which medical advice can be obtained.

The International Medical Guide for Ships is published by the World Health Organization with the ILO and IMO. The current edition is the third (2007), with a separate quantification addendum for medicine quantities. Work on a fourth edition began in 2021; check with WHO or your flag whether it has been published before you replace the guide on board.

Preparing the medical locker for inspection

1. Check the inventory against the flag’s national list for the ship’s category, not against an old supplier list.
2. Remove and record expired items, and order replacements early, as controlled drugs may need special permits to be supplied.
3. Check storage: temperature-sensitive items in the fridge, controlled drugs locked with a register.
4. Test equipment: oxygen resuscitator cylinder pressure and masks, defibrillator battery and pads (if carried), stretcher and splints.
5. Make sure the medical guide, MFAG (for dangerous goods) and the radio medical advice list are on board and current.
6. Have the last annual inspection record, and the medical training certificates of the designated officers, ready to show.

The 2022 amendments (in force since 23 December 2024)

The amendments approved in 2022 added, among others: free drinking water of suitable quality (A3.2); prompt medical disembarkation and access to shore treatment, and repatriation of the remains of deceased seafarers (A4.1, paragraphs 5 and 6, with a list in Guideline B4.1.3 of cases that count as needing immediate care, including suicide risk and a tele-medical service recommending treatment ashore); appropriately sized personal protective equipment (A4.3); and reporting of seafarer deaths to the ILO for a global register (A4.3, paragraph 5(a)).

The 2025 amendments (expected in force 23 December 2027)

Approved on 6 June 2025 at the 113th International Labour Conference, they amend provisions on recruitment and placement, shore leave, repatriation, accommodation, medical care on board and ashore, health and safety (including violence and harassment), shore-based welfare and flag State responsibilities. They are not yet in force: until 23 December 2027, inspections follow the text as amended in 2022.

Port State inspection under the MLC

Under Standard A5.2.1, a PSCO who finds missing or invalid documents, clear grounds, signs of a flag change to avoid compliance, or a complaint, may carry out a more detailed inspection. If conditions are “clearly hazardous to the safety, health or security of seafarers”, or the non-conformity is a “serious or repeated breach” of the Convention, the officer must stop the ship sailing until it is rectified or an acceptable action plan is agreed.