Social

Illegal, unregulated, unreported (IUU) fishing

Seafood is a nutritious meal for millions of people across the world and an essential food protein in many developing countries. A major problem for sustainable fisheries management is illegal, unregulated and unreported fishing (IUU fishing). Vessels engaged in IUU fishing activities do not use legal fishing gear, do not follow fisheries management regulations and/or do not comply with regulations on quotas, fishing areas, closed seasons or prohibited species. The IUU catch is not recorded in catch registers. This is an important aspect because fishing stocks are estimated based on these registers. IUU fishing destroys marine habitats, adds pressure to fish populations that are already at risk of over-exploitation and undermines efforts to responsibly manage and protect the ocean. It exploits the natural resources of coastal nations, reduces economic opportunities and threatens food security, particularly in developing countries, and has therefore environmental and social implications.

Marine insurers can support the suppression of IUU fishing activities by refusing or cancelling insurance to vessels which have been blacklisted for involvement in illicit actions. The ocean conservation group Oceana in cooperation with UNEP FI’s PSI have engaged with marine insurers and associations including IUMI to develop guidelines to mitigate the risk of insuring vessels and companies associated with IUU fishing.

Oceana has further developed an information-sharing tool intended to facilitate and foster the exchange of information on IUU fishing vessels between companies that provide services to the global fishing sector, including marine insurers. Through the tool, companies can exchange information with other businesses on when a vessel on the official IUU vessel list of any RFMO has sought and been denied services or had services cancelled, and in addition they will be notified when new vessels get added to the IUU vessel lists. To register to the tool please visit Pull the Plug on Pirate Fishing.

A separate initiative is Vessel Viewer developed by the Ocean Risk Alliance (ORRAA). This IUU fishing risk assessment tool is intended to help insurers quickly evaluate the risk that a vessel or a group of vessels may engage in or support IUU fishing. Through the tool, insurers are able to access key information on vessel identity, behaviour and risk indicators.

IUMI supports the adoption of the Cape Town Agreement (CTA) of 2012 on the Implementation of the Provisions of the 1993 Protocol relating to the Torremolinos International Convention for the Safety of Fishing Vessels. This IMO treaty to address fishing vessel safety is not in force yet. The absence of an international mandatory regime makes effective control and monitoring of fishing vessels difficult. The CTA sets minimum requirements on the design, construction, equipment, and inspection of fishing vessels of 24 meters in length and over. The agreement further facilitates better control of fishing vessel safety by flag, port and coastal States. Swift ratification of the CTA is therefore desirable and supported by IUMI.

Seafarers’ wellbeing

Crew change crisis

Seafarers are at the heart of the maritime sector. They are enablers of global shipping and without them international trade of the essential goods and products around the world would collapse. The COVID-19 pandemic created an unprecedented crew change crisis. Hundreds of thousands of seafarers stranded working aboard ships beyond the expiry of their contracts. Meanwhile, thousands of seamen and women were unable to reach ships for crew change, leading to financial uncertainty for themselves and their families.

This is an unacceptable way to treat seafarers who are key to maintaining the global flow of essential (and less essential) goods. Fatigue after extended periods at sea has significant consequences on the physical and mental wellbeing of seafarers. It also increases the risk of maritime accidents and environmental disasters, and poses a wider threat to the integrity of global supply chains which depend on safe and reliable maritime transport.

Recognising a shared responsibility to resolve the crew change crisis, IUMI signed the Neptune Declaration on Seafarer Wellbeing and Crew Change in January 2021. The Neptune Declaration urges the implementation of four main actions to address the crisis:

• Recognise seafarers as key workers and give them priority access to COVID-19 vaccines.
• Establish and implement gold standard health protocols based on existing best practice.
• Increase collaboration between ship operators and charterers to facilitate crew changes.
• Ensure air connectivity between key maritime hubs for seafarers.

By November 2022, 66 countries had designated seafarers as keyworkers.

Code of Conduct on Seafarers’ Rights

The shipping industry is required to comply with the International Labour Organization (ILO) Maritime Labour Convention (MLC) and other international conventions covering the human rights (which include labour rights) of workers. Alongside increased public awareness of the role of seafarers, there is a growing demand from consumers, investors, business partners, civil society and governments via increasing regulatory requirements for more transparent and sustainable supply chains that address human rights as well as environmental concerns throughout the supply chain, including logistics segments. Ensuring that seafarers’ rights and welfare are respected is critical in the shipping industry’s sustainability journey. The Sustainable Shipping Initiative published a Code of Conduct on Seafarers’ Rights in October 2021. It seeks to reinforce compliance with the MLC and other relevant maritime conventions and goes beyond by focusing on valuing seafarers and the full spectrum of their human rights.

Fatigue

Ships’ crews are under increasing pressure from competitive voyage schedules and have to handle their tasks with fewer crew members. Evidence from accident records and research literature both point to the serious impact that sleepiness and fatigue may have on the safety and welfare of seafarers. Fatigue has short and long-term effects on seafarers and measures must be taken to reduce the risk of fatigue. IUMI addressed this topic in a webinar to raise awareness for this issue which can have serious implications for the safety of the crew, the vessel, its cargo and the environment. IUMI further supported the review of the IMO’s Guidelines of fatigue mitigation and management. The review was concluded by the Sub-Committee on Human Element, Training and Watchkeeping in 2018 and a circular approved by the Maritime Safety Committee in December 2018 to inform Member States of the updated guidelines.

Sexual assault and harassment (SASH) at sea

In the wake of widespread allegations of sexual harassment in the maritime industry, calls to ensure the safety and security of seafarers, including women seafarers, have been widespread. In February 2022, the IMO’s Sub-Committee on Human Element, Training and Watchkeeping (HTW) discussed to the revision of a model course on “Personal Safety and Social Responsibilities” with a view to including specific content to establish appropriate maritime workplace behavioural norms. Psychological safety, mental health, wellbeing, including SASH, constitute relevant areas of ILO’s remit. The IMO there will coordinate its efforts with the ILO and has invited IMO member States to submit proposals to the Maritime Safety Committee for consideration and action.

In this context the U.S. Department of Transportation and the Maritime Administration (MARAD) released new safety standards to govern the U.S. Merchant Marine Academy’s Sea Year following a sexual abuse case while at sea. The “Every Mariner Builds A Respectful Culture” (EMBARC) Standards were launched by MARAD in December 2021.

Ship recycling

Vessels are considered hazardous waste under international environmental law such as the Basel Convention and the EU Ship Recycling Regulation. According to the NGO Shipbreaking Platform, 443 ocean-going commercial vessels were sold to the scrap yards in 2022. Of these vessels, 292 large tankers, bulkers, offshore platforms, cargo and passenger vessels were dismantled in Bangladesh, India and Pakistan, amounting to 80% of the gross tonnage broken up globally. The process of dismantling often does not occur in safe and environmentally sound working conditions. The practice of “beaching” vessels to break them up poses significant risks to the health and safety of the workers. It also causes environmental damage due to the toxic materials released during the process.

The IMO’s Hong Kong Convention is aimed at ensuring that vessels when being recycled do not pose any unnecessary risk to human health and safety or to the environment. The Hong Kong Convention was adopted in May 2009 and will enter into force in June 2025. Regulations in the Convention cover the design, construction, operation and preparation of vessels to facilitate safe and environmentally sound recycling and the establishment of an appropriate enforcement mechanism for vessel recycling, incorporating certification and reporting requirements. Vessels to be sent for recycling will be required to carry an inventory of hazardous materials which will be specific to each vessel. IUMI welcomes the ratification of the Hong Kong Convention to ensure a minimum standard of safety and environmental standards during the dismantling of vessels.

The EU put in place its own regulatory measure. From 31 December 2018, the EU Ship Recycling Regulation mandates the recycling of all large sea-going vessels sailing under an EU flag to take place in yards included in the European List of ship recycling facilities. The regulation aims to make ship recycling safer and environmentally sound. The 11th edition of the European List of ship recycling facilities was published in July 2023 and contains 48 yards, including 38 yards in Europe, 9 yards in Turkey and 1 yard in the USA.

The EU Ship Recycling Regulation has implications for marine insurance. Insurers involved in actions which may be considered illegal exports of ships to yards not included on the European List of ship recycling facilities may be held liable. Being associated with unsustainable practices such as “beaching” of vessels may further lead to reputational risks. IUMI is raising awareness for this issue by holding presentations and webinars on the topic. IUMI further supports the work of the Ship Recycling Transparency Initiative (SRTI) which aims at ensuring better labour and environmental standards by requiring shipowners to disclose their ship recycling policies and practices.