17 April 2020
London. UK. With permission, Human Rights at Sea publishes the 15th March 2020 letter sent to the IMO by Captain Michael Lloyd, RD**, MNM, CMMar, FNI, raising his concerns of the consequences and effects of the COVID-19 pandemic on crews, including the treatment of those infected and the necessity for PPE to be placed onboard ships.
According to Captain Lloyd copies of the letter were also sent to the ICS, MCA, Nautilus and IFSMA, but to date there have been no acknowledgements. He has suggested there is ‘no one correlating the number of seafarers with this virus and those that have died from it, while everyone is correlating this information ashore’.
Meanwhile the issue of the availability of, and access by seafarers to PPE continues to be raised by Human Rights at Sea. Captain Lloyd sits on the charity’s non-executive Board.
Maritime Safety Division
I would thank you for your courteous response to my email. I hope you understand that I am writing because of my concerns with those at sea during this difficult time.
With regard to your reply, I noted the various circulars you mentioned most of which I was familiar with.
My comments are as follows;
The Circular Letter No.4204 31 January 2020 says little except advice regarding procedures
Circular Letter No.4203/Add.1 12 February 2020 ideals with advice to delegates.
The operational considerations for managing COVID-19 cases and outbreaks on board ships interim guidance published 20th of February is directed at and for passenger vessels not cargo ships which have a totally different problem.
The accompanying document COVID-19 v4; Operational Support & Logistics Disease Commodity Packages, refers to equipment that cargo ships do not have and is a document not designed specifically for ships. Circular Letter No.4204/Add.3 2 March 2020 is again primarily directed at passenger vessels and refers to organisations and procedures that cargo ships do not have access to.
The International Chamber of shipping document Coronavirus (COVID-19) published on the 3rd of March, Guidance for Ship Operators for the Protection of the Health of Seafarers that you refer to is better than the IMO publications but still does not deal with the specific problem of equipment and the assistance for infected crew members on board ships transiting flag state areas or those seeing port of refuge for the transferring of crew members to hospitals ashore. As this document notes, many flag states ports are not complying with the WHO International Health Regulations (IHR) but to many seafarers, this is not a new situation as many flag states have often ignored their responsibilities for some time as the IMO well knows.
Further, the list of medical equipment that is stated as being already carried on board does not bear any relation to reality for cargo ships. For example it states that resuscitators are carried when few ships have these as they are not a statutory requirement.
While appreciating the time and thought put into these documents giving advice on what to do, they have little substance for actually dealing with a situation that can occur on board a cargo or work ship.
The problem we are facing at sea for the majority of shipping, the cargo and work ships, is that they do not have the required equipment or PPE for dealing with an outbreak on board ship, and there is no formal requirement that flag state ports MUST evacuate seafarers from ships within their waters and those ships entering their waters to evacuate sick crew members with COVID-19.
As most authorities now appreciate, we are entering unknown waters in dealing with a worldwide pandemic. I suggest that existing protocols may not be sufficient for dealing with the situation and that the administration of the IMO must now take charge and lead the industry by dictate rather than consensus, as the normal delays experienced in the IMO cannot be acceptable during this pandemic.
If we are to expect that our crews will carry supplying the essential products to sustain our countries during this emergency, we must demonstrate a more tangible support that just advice which is mostly what these documents contain.
It is the IMO that must supply this initial leadership to the Flag States stating what is required of them. I do not think that the closing of the IMO headquarters is setting a good leadership example especially while we expect the crews to continue manning their ships. A little like the generals leaving the field of battle while expecting the soldiers to carry on fighting.
If this decision is to stand, then I suggest that an ad hoc pandemic committee be established at the IMO with enough practical experience to allow decisions to be made quickly and with understanding of the circumstances prevailing at sea. In the event of any refusal to evacuate a sick crew member by any port or flag state, then that can be immediately reported to that committee for their action.
To conclude, I suggest that what is immediately required is that;
1. All ports must carry a supply of test equipment, and the PPE required for dealing with COVID-19, and that this is placed on board all ships, regardless of flag, that needs this. The cost them should be passed to the ship owners.
2. That Flag States be immediately required to evacuate seafarers sick from COVID-19 from ships in their waters or entering their waters for that purpose.
3. That compulsory reporting of all cases of the virus on ships, including those seafarers evacuated and any deaths. Initially to the Flag State and then on to the IMO for compilation.
It is essential that we have a record of how the virus has progressed on our ships in order that we have the essential learning for the future pandemics.
By these basic measures, we provide far more meaningful support than all the well intentioned paperwork of advice. I am sure that if those at sea, especially the Captains know that such support is being required rather than advised, their concerns will be greatly alleviated.
Captain Michael Lloyd, RD**, MNM, CMMar, FNI.”
The opinions expressed herein are the author’s and not necessarily those of Human Rights at Sea.