I am distressed by the number of ships being built with crew accommodation forward. The new Maersk ships are the last straw.
The design of these is in flat contradiction of the Maritime Labour Convention 2006, of which Title 3, Standard 3.1.6 (c) states: 'In ships other than passenger ships, as defined in Regulation 2 (e) and (f) of the International Convention for the Safety of Life at Sea, 1974, as amended (the SOLAS Convention), sleeping rooms shall be situated above the load line amidships or aft, except in exceptional cases; where the size, type or intended service of the ship renders any other location impracticable, sleeping rooms may be located in the fore part of the ship, but in no case forward of the collision bulkhead.'
Why, on any of these new ships, is it an 'exceptional case' or 'impracticable' for the accommodation to be midships or aft, when thousands of similar ships have been so built over the last few decades? Just what are the flag administrations and their class society advisors thinking?
A version of this letter was previously published in Ships Monthly magazine