The IMO Sub-Committee on Human Element, Training and Watchkeeping (HTW 12), held from 23-27 February 2026, delivered progress across several areas of importance to the maritime workforce, including the comprehensive review of the STCW Convention and Code, training for alternative fuels and the launch of a new workstream on fatigue and hours of work and rest.
The HTW Sub-Committee deals with the human side of shipping, including ensuring that seafarers are adequately trained, competent and fit for duty, while addressing issues such as fatigue management, crew welfare and evolving industry needs across the maritime sector.
STCW review moves into detailed phase
Progress on training for alternative fuels and new technologies
New IMO work launched on fatigue
STCW review moves into detailed phase
HTW 12 continued the comprehensive review of the STCW Convention and Code, focusing on updates to competence requirements for deck and engine officers based on gaps identified earlier in the process. Given the large number of submissions, discussions concentrated primarily on strategic direction rather than detailed drafting.
One area receiving particular attention was the potential partial substitution of seagoing service with simulator training. While views differed, the STCW Convention already allows administrations to approve alternative training arrangements, and some are applying such approaches in practice, albeit without harmonised criteria or consistent safeguards. The work will therefore focus on the conditions under which substitution could be implemented safely and consistently, including the need for clear criteria, defined limits on the amount of sea service that could be replaced, appropriate quality assurance of simulators and training programmes, and the importance of combining simulator training with onboard experience.
In addition to the review of existing provisions, HTW 12 considered the introduction of new provisions addressing emerging risks and operational areas related to:
- Violence and harassment, including sexual harassment, bullying and sexual assault
- Mental health, psychological safety, and gender and cultural diversity
- Ballast water management
- Cybersecurity
These topics reflect broader societal developments, increasing digitalisation and the growing recognition of human element aspects as an integral part of maritime safety.
Work on the comprehensive review continues intersessionally. BIMCO is actively contributing to ensure that any amendments remain practical, proportionate and globally implementable, without creating unnecessary burdens or unintended consequences. Attention will be needed to maintain a clear distinction between training requirements under STCW and company responsibilities addressed under the ISM Code, and to consider the cumulative impact of changes on training duration, costs and career pathways. This aligns with BIMCO’s broader focus on workforce sustainability and the need to support a resilient and attractive maritime profession.
Progress on training for alternative fuels and new technologies
Work on training provisions for seafarers serving on ships using alternative fuels and new technologies initially focused on the development of generic interim guidelines, which were approved at MSC 110. The work has now moved towards the preparation of fuel- and technology-specific interim training guidelines to support their safe introduction.
HTW 12 made substantial progress by finalising the draft interim guidelines on training of seafarers using methyl/ethyl alcohols as fuel and the draft interim guidelines on training of seafarers using ammonia as fuel, which will be submitted to MSC 111 for approval. Once approved, the guidelines can be used to develop training programmes for seafarers serving on ships using these fuels.
The methyl/ethyl alcohol guidelines include clarifications on the relationship between the fuel-specific guidelines and the generic guidance, to avoid misinterpretation of the interim provisions as a stand-alone mandatory standard.
For ammonia as fuel, a key issue considered was the scope of application, particularly in relation to ships covered by the IGC Code. The Sub-Committee agreed to maintain a broad scope without explicitly excluding IGC Code ships, noting that the interim guidelines are non-mandatory and that administrations may apply alternative arrangements.
HTW 12 also agreed a work plan extending to 2029, recognising the close interdependence between training provisions and parallel technical safety developments underway across IMO. The work will prioritise training requirements for seafarers serving on ships using hydrogen fuel cells, followed by LPG, hydrogen, battery-powered ships and wind-assisted propulsion systems, with the longer-term objective of incorporating these requirements into the STCW framework.
BIMCO continues to contribute actively to this work, with a focus on ensuring that training requirements remain risk-based, proportionate and aligned with operational realities, while avoiding unnecessary complexity or duplication within the regulatory framework.
New IMO work launched on fatigue
Seafarer fatigue and the effectiveness of provisions on hours of work and rest have been longstanding concerns within IMO, supported by research, casualty investigations and repeated submissions to the Maritime Safety Committee (MSC). These have highlighted persistent challenges, including inaccurate recording of hours, workload imbalances and limitations in inspection and enforcement practices.
Following instructions from MSC, HTW 12 formally commenced a scoping exercise to assess whether the existing regulatory framework remains effective and fit for purpose. The work will take a comprehensive view across relevant IMO instruments, the STCW Convention and Code, and the Maritime Labour Convention (MLC), as well as associated implementation and enforcement practices. The target completion year is 2027.
The objective is not limited to identifying potential regulatory amendments but also includes examining how existing provisions are implemented in practice, including challenges related to workload, crewing levels, recording practices and compliance monitoring. The relevance of findings from the study on the effectiveness of the ISM Code was also noted, particularly in relation to company responsibilities, resource allocation and safety culture factors influencing fatigue management. The work will continue intersessionally through a correspondence group ahead of HTW 13.
This topic is of particular importance to BIMCO members and has been a longstanding industry concern. While regulatory requirements have existed for many years, challenges related to practical implementation, compliance verification and record-keeping continue to be widely reported, and the current framework is often perceived as difficult to apply consistently under real operational conditions on board ships.
BIMCO supports efforts to improve the effectiveness and practical implementation of fatigue-related provisions and considers this work both timely and necessary. Ensuring alignment between regulatory requirements and operational realities will be essential to achieving meaningful safety improvements without creating unintended administrative burdens.
Towards this direction, BIMCO will launch a member survey to gather operational experience related to fatigue, workload and hours of work and rest implementation. The results will help inform BIMCO’s engagement at IMO and support the development of practical guidance for members.
