The Declaration of Maritime Labour Compliance (DMLC) is an essential document for a vessel’s certification under the Maritime Labour Convention (MLC). It ensures compliance with the MLC’s provisions, including welfare measures for seafarers. It is divided into two parts:
1. DMLC Part I
- Prepared by the Competent Authority of the Flag State (e.g., national government or designated administration).
- Specifies national laws, regulations, and measures implementing MLC requirements.
- Covers all 14 areas of the convention, including welfare-related provisions such as:
- Medical care and occupational health protection
- Accommodation standards
- Food and catering requirements
- Recreational facilities and welfare services in ports
- Acts as an official statement that the Flag State has fulfilled its MLC obligations and provides a legal reference for compliance.
2. DMLC Part II
- Prepared by the shipowner.
- Describes ship-specific measures for complying with the national legislation referenced in Part I.
- Details for each of the 14 MLC areas, including welfare provisions, such as:
- Policies for food provision and catering arrangements
- Procedures to maintain clean and safe accommodation
- Medical care arrangements, including shore-based medical access
- Provision of recreational facilities and welfare services
- Forms part of the vessel’s compliance system and is subject to auditing and verification.
Together, DMLC Part I and Part II provide a binding framework ensuring welfare provisions under the MLC are not only legal requirements but are actively implemented and verifiable on MLC-certified vessels.
The MLC requires all ships to have a fair and effective on-board grievance procedure. For Indian-flagged vessels, the grievance mechanism follows a three-tier structure:
1. On-Board Procedure
- Seafarer first reports the grievance to immediate superior or Head of Department.
- If unresolved, the matter is taken to the Master.
- The Master investigates and attempts resolution promptly and fairly, as per procedures described in DMLC Part II.
2. Company Procedure (Designated Person Ashore – DPA)
- If still unresolved, the grievance is escalated to the company’s Designated Person Ashore, as per the ISM Code.
- The DPA ensures the complaint is properly investigated and addressed by company management.
3. External Authority (Directorate General of Shipping – DGS)
- If the company fails to resolve the issue, the seafarer can approach the DGS, the competent authority for Indian-flagged ships.
- Complaints can be submitted via the DGS e-governance system or through the nearest Mercantile Marine Department (MMD).
- The DGS investigates, mediates, and enforces compliance.
- If necessary, the DGS can initiate legal action against the shipowner for MLC violations.
This multi-level mechanism ensures seafarers have a clear and accessible pathway for resolving grievances, with escalation options from shipboard level to national authority.