EU Working Time Directive Consultation – IMCA Response

The European Commission has been consulting on a review of the EU Working Time Directive (2003/88/EC).  The aim of the review is to identify what changes might be needed in order to reflect current and future working practices.

The Working Time Directive applies to ‘offshore workers’ in the EU, so it covers all personnel working on offshore installations and also divers, whether they are diving from an installation or from a vessel.  Other personnel working on vessels are subject to the separate ‘seafarers’ workhour regime based on the International Labour Organization (ILO) rules (Council Directive 1999/63/EC concerning the Agreement on the organisation of working time of seafarers).

In the past, IMCA has argued successfully that project personnel apart from diving personnel should be under the ‘Seafarers’ regime, which does not have a rigid cap on days worked a year.  This is also the approach we have taken recently in discussion with the German authorities about vessel personnel in the windfarm sector. 

IMCA has therefore responded to this latest EU consultation with some general comments about the need for the Working Time Directive to take account of the special requirements of the offshore industry, but also stressing the need to maintain the current delineation between ‘offshore work’ and the ‘seafarers’ regime. 

The IMCA response is attached for members’ information.