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Maritime Labour Convention, 2006 (MLC, 2006) - Ghana (RATIFICATION: 2013)

The Committee notes the Government’s second report on the application of the Maritime Labour Convection, 2006 (MLC, 2006). The Committee also notes that the amendments to the Code approved by the International Labour Conference in 2014, 2016 and 2018 entered into force for Ghana on 18 January 2017, 8 January 2019 and 26 December 2020, respectively.

Article I of the Convention. General questions on application. Implementing measures. The Committee notes that, in reply to its previous comments, the Government states that it is still working on the amendments of national related laws and regulations, in particular the Shipping Act, 2003. Recalling that the Convention was ratified by Ghana in 2013, the Committee expects that the relevant measures will be adopted without further delay to give full effect to the provisions of the Convention taking into account the comments presented below. It requests the Government to provide a copy of all new laws and regulations once adopted.

Article II. Definitions and scope of application. The Committee requested the Government to indicate if categories of persons or ships have been exempted from the application of the Shipping Regulations by the Director-General and specified in a Maritime Circular, and if this is the case whether any exemptions with respect to the application of these Regulations to categories of persons or ships were made after consultation with the shipowners’ and seafarers’ organizations.The Committee notes the Government’s indication that consultations will be held regarding possible exemptions. The Committee requests the Government to provide information in this respect with its next report.

Article II, paragraphs 1(f), 2, 3 and 7. Definitions and scope of application. Seafarers. National determination. The Committee requested the Government to provide information on the measures adopted to amend its legislation in order to ensure that masters and apprentices are covered by the Convention. The Committee notes the Government’s indication that it will issue maritime circulars to give immediate effect to the provisions of the MLC, 2006 and further incorporate the same in the Act. The Committee requests the Government to take the necessary steps to ensure that masters and apprentices benefit from the protection provided by the Convention.

Regulation 1.1 and Standard A1.1, paragraph 1. Minimum age. The Committee requested the Government to indicate the measures to comply with Standard A1.1, paragraph 1, of the Convention. The Committee notes the Government’s indication that it will have stakeholders’ consultation to consider the concerns raised from the wording of section 118 of the Ghana Shipping Act 2003. The Committee requests the Government to take the necessary steps without further delay to align its legislation with Standard A1.1, paragraph 1, of the Convention.

Regulation 1.1 and Standard A1.1, paragraph 4. Minimum age. Hazardous work. The Committee requested the Government to take the necessary measures to ensure that the list of types of hazardous child labour is prepared and adopted, thereby prohibiting hazardous types of work to children under 18 years and to provide information on the progress made in this regard. The Committee notes the Government’s indication that it will engage the relevant stakeholders to address this issue, and, in the meantime, it will issue a maritime circular containing the list of hazardous jobs which persons under the age of 18 years are barred from engaging in, to reflect the provisions of the MLC, 2006. The Committee requests the Government to take the necessary measures, after consultation with the shipowners’ and seafarers’ organizations concerned to bring its legislation in conformity with Standard A1.1, paragraph 4, without further delay.

Regulation 1.2 and Standard A1.2, paragraph 4. Medical Certificate. Qualified medical practitioner. The Committee requested the Government to provide information with regard to (i) the requirement that duly qualified practitioners must enjoy full professional independence in exercising their medical judgement in undertaking medical examination procedures (Standard A1.2, paragraph 4) and (ii) the opportunity for seafarers, who have been refused a certificate or have had a limitation imposed on their ability to work, to have a further examination by another independent medical practitioner or by an independent medical referee (Standard A1.2, paragraph 5). The Committee notes that the Government provided a specimen of Seafarer Medical Certificate and a copy of the Guidelines on Medical Examination for Seafarers (hereinafter “Guidelines”). The Committee notes that section 5.1 (Recognition of Medical Practitioners) of the Guidelines refers inter alia to the professional independence that medical practitioners should enjoy from shipowners, seafarers, and their representatives in exercising their medical judgment in terms of the medical examination procedures and decision on fitness. The Committee further notes that regulation 10(3) of the Ghana Shipping (Maritime Labour) Regulations, 2015 (hereinafter, the Shipping Regulations) states that the Authority may permit a seafarer to be examined by a medical referee, where: (a) a medical practitioner issues a medical certificate with restrictions imposed on the seafarer's ability to work; or (b) a medical practitioner refuses to issue a medical certificate to the seafarer. It further notes that section 5.2 of the Guidelines on Medical Examination (Appeal Procedures) includes specific guidelines on the establishment of processes and procedures to enable seafarers who do not meet fitness standards or who have had a limitation imposed on them to have their case reviewed through an appeal process. The Committee notes this information, which addresses its previous request.

The Committee further requested the Government to indicate the measures taken to ensure that full effect is given to Standard A1.2, paragraph 7. The Committee notes in this regard that while that the regulation 10(7) of the Shipping Regulations and Guidelines are in conformity with the Convention in relation to the periods of validity for medical and colour vision certificates, the LI 1790 Merchant Shipping (Training, Certification, Manning and Watchkeeping) Regulations, 2004, do not refer to the same validity periods for examinations and do not specifically require a medical certificate. The Committee therefore requests the Government to adopt the necessary measures to amend its national legislation to give full effect to Standard A1.2, paragraph 7.

Regulation 1.4 and Standard A1.4, paragraph 5(c)(vi). Recruitment and placement. System of protection.Noting the absence of information on this point, the Committee requests again the Government to indicate how it gives effect to the detailed requirements of Standard A1.4, paragraph 5.

Regulation 1.4 and Standard A1.4, paragraph 7. Recruitment and placement. Investigation of complaints.Noting that the Government does not provide information on this point, the Committee requests again the Government to indicate how it gives effect to the detailed requirements of Standard A1.4, paragraph 7.

Regulation 2.1, paragraph 1, and Standard A2.1. Seafarers’ employment agreements. Exceptions.Noting the absence of information on this point, the Committee requests again the Government to harmonize its legislation to ensure full conformity with Regulation 2.1, recalling that Standard A2.1. paragraph 6 does not provide for the exclusion of a ship, or a category of ships, from the protection offered by the Convention.

Regulation 2.1, paragraph 1, and Standard A2.1, paragraph 1(a) and (c). Seafarers’ employment agreements. Signature of seafarer and shipowner or a representative. Signed original. The Committee requested the Government to indicate the measures taken or envisaged to amend the Ghana Shipping Act, 2003, in order to put it in conformity with Regulation 2.1, paragraph 1, and Standard A2.1, paragraph 1(a) and (c). The Committee notes that the content of the draft SEA submitted by the Government is in line with regulation 13(1) of the Shipping Regulations and by extension with Standard A2.1, paragraphs 1(a) and (c). The Committee reiterates however that the Ghana Shipping Act, 2003, especially sections 108 and 112, do not give effect to the requirements of the Convention. The Committee therefore requests again the Government to indicate the measures taken or envisaged to amend the Ghana Shipping Act, 2003, in order to put it in conformity with the Convention.

Regulation 2.1 and Standard A2.1, paragraph 4. Seafarers’ employment agreements. Content. The Committee requested the Government to indicate the measures taken or envisaged to amend the Ghana Shipping Act, 2003, in order to give full effect to Standard A2.1, paragraph 4. TheCommittee notes that the content of the draft SEA submitted by the Government is in line with Standard A2.1, paragraph 4. The Committee reiterates however that the Ghana Shipping Act, 2003does not contain all the matters that should be included in a SEA according to the Convention. The Committee therefore requests the Government to amend the Ghana Shipping Act, 2003, in order to give full effect to Standard A2.1, paragraph 4.

Regulation 2.1 and Standard A2.1, paragraph 6. Seafarers’ employment agreement. Termination. Shorter notice period for urgent reasons. The Committee requested the Government to specify what would be considered “exceptional circumstances” under regulation 13(11) of the Shipping Regulations and to indicate if compassionate reasons are taken into account.The Committee notes that the draft SEA provided by the Government includes a list of circumstances that lead to an earlier termination of a SEA, one of them being when a seafarer needs to terminate the agreement without notice on grounds of injury, illness, compassionate or other urgent reasons. While noting this information, the Committee requests the Government to adopt the necessary measures to ensure that these requirements are incorporated into national laws or regulations in order to fully comply with the Convention.

Regulation 2.1 and 2.2 and Standard A2.1, paragraph 7 and Standard A2.2, paragraph 7. Seafarers’ employment agreements and wages. Captivity as a result of acts of piracy or armed robbery against ships. In relation to the 2018 amendments to the Code, the Committee draws the Government’s attention to the following questions included in the revised report form for the Convention: a) do laws or regulations provide that a seafarer’s employment agreement shall continue to have effect while the seafarer is held captive on or off the ship as a result of acts of piracy or armed robbery against ships?; b) how are the terms piracy and armed robbery against ships defined under national legislation? (Standard A2.1, paragraph 7); and c) do laws or regulations provide that wages and other entitlements under the seafarers’ employment agreement, relevant collective bargaining agreement or applicable national laws, including the remittance of any allotments, shall continue to be paid during the entire period of captivity and until the seafarer is released and duly repatriated or, where the seafarer dies while in captivity, until the date of death in accordance with national legislation? (Standard A2.2, paragraph 7). The Committee requests the Government to reply to the above-mentioned questions, indicating in each case the applicable national provisions.

Regulation 2.2 and Standard A2.2, paragraphs 1 and 2. Wages. Regular payment. Monthly account. Recalling the importance to avoid inconsistencies between national provisions, the Committee requested the Government to indicate the measures taken to amend the Ghana Shipping Act, 2003 in order to give full effect to Standard A2.2, paragraphs 1 and 2. While noting that regulation 14 of the Shipping Regulations as well as the draft SEA provided by the Government implement the requirements of Standard A2.2, the Committee again requests the Government to consider amending the Ghana Shipping Act, 2003 in order to give full effect to Standard A2.1, paragraphs 1 and 2.

Regulation 2.2 and Standard A2.2, paragraph 6. Wages. Deductions. The Committee requested the Government to indicate how it has given due consideration to Guideline B2.2.2, paragraph 4(h). Noting that the Government does not provide information on this point, the Committee reiterates its previous request.

Regulation 2.3 and Standard A2.3, paragraph 14. Hours of work and hours of rest. Immediate safety and distress at sea. The Committee requested the Government to take the necessary steps to ensure the application of Standard A2.3, paragraph 14. The Committee notes that the draft SEA states in section 3 (Hours of Rest) that “the seafarer may be required, at the discretion of the master, to work additional hours during an emergency; (a) which threatens the safety of the ship; (b) which threatens the safety of a person on board the ship; (c) which may result in damage to cargo; or (d) for the purpose of giving assistance to other ships or persons in distress at sea. The seafarer may also be required to work additional hours for the safety drills such as musters, fire-fighting and lifeboat drills. In such situation the seafarer will be provided subsequently with Compensatory rest period(s).” The Committee notes that pursuant to StandardA2.3, paragraph 7, musters, fire-fighting and lifeboat drills, and drills prescribed by national laws and regulations and by international instruments, shall be conducted in a manner that minimizes the disturbance of rest periods and does not induce fatigue. Therefore, seafarers performing such works are entitled to compensatory rest. However, Standard A2.3, paragraph 14 broadens the circumstances where a seafarer is entitled to compensatory rest, explicitly including the situations where the scheduled duty periods are extended due to an emergency: (a) which threatens the safety of the ship; (b) which threatens the safety of a person on board the ship; (c) which may result in damage to cargo; or (d) for the purpose of giving assistance to other ships or persons in distress at sea. The Committee therefore requests the Government to take the necessary steps to ensure full compliance also with Standard A2.3, paragraph 14.

Regulation 2.4 and Standard A2.4, paragraph 3. Regulation 2.5 and Standard A2.5.1, paragraph 2(b). Possible exceptions to the prohibition to forgo paid annual leave. Maximum period of service on board. Noting the absence of information on this point, the Committee requests the Government to take the necessary measures to ensure full conformity with Standard A2.4, paragraph 3 and Standard A2.5.1, paragraph 2.

Regulation 2.4 and Standard A2.4, paragraph 3. Entitlement to leave. Prohibition of agreements to forgo annual leave. Noting that the Government does not provide information on this point, the Committee reiterates its previous request.

Regulation 2.5 and Standard A2.5.1, paragraphs 1 and 2(a). Repatriation. Circumstances. The Committee requested the Government to indicate how it ensures that the financial security provided by the shipowners covers all the cases of seafarers’ repatriation foreseen in Standard A2.5.1, paragraph 1. Noting that the Government does not provide information on this point, the Committee reiterates its previous request.

Regulation 2.5 and Standard A2.5.1, paragraph 2(b). Repatriation. Maximum period of service on board. Recalling that Standard A2.5, paragraph 2(b), provides that national laws or regulations, other measures, or collective bargaining agreements, should prescribe “the maximum duration of service periods on board following which a seafarer is entitled to repatriation – such periods to be less than 12 months”, the Committee requested the Government to take the necessary measures to give effect to this requirement of the Convention. Noting the absence of information on this point, the Committee reiterates its previous request.

Regulation 2.5 and Standard A2.5.1, paragraph 2(c). Repatriation. Entitlements. The Committee requested the Government to provide information as to how it has given due consideration to Guideline B4.1.1, paragraph 7 which states that seafarers should have the right to choose from among the prescribed destinations the place to which they are to be repatriated. Noting that the Government does not provide information on this point, the Committee reiterates its previous request.

Regulation 2.5 and Standard A2.5.2. Repatriation. Financial security. The Committee requested the Government to indicate the national provisions implementing the 2014 amendments to the Code of the Convention. The Committee notes that the Government does not provide information on legislative provisions giving effect to these provisions of the Convention. The Committee recalls that, in conformity with Regulation A2.5, paragraph 2, each Member shall require ships that fly its flag to provide financial security to ensure that seafarers are duly repatriated in accordance with the Code. The Committee requests the Government to adopt the necessary measures to give effect to these requirements of the Convention.

Regulation 2.7 and Standard A2.7, paragraph 3. Manning levels. Food and catering. The Committee requested the Government to take the necessary measures to ensure that full effect is given to Standard A2.7, paragraph 3. The Committee notes the Government’s indication that it took note of the legislation gap and will have stakeholders’ consultation to amend the law to give effect to the provisions of the Convention. Reiterating that a fully qualified cook should be carried on board all ships except on those operating with a prescribed manning of less than ten, the Committee requests the Government to adopt the necessary measures to give effect to Standard A2.7, paragraph 3 and Standard A3.2 paragraph 5.

Regulation 3.1, paragraph 2. Accommodation and recreational facilities. Scope of application. Requirements for ships constructed prior to the entry into force of the MLC, 2006. The Committee requested the Government to provide detailed information concerning the implementing legislation for ships that continue to fall under the application of the Accommodation of Crews Convention (Revised), 1949 (No. 92). The Committee notes the Government’s indication that it took note of the legislation gap and will have stakeholders’ consultation to amend the law to give effects to the provisions of the Convention. Recalling, that Regulation 3.1, paragraph 2, provides that, for ships constructed before the date of its entry into force, the requirements relating to ship construction and equipment that are set out in Convention No. 92 shall continue to apply to the extent that they were applicable, prior to that date, under the law or practice of the Member concerned, the Committee requests the Government to adopt the necessary measures to give effect to Regulation 3.1, paragraph 2 and to provide information on any development in this regard.

Regulation 3.1 and Standard A3.1, paragraphs 2(a) and 17. Accommodation and recreational facilities. Occupational safety and health and accident prevention requirements.The Committee requested the Government to provide information on the implementation of Standard A3.1, paragraphs 2(a) and 17. The Committee notes the Government’s indication that it is in the process of publishing a maritime circular for the purpose of issuing guidelines for the management of occupational health and safety of a seafarer and accident prevention. The Committee requests the Government to indicate the concrete measures taken to give effect to Standard A3.1, paragraphs 2(a) and 17.

Regulation 3.1 and Standard A3.1, paragraph 3. Accommodation and recreational facilities. Flag State inspection.The Committee requested the Government to provide information on how effect is given to the requirement of Standard A3.1, paragraph 3. The Committee notes the Government’s indication that it is working towards the implementation of this provision. Recalling that pursuant to Standard A3.1, paragraph 3, the inspections required under Regulation 5.1.4 shall be carried out when (a) a ship is registered or re-registered or (b) the seafarer accommodation on a ship has been substantially altered, the Committee requests again the Government to adopt the necessary measures to give effect to Standard A3.1, paragraph 3 and to provide information on any development in this regard.

Regulation 3.1 and Standard A3.1, paragraph 19. Accommodation and recreational facilities. Variations. Religious and social practices.The Committee requested the Government to explain how it gives effect to Standard A3.1, paragraph 19. The Committee takes note of the Government’s indication that the 1992 Constitution of Ghana, being the supreme law of Ghana, prohibits all forms of discrimination. In this regard, in the application and interpretation of section 29 of the Shipping Regulations, due regard is given to the provisions of Chapter 5, Article 17 of the 1992 Constitution. The Committee takes note of this information.

Regulation 3.1 and Standard A3.1, paragraphs 20 and 21. Accommodation and recreational facilities. Exemptions.The Committee requested the Government to ensure that all exemptions to the application of the Shipping Regulations are made within the limitations provided for under Standard A3.1, paragraphs 20 and 21. The Committee takes note of the Government’s indication that it took note of the legislation gap and will adopt the necessary legislative amendments to give effect to the provisions of the Convention. The Committee requests the Government to indicate all measures taken in this regard.

Regulation 3.2, paragraph 1, and Standard A3.2, paragraph 2(a). Food and catering. Religious and cultural practices.The Committee requested the Government to provide information in relation to the requirement that the differing cultural and religious backgrounds of seafarers are taken into account when determining the suitability of food supplies. The Committee takes note of the Government’s indication that it took note of the legislation gap and will make legislative amendments to give effect to the provisions of the Convention. The Committee requests the Government to provide information on the measures taken in this respect.

Regulation 3.2 and Standard A3.2, paragraph 6. Food and catering. Dispensation permitting a non-fully qualified cook.The Committee requested the Government to indicate the measures taken to ensure that dispensations permitting a non-fully qualified cook to serve as a ship’s cook are in conformity with Standard A3.2, paragraph 6. The Committee notes the Government’s reply and its indication that it will have stakeholders’ consultation to amend the law to give effect to the provisions of the Convention. The Committee requests the Government to adopt the necessary measures to give full effect Standard A3.2.

Regulation 4.1, paragraph 3. Medical care on board and ashore. Access to on shore medical facilities for seafarers on board foreign ships.The Committee requested the Government to provide information on the measures adopted to give effect to Regulation 4.1, paragraph 3, regarding the obligation as a port State to ensure that seafarers on board ships in Ghanaian territory who are in need of immediate medical care are given access to the Member’s medical facilities on shore. The Committee takes note of the Government’s indication that the Ghana Maritime Authority will provide the appropriate documentation on actionable activities on future cases. It also notes that the Guidelines on Medical Examination of Seafarers, transmitted by the Government, reproduce the wording of Regulation 4.1, including paragraph 3. The Committee notes that although the Guidelines contain the relevant provisions implementing the Convention, the national legislation in force does not give effect to the requirements of Regulation 4.1, paragraph 3. The Committee therefore requests the Government to align its legislation with these provisions of the Convention.

Regulation 4.1 and Standard A4.1, paragraph 4(d). Medical care on board and ashore. Minimum requirements. Medical advice by radio or satellite.The Committee requested the Government to indicate how it ensures that the requirement under Standard A4.1, paragraph 4(d) applies to all ships voyaging in Ghanaian waters irrespective of the flag that they fly. The Committee takes note of the Government’s indication that it will provide available information in due course. It also notes that the Guidelines on Medical Examination of Seafarers, annexed to the Government’s second report, reproduce the wording of Standard A4.1, paragraph 4(d). The Committee takes note of this information.

Regulation 4.2 and Standard A4.2.1, paragraph 7. Shipowners’ liability. Safeguarding of property left on board. The Committee requested the Government to indicate the measures taken to amend the Ghana Shipping Act, 2003, to ensure full conformity with this requirement of the Convention. The Committee notes the Government’s indication that it took note of the legislation gap and will adopt legislative amendments to give effect to the provisions of the Convention. The Committee requests the Government to indicate the measures taken in this regard.

Regulation 4.2 and Standards A4.2.1, paragraphs 8–14, and A4.2.2. Shipowners’ liability. Financial security. The Committee requested the Government to indicate the national provisions implementing the 2014 amendments to the Code. The Committee takes note of the Government’s indication that it will amend the law to reflect the provisions of the Convention. The Committee requests the Government to adopt legislation giving effect to the 2014 amendments and to reply to the relevant questions identified in its previous request. The Committee also requests the Government to provide a copy of a model certificate or other documentary evidence of financial security containing the information required in Appendix A4-I of the Convention (Standard A4.2.1, paragraph 14).

Regulation 4.3 and Standard A4.3. Health and safety protection and accident prevention. The Committee requested the Government to provide detailed information on: (i) any national laws and regulations and other measures adopted and their regular review in consultation with representatives of the shipowners’ and seafarers’ organizations, in accordance with Regulation 4.3, paragraph 3, and Standard A4.3, paragraphs 1–3; (ii) the development, after consultation with representative shipowners’ and seafarers’ organizations, of national guidelines for the management of occupational safety and health to protect seafarers that live, work and train on board ships flying its flag, and to provide a copy of them when available (Regulation 4.3, paragraph 2); (iii) the implementation of the requirement that a safety committee – including a seafarers’ representative – be established on all ships with five or more seafarers (Standard A4.3, paragraph 2(d)); and (iv) the reporting, investigation and statistics on occupational accidents, injuries and diseases in accordance with Standard A4.3, paragraphs 5 and 6. The Committee notes the Government’s indication that it is in the process of enacting regulations to address occupational safety and health protection of seafarers as envisaged under the MLC, 2006, which will be communicated in the next report. The Committee requests the Government to adopt the necessary measures, without further delay, to give effect to these requirements of the Convention.

Regulation 4.5 and Standard A4.5, paragraph 6. Social security. Comparable benefits for seafarers in the absence of adequate coverage.The Committee requested the Government to specify whether maritime circulars have been adopted or are envisaged, in accordance with regulation 35(2) of the Shipping Regulations, to provide seafarers from countries that are not party to the Convention but work on board ships flying the Ghanaian flag, with access to social security protection. The Committee notes the Government’s indication that it will issue a maritime circular to ensure that seafarers from non-party States working on board ships flying the national flag have access to social security protection. The Committee requests the Government to provide information on any developments in this regard.

Regulation 5.1.1 and Standard A5.1.1, paragraph 2. Flag State responsibilities. Copy of the MLC, 2006, on board. Recalling that pursuant to Standard A5.1.1, paragraph 2, each Member shall require all ships that fly its flag to have a copy of the Convention available on board, the Committee requested the Government to indicate how it ensures compliance with this requirement of the Convention. The Committee takes note of the Government’s indication that it will amend the law to reflect the provisions of the Convention. The Committee requests the Government to provide information in this respect.

Regulation 5.1.3 and Standard A5.1.3. Flag State responsibilities. Maritime Labour Certificate and Declaration of Maritime Labour Compliance. Interval and scope of inspections.The Committee requested the Government to indicate how it gives effect to the requirements of the Convention with respect to the interval of inspections, as well as how it ensures that the 16 areas listed under Appendix A5-I of the Convention are subject to inspection. The Committee notes the Government’s indication that it will issue a maritime circular to fill the legislative gap. The Committee requests the Government to adopt the necessary measures to comply with these requirements of the Convention and to provide information on any developments in this regard.

Regulation 5.1.3 and Standard A5.1.3, paragraph 10. Flag State responsibilities. Declaration of Maritime Labour Compliance. Content. The Committee requested the Government to send a copy of the Maritime Labour Certificate, as well as examples of Part II of the DMLC which have been prepared by a shipowner and have been accepted when certifying ships. The Committee notes that the Government did not provide the requested information. Reiterating that the examination of these documents is crucial to assess the correct implementation of the Convention, the Committee once again requests the Government to send the requested documents.

Regulation 5.1.4 and Standard A5.1.4, paragraphs 3, 6, 11(a) and 17. Flag State responsibilities. Inspection and enforcement. Qualification, status and conditions of service of inspectors. The Committee requested the Government to indicate how it gives effect to Standard A5.1.4, paragraphs 3, 6, 11(a) and 17. The Committee notes the Government’s indication that a policy framework is being prepared to address these matters. The Committee requests the Government to adopt the necessary measures to give effect to these requirements of the Convention and to provide information any developments in this regard.

Regulation 5.1.4 and Standard A5.1.4, paragraph 12. Flag State responsibilities. Inspection and enforcement. Reporting on inspections.In the absence of information, the Committee requests once again the Government to specify how it gives effect to the requirement of Standard A5.1.4, paragraph 12, including arrangements for inspectors to submit a report of each inspection to the competent authority, as well as a copy to the master of the ship and that an additional copy be posted on the ship’s notice board for the information of the seafarers, and upon request, sent to their representatives.