Panama: circular regarding the on-board complaints procedure

The Panama Maritime Authority has released a merchant marine circular (MMC-264) regarding the on-board complaints procedure.

This Circular informs users of the Panamanian Registry that all Panamanian ships, in compliance with the Maritime Labour Convention, 2006 (MLC, 2006), must maintain on-board procedures for handling seafarer complaints related to MLC, 2006 violations, available in English or the ship's spoken language.

This Merchant Marine Circular applies to all seafarers, ship-owners, operators, and companies under MLC, 2006.

Seafarers may use on-board procedures to report any alleged MLC, 2006 violations.

Each vessel or company must establish on-board procedures for handling complaints.

Seafarers can present complaints directly to the ship's master or, if needed, to competent authorities, such as Port State Control or Flag State inspectors.

On-board procedures must ensure seafarers' rights to be represented and protected against harassment for filing non-malicious complaints.

Panamanian-flagged vessels must provide seafarers with on-board complaint procedures and their employment agreements, including contact information for competent authorities and impartial advisors on board.

The complaint process starts with the department head or superior officer, who has five days to resolve the matter. If unresolved, seafarers can refer the complaint to the ship's master and have a companion on board.

A complaint record book must be kept on board. Unresolved complaints can be referred to the ship owner, who has eight days for resolution. Seafarers can also report complaints to competent authorities.

If a complaint remains unresolved after eight days, an additional 22 days may be granted to seek a solution, recorded in ship registries, and reported to authorities.

Harassment of seafarers filing complaints is strictly prohibited.

This circular was released on 1 October 2023.

For more information, please see the document below (available only to subscribers):