                      REPORT OF THE TASK 89 WORKING GROUP
                             September 29-30, 2015
 The working group requests that MERPAC accept the recommended changes to the following Modules
 MSC Circ  1014 Module 1 Fatigue Causes and Consequences 22092015 Australia - US Comments
 MSC Circ 1014 Australia Module 3 Fatigue and the Seafarer Revised - US Comments
 MSC Circ 1014 Module 4- Fatigue and Training Australia draft 250915 20150930
 MSC Circ. 1014 Module 5 - Fatigue and Ship Design Australia Draft 290915 MERPAC 20150930
      MERPAC should note that the recommended changes to Modules 4 & 5 are minimal.  It was felt that there was insufficient representation by the relevant sectors of the maritime industry to provide more detailed input on these modules.
MERPAC recommends that these modules be forwarded to Australia in order to provide initial input into their paper on this subject.
 The working group upon review of Australia's second draft of Module 2 that again suggests that ship owner/operators development a Formal Risk Management System(FRMS) is the only option available to them, determined that MERPAC's response to the first draft by Australia should stand and be submitted to the IMO as an alternative to the Australian submission. Therefore;
 MERPAC recommends that the U.S. submit the MERPAC approved Module 2 to HTW as a separate paper and include the following points for HTW to consider regarding the revision of MSC 1014.
 A FRMS is not the only option for Companies to address fatigue in a risk based manner, as illustrated in our version of module 2.
 A FRMS would be difficult to implement for many operators
 Must avoid any additional administrative burdens for the seafarer and the company(e.g. formal FRMS)
 Must avoid any additional PSC burden on seafarers
 Must protect the privacy of seafarers
 Guidance should be written for intended audience (not technical experts).  (written at the reading level of general seafarers, KISS keep it short and simple, etc.)
 Avoid confrontational tones and language in writing (e.g. insidious)
 Reference all referred to research as per IMO guidelines
 Measures should be scalable to all modes of maritime transportation. 
 If HTW accepts the US version of module 2 then module 3(seafarer) must be amended to delete the seafarer's obligations under the FRMS
