Summary
These Regulations amend the Merchant Shipping (Working Time: Inland Waterways) Regulations 2003, expanding definitions (free health assessment, passenger, pleasure vessel, rest day, shift worker, work schedule, working day, workstation, reference period), replacing the general exception provision with specific working time limits (14 hours daily, 84 hours weekly, 2,304 hours annually, 48-hour average weekly), introducing rest break entitlements (20-minute minimum for shifts over 6 hours), limiting consecutive working days to 31 with calculated rest day requirements, adding night work limits (42 hours weekly), expanding health assessment requirements, and creating a seasonal work exception for passenger ships allowing 12-hour days and 72-hour weeks.
Reason
These regulations impose substantial compliance burdens on small inland waterway operators through prescriptive working time limits (14-hour daily, 84-hour weekly maxima), mandatory health assessments, detailed record-keeping requirements, and complex rest day calculations. The amendment expanded the original 2003 regime without clear evidence of safety failures justifying the additional restrictions. Worker protections in this sector can be better addressed through individual employment contracts and industry standards, allowing flexibility that rigid statutory limits cannot provide. The administrative cost of compliance falls disproportionately on smaller operators while providing questionable marginal benefits over market-negotiated arrangements.