• The vessel operator should demonstrate a suitable system in place to record rest hours and calculate conformance in any 24 hour and 7 day period, for each individual onboard, based on the governing requirements of STCW and MLC, or the vessel’s applicable regulations. • Any duties performed outside a seafarer’s normal working hours, should be recorded against their daily records. • Monthly non-conformance reports should be submitted to shore management, who should acknowledge the occurrence of 3 or more days’ non-conformance by any individuals in any 30 day period.