MLC 2006 Standard A5.1.5 requires every flag state to ensure that every ship carries and displays a written onboard complaint procedure, posted at a place accessible to all seafarers — typically the messroom noticeboard. That procedure must name the persons in the chain of escalation: head of department, master, and from the master directly to the shipowner (DPA). Critically, the procedure must allow you to accompany or be represented during any stage of the complaint process, and it must explicitly protect you from victimisation. If you are afraid to raise a matter through the master because the master is the problem, the Standard permits direct complaint to the shipowner — the DPA contact is posted per the ISM Code. Filing a formal onboard complaint creates a paper trail that is later evidence for flag-state and port-state proceedings. The posting obligation means that a ship without a visible complaint procedure is already in breach and is a valid PSC deficiency in its own right. For the full technical treatment of complaint pathways, see /reference/mlc.
What this usually means
MLC 2006 Regulation 5.1.5 requires every flag state to provide an onboard complaints procedure, and Regulation 5.2.2 requires every port state party to provide a procedure for handling complaints from seafarers in their ports. A formal complaint can result in port-state inspection, deficiency notes, and — for serious failures — vessel detention. Use this when the onboard complaints process has failed or where the ship is non-compliant in ways that affect crew welfare.
Step-by-step
Exhaust the onboard procedure first: speak to the head of department, then the Master, then submit a written complaint per the procedure posted in the messroom (required by Standard A5.1.5).
If onboard escalation fails or is unsafe: file with the flag state's maritime administration (contact details on the MLC-DMLC Part II) — this is your primary route.
If the flag state does not act, file with the port state in your current or next port. Most port-state regimes (Paris MoU, Tokyo MoU, USCG, AMSA) accept written complaints from any seafarer.
For organised support: ITF inspector at the port can submit on your behalf and back the complaint with a vessel visit. ISWAN provides case management.
Provide: copy of SEA, photographs of the issue (e.g. accommodation, food, working conditions), timeline of complaints already raised, witness names where willing.
PSC officers cannot identify you to the Master without your consent. Insist on this in the complaint.
Evidence to save
Photograph of the onboard complaint procedure notice posted in the messroom — includes the names of the contact persons in the chain.
Copies of your written complaint and any written acknowledgement from the head of department or master.
Record of the date the complaint was filed and the date (if any) a response was given.
Witness names of crew members who can confirm the facts of your complaint, if they are willing.
Written record of any retaliation — duty schedule changes, cabin reassignment, increased workload, verbal threats — with dates and witnesses.
Copies of any subsequent written communication with the DPA or shipowner.
Screenshot or photograph of any removal or defacing of the onboard complaint procedure notice.
What NOT to sign
A 'withdrawal of complaint' form before the matter has been properly investigated and a remedy provided.
Any agreement to keep the complaint confidential from the flag state or PSC — you cannot be bound to silence about MLC non-compliance.
A document that characterises your complaint as 'resolved' when the underlying issue has not been corrected.
A new employment contract or 'agreement' that trades resolution of the complaint for waiver of past claims.
Any disciplinary notice issued to you in direct response to a complaint you filed — challenge it in writing immediately.
Escalation path
Step 1: Raise the matter verbally with your head of department. If no resolution within a reasonable time, move to the written procedure.
Step 2: Submit a written complaint to the master, per the posted procedure. Request a written acknowledgement with a date.
Step 3: If the master is the subject of the complaint, or fails to act within the procedure timeline: write directly to the DPA / shipowner (ISM Code confidentiality applies to DPA contact).
Step 4: If no remedy after the shipowner stage: file with the flag state's maritime administration using the contact on the DMLC Part II.
Step 5: File with the port state PSC at the current or next port — parallel to or after the flag-state step. PSC cannot disclose your identity to the master without your consent.
Step 6: Contact the ITF inspector, ISWAN SeafarerHelp, or Human Rights at Sea for third-party support and case management throughout.
Legal basis
MLC 2006 Regulation 5.1.5 (onboard complaint procedures), Regulation 5.2.2 (onshore seafarer complaint-handling procedures), Standard A5.2.2 (procedural requirements for the port state). Paris MoU and Tokyo MoU concentrated inspection campaigns periodically focus on MLC compliance.
Disclaimer. General information only — not legal advice. Rules vary by flag state, port state, vessel type, applicable CBA, and contract. Where a fact below is critical to your case, verify against the cited source and consider professional advice.