The short version
- MLC 2006 Standard A4.1 requires a medicine chest, medical equipment and a medical guide on every covered ship.
- Inspection is at least every 12 months, and the documentation must be available to the flag inspector.
- Contents are not set by MLC. The working standard is the WHO guide, and in Europe the Category A, B and C scheme.
- US commercial fishing vessels sit outside that framework entirely, under 46 CFR 28.210.
- Controlled substances in the chest trigger a separate US regime under 21 CFR 1301.25.
A fleet manager with vessels on two registers has two different medicine chest obligations, and the difference is not obvious from either rulebook. The flag state sets the specifics; MLC 2006 only sets the floor beneath them.
This page compares the flag-state requirements operators meet most often, cites each to its source, and marks where a US rule replaces the international one. For the managed service, see MedChest. For help deciding which rules apply to your fleet, see Consulting.
What every flag state starts from
MLC 2006 Standard A4.1(4)(a) requires ships to carry a medicine chest, medical equipment and a medical guide, with specifics prescribed by the competent authority and inspected at regular intervals[1].
Two further paragraphs matter to procurement. A4.1(4)(b) requires a qualified medical doctor aboard where 100 or more persons sail an international voyage of more than three days[1]. A4.1(4)(d) gives every vessel a right to free medical advice by radio or satellite, at any hour[1]. That last right is free, and no vendor can charge you for it.
Flag-state requirements compared
Each row below is drawn from the flag authority’s own published notice. Verify against the current issue before you act, because notices are revised.
| Flag or framework | Instrument | Inspection interval | Documentation | Notable requirement |
|---|---|---|---|---|
| Marshall Islands (RMI) | MN 7-042-1 | Not exceeding 12 months | Carried aboard, verified at annual flag inspection | Follows MLC A4.1, chest plus equipment plus medical guide |
| Panama | MMC-339 | Per circular, aligned to MLC | Held aboard for port and flag inspection | Doctor required at 100+ persons on international voyages over 3 days |
| United States, commercial fishing | 46 CFR 28.210 | Per the regulation | Records with the vessel | First aid equipment and training, separate from the MLC scheme |
| EU member flags | Directive 92/29/EEC | Annual | Inspection record aboard | Category A, B and C by voyage type, with a defined contents scheme |
| MLC 2006 floor, all flags | Standard A4.1 | At least every 12 months | Documented inspection | Chest, equipment and medical guide, plus free 24-hour medical advice |
How often must the chest be inspected?
At least every 12 months is the answer in nearly every case. Guideline B4.1.1 sets inspection at regular intervals not exceeding 12 months[1], and the Marshall Islands notice MN 7-042-1 restates it, adding that certification must be carried aboard and is verified during the annual flag inspection[2].
What an inspector actually checksLabelling, expiry dates, storage conditions and the directions for use, plus the record showing when this was last verified and by whom. A chest that is fully stocked but undocumented still fails.
US vessels: the rule most operators miss
There is no single US regulation prescribing medicine chest contents for all vessels. The literal medicine chest requirement most US operators meet sits at 46 CFR 28.210, covering first aid equipment and training on commercial fishing industry vessels[3].
Operators who assume the MLC framework covers them, and then discover their fishing vessels answer to a different part of the CFR, are the most common case we see. If that describes your fleet, the consulting assessment exists for exactly this.
Who decides what goes in the chest?
MLC deliberately does not publish a contents list. In practice two references fill the gap. The WHO International Medical Guide for Ships, third edition, with its Quantification Addendum, is the international working standard[4]. In European waters, EU Directive 92/29/EEC defines the Category A, B and C scheme by voyage type[5].
Common misattributionThe Category A, B and C scheme is European Union law, not a WHO, IMO or ILO instrument. We have seen it cited to the wrong body in vendor material and even in internal procedures. Cite it to Directive 92/29/EEC.
Four ways operators fail the inspection
Ranked by how often we find them.
- No inspection record. The chest is compliant, the paperwork proving it is not aboard.
- Expiry drift. Restocking happens, the expiry review does not, and one item ages out between annual checks.
- Wrong reference standard. The chest is built to a generic kit list rather than the flag state’s own notice.
- Controlled substances handled as ordinary stock. This is the expensive one. It engages 21 CFR 1301.25 and a separate record regime[6]. See our 21 CFR 1301.25 walkthrough and the Controlled Substances service.
Common questions
How often must a ship’s medicine chest be inspected?
At least every 12 months. MLC 2006 Guideline B4.1.1 sets inspection at regular intervals not exceeding 12 months, and flag states restate it. The Marshall Islands notice MN 7-042-1 requires the documentation to be carried aboard and verified at the annual flag inspection. See MedChest.
Which flag state rules apply to my vessel?
Your flag of registry sets the specifics, within the MLC 2006 Standard A4.1 floor. A vessel on the Marshall Islands register follows RMI notices; a Panama-flag vessel follows MMC-339. If you are unsure which applies to your fleet, that is exactly what our consulting engagement answers.
Does a US commercial fishing vessel need a medicine chest?
It has its own rule. 46 CFR 28.210 sets first aid equipment and training requirements for commercial fishing industry vessels, separate from the MLC framework that governs international trade. Many US fishing operators are surprised by this. Read the MedChest service.
What should the chest actually contain?
MLC does not publish a universal contents list. The working standard is the WHO International Medical Guide for Ships with its Quantification Addendum, and in European waters the Category A, B and C scheme from EU Directive 92/29/EEC. Your flag state may add to either.
Do controlled substances in the chest have separate rules?
Yes, and this is where most programs break. Carrying controlled substances aboard a US-linked vessel engages 21 CFR 1301.25, which requires a DEA-registered medical officer or the master requisition route. See Controlled Substances and our walkthrough of 21 CFR 1301.25.
Who can inspect and certify the chest?
Flag states generally expect a designated person aboard or a qualified party ashore to verify labelling, expiry dates, storage conditions and directions for use, then document it. Discovery Health MD physicians run this as a managed service. Ask us to scope your fleet.
