The short version
- The 2022 amendments entered into force on 23 December 2024 and medical care on board ship and ashore is one of the seven topics.
- The medical change concerns prompt disembarkation and access to medical facilities ashore, plus repatriation of a deceased seafarer.
- The chest, medical equipment, medical guide, inspection interval and doctor thresholds are NOT among the named changes.
- The United States has not ratified MLC 2006, so none of it binds a US-flagged hull directly.
- The action item is a procedure, not a purchase.
The 2022 amendments to the Maritime Labour Convention entered into force on 23 December 2024, and medical care on board ship and ashore is one of the topics they change[1]. Most circulars covering them run to every topic at once, which makes it hard to answer the only question an operator actually has: does anything about my medical program have to change.
The short answer is that one thing does and several things people assume do not. The distinction is worth getting right, because acting on the wrong half means buying stock you did not need while leaving a procedure unwritten.
Where medical care sits among the amendments
The ILO groups the 2022 set under seven headings. Medical care is one of them, alongside recruitment and placement, repatriation, accommodation and shore-based welfare access, food and catering, health and safety protection and accident prevention, and financial security[1].
The medical change, in the ILO’s own framing
Seafarers are to be “promptly disembarked when they are in need of immediate medical care and are given access to medical facilities ashore in cases of, among others, any serious injury or disease”. Separately, Member States facilitate repatriation by the shipowner of the body or ashes of seafarers who have died on board[1].
Read what that is about. It is access and movement of people, not equipment. The amendment addresses getting a sick seafarer ashore and getting a deceased seafarer home. Neither is a stocking question.
The context explains the shape. The 2022 set was developed substantially out of the COVID-19 period, when seafarers were refused shore leave, denied disembarkation for treatment and left aboard long past the end of their agreements. The medical amendment is a response to people being kept on ships, not to ships being under-equipped. That is why it lands on procedures and port relationships rather than on inventory.
It also means the compliance evidence looks different from what most medical files hold. A chest audit produces a list and a signature. A disembarkation obligation produces a decision record: when advice was sought, what was advised, which port was selected and why. Very few operators keep the second, and it is the one the amendment implicitly asks for.
What did not change, and why that matters more
This is the half that saves money. Nothing in the summarised medical amendments touches the chest, its contents, the medical equipment, the medical guide or the inspection interval[1]. Those obligations sit where they always did.
| Element | Status after 23 December 2024 | Where the obligation still comes from |
|---|---|---|
| Prompt disembarkation and shore access | Changed, and this is the amendment[1] | Update the procedure, not the chest |
| Repatriation of a body or ashes | Changed, Member States facilitate it[1] | A shipowner obligation with a state facilitation duty |
| Medicine chest, equipment, medical guide | Not among the named changes | Standard A4.1(4)(a), plus your flag state notice[2] |
| Inspection interval | Not among the named changes | Guideline B4.1.1, at most twelve months. EU flags, annual under 92/29/EEC[2][4] |
| Doctor and sick bay thresholds | Not among the named changes | 100 persons on an international voyage over three days[2] |
| Controlled substances | Outside MLC entirely | National law. For US registration, 21 CFR 1301.25[7] |
If a supplier has told you the 2024 amendments require a chest upgrade, ask which amendment. On the published summary the answer is none of them[1]. The chest standard still derives from A4.1(4)(a) and your flag, set out in requirements by flag state and, for EU tonnage, the 92/29/EEC categories.
Who this binds, and who it does not
An amendment to MLC binds vessels flying the flag of a ratifying state. The United States has not ratified MLC 2006[2], so no part of this reaches a US-flagged hull directly.
That is a narrower exemption than it sounds, because most operators do not have a single answer. A company running domestic US tonnage alongside a foreign-flag charter is bound on one hull and not the other, with the same crewing office and often the same written procedure covering both. The safe course is to identify which hulls the amendment reaches before deciding whether the procedure needs one version or two.
| Your position | What the 2024 amendments mean for you |
|---|---|
| Ratifying flag, international trading | Directly binding. Review the disembarkation and shore-access procedure and the deceased-seafarer arrangements |
| US flag, calling at ratifying ports | Not binding on the hull. Port state expectations still shape the encounter, so a documented procedure is worth having anyway |
| US operator managing ratifying-flag tonnage | Binding for that tonnage. The flag travels with the hull, not the head office. See changing flag state |
| US fishing vessel, domestic | Outside MLC. Obligations are 46 CFR part 28 and 21 CFR 1301.25[5][7]. See the six federal obligations |
How to test a supplier claim against an amendment
Regulatory change is a selling season. Four questions settle almost any claim that a new rule requires a purchase, and none of them needs a lawyer.
| Ask this | What a good answer looks like |
|---|---|
| Which instrument, and which provision? | A named Standard or Regulation, not “the new MLC rules”. If they cannot name it, there is nothing to comply with |
| Does it bind my flag? | An amendment reaches ratifying states. A US-flagged hull is outside MLC entirely[2] |
| Is it a process change or a stock change? | The 2024 medical amendment is about disembarkation and shore access, which is a procedure[1] |
| What was the obligation before? | If the answer is the same, nothing changed for you. Chest obligations still run from A4.1(4)(a) and your flag notice[2] |
This project has documented three separate cases of search results serving instruments that were withdrawn or expired, so a claim that sounds authoritative is not the same as one that is current. The same discipline applies to a DEA rulemaking that was opened and then dropped, covered in the vessel rule changes, and to what a port state officer will actually ask for, in what a PSCO checks.
What to actually do about it
- Confirm the flag ratified MLC. If it did not, most of this is background reading[2].
- Write or revise the disembarkation procedure. Who decides, who is called, how the port is selected and how it is recorded. That is the amendment made operational[1]. The decision framework is in when to disembark or evacuate.
- Check the deceased-seafarer arrangement exists at all. Most procedures are silent on it, and it is now named in the amendments[1].
- Do not touch the chest on account of this. Verify the standard against your flag notice and leave it alone if it complies[6]. The stocking method is in how to stock a ship medicine chest.
- Diarise the next port call as the test. A PSC officer works from your certificate and DMLC, covered in what a PSCO checks.
Step two is the whole job. Everything else is confirming that something did not change, which is the cheapest work in compliance and the most commonly skipped. If you would rather have a physician read the amendment against your fleet, that is consulting, and MedChest holds the chest side. Accountability for the file itself is covered in owner or DPA.
Common questions
Did the 2024 MLC amendments change the medicine chest requirements?
Not among the named changes. The ILO summary groups the 2022 amendments under seven headings, one of which is medical care on board ship and ashore, and the medical changes it describes concern disembarkation and access to care ashore, not chest contents, equipment or the medical guide[1]. Our MedChest service tracks that distinction.
When did the amendments enter into force?
23 December 2024[1]. They are the 2022 set, adopted by the Special Tripartite Committee and driven substantially by lessons from the COVID-19 period. The consolidated text now carries the amendments of 2014, 2016, 2018 and 2022[3]. See what an audit checks.
What actually changed about medical care?
Two things stand out in the ILO summary. Seafarers are to be promptly disembarked when in need of immediate medical care, with access to medical facilities ashore in cases including serious injury or disease. And Member States facilitate repatriation by the shipowner of the body or ashes of seafarers who die on board[1]. Ask how that lands on your procedures.
Does this affect a US-flagged vessel?
Not directly. The United States has not ratified MLC 2006[2], so no amendment to it binds a US-flagged hull. A US commercial fishing vessel answers to 46 CFR 28.210 instead[5]. MLC still reaches a US vessel in a ratifying port state. See the 28.210 rules.
Do we need to update the medicine chest because of this?
On the evidence, no. Nothing in the summarised medical amendments touches chest contents, quantities or the medical guide[1]. What may need updating is the disembarkation and shore-access procedure, which is a documented process rather than a purchase. See the six decisions.
Where do the chest obligations still come from?
Standard A4.1(4)(a) for the chest, equipment and medical guide, with Guideline B4.1.1 pointing at inspection intervals of at most twelve months[2], plus your flag state notice, and 92/29/EEC for an EU flag[4]. Quantities anchor to the WHO Quantification Addendum[6]. See requirements by flag state.
What about controlled substances?
MLC does not govern them at all. They answer to national law, and for a US-registered vessel that means 21 CFR 1301.25[7], which is also unchanged, and a separate DEA rulemaking on it was withdrawn in 2025. See what happened to that.
