SAILORS' UNION OF INDIA - SUI

14/09/2026

To
Smt. Nirmala Sitharaman,
Hon’ble Union Minister for Finance,
Room No. 15074-15075,
5th Floor, B-Wing,
Kartavya Bhawan - I,
New Delhi.

Copy to:
Shri V. Vualnam.
Secretary Finance,
Room No. 16102,
Kartavya Bhawan - I,
New Delhi.

Date: 14/09/2026

Subject: Request for practical and special tax-residency relief for Indian Seafarers in view of the special nature of maritime employment, employment uncertainty and prevailing maritime-security conditions-reg

Respected Madam,

We respectfully submit this representation on behalf of Indian Seafarers seeking a practical review of the provisions governing determination of residential status for tax purposes, particularly in relation to Seafarers who are required to remain outside India for prolonged periods in the course of their employment and who are presently facing unprecedented employment uncertainty and maritime-security risks.

Under the residential-status provisions of the Income-tax Act, an individual is generally treated as resident in India if the prescribed conditions relating to the period of stay in India are satisfied. The law has, however, recognised the special circumstances of Indian citizens who leave India as members of the crew of a forign / Indian ship or for the purposes of employment outside India. Under the earlier Income-tax Act, 1961, Section 6, the 60-day condition in the relevant test was substituted with 182 days in the case of an Indian citizen leaving India as a crew member of an Indian ship or for employment outside India. The Income-tax Department has confirmed that this special treatment has continued under the Income-tax Act, 2025.

The legislation has also recognised the unique nature of foreign-bound maritime employment. In the case of an Indian citizen who is a member of the crew of a foreign-bound ship leaving India, the period of stay in India relating to an eligible voyage is determined in the prescribed manner. Rule 126 of the Income-tax Rules, 1962 provided for exclusion of the period beginning from the date of joining the ship recorded in the Continuous Discharge Certificate and ending on the date of signing off, subject to the prescribed conditions relating to an eligible voyage.

These provisions demonstrate that the Government has historically recognised that Seafarers cannot be treated in the same manner as ordinary land-based employees because their employment is inherently international, rotational and dependent upon vessel availability, contractual requirements, port restrictions, crew changes, international trade and geopolitical circumstances.

However, the present maritime employment environment has changed considerably. Indian Seafarers are facing prolonged periods of unemployment, uncertainty in recruitment, reduction in available vessels and voyages, increased compliance requirements and restrictions arising from geopolitical developments. At the same time, several important international maritime routes are experiencing serious security concerns, including the Red Sea, Bab el-Mandeb, Strait of Hormuz and other strategically sensitive areas.

The present situation creates a serious practical difficulty for Seafarers. A Seafarer may not always be able to obtain employment or may reasonably decline a particular assignment because of security risks, sanctions-related concerns, contractual uncertainty or other circumstances beyond his or her control. Such circumstances are fundamentally different from voluntary unemployment or an ordinary decision not to work.

Seafarers should therefore not be placed in a position where they are economically compelled to accept hazardous or unsuitable shipboard employment merely because of concerns relating to their tax-residency status. The tax framework should recognise that the availability of employment at sea is not continuously within the control of the individual Seafarer.

A further difficulty has emerged from the increasing use of international sanctions and enhanced compliance screening in the shipping industry. Seafarers who have previously served on vessels involved in Iran-related, Russia-related or other sanctions-sensitive trades may subsequently face additional scrutiny when seeking employment with other international shipping companies. In many cases, the individual Seafarer may have had no ownership, commercial, chartering, cargo, routing or decision-making role in the transaction that subsequently became subject to sanctions or enhanced compliance scrutiny.

Nevertheless, the employment history of such Seafarers may result in additional background checks, compliance inquiries, delays in recruitment or reluctance on the part of prospective employers. This can materially reduce their employment opportunities and may result in periods of involuntary unemployment.

It is therefore respectfully submitted that the tax-residency framework should take into account such exceptional circumstances. A genuine Seafarer who is unable to secure employment because of prevailing maritime-security conditions, sanctions-related employment scrutiny, vessel restrictions, geopolitical disruption or other circumstances beyond his or her reasonable control should not be placed at a disadvantage merely because the individual could not obtain sufficient qualifying employment during the relevant period.

The Government may consider introducing a special 'Seafarer Relief Mechanism" under which documented periods of involuntary unemployment or inability to obtain suitable employment arising from exceptional maritime circumstances may be given appropriate consideration for determining residential status. Such a mechanism could be supported by documentary evidence including Continuous Discharge Certificate records, seafarer employment agreements, discharge records, employment applications, rejection or compliance communications from prospective employers, medical or security-related documentation and other evidence considered appropriate by the tax authorities.

We further request that the Government examine whether an appropriate relaxation, exclusion, deferment or special computation mechanism can be introduced for genuine Seafarers affected by extraordinary maritime-security situations. The purpose would not be to create an unrestricted tax exemption, but to prevent the tax-residency provisions from creating an unintended economic compulsion upon Seafarers to undertake employment in unsafe, sanctions-sensitive or otherwise unsuitable maritime circumstances.

We respectfully submit that Seafarers constitute a distinct category of workers. Their workplace is frequently a vessel operating in international waters and foreign jurisdictions, and their employment is governed by a combination of national / international law, flag-State requirements, maritime labour convention, ( MLC) contractual arrangements and international maritime regulations. Their ability to determine the location and duration of their employment is consequently substantially different from that of a land-based employee.

The contribution of Seafarers to India's economy and international trade should also be recognised. Indian Seafarers are an important source of foreign exchange earnings and are essential to the operation of global supply chains. They spend prolonged periods away from their families and perform their duties under demanding occupational, environmental and geopolitical conditions.

We therefore request the Ministry of Finance to undertake a comprehensive review of the practical application of the tax-residency provisions to Indian Seafarers and consider a dedicated policy mechanism that recognises the exceptional circumstances of maritime employment.

We further request that appropriate consultation be undertaken with recognised Seafarers' Organisations, Maritime Employers, Shipowners, Manning Agencies, tax professionals and other relevant stakeholders before finalising any such mechanism, so that the actual working conditions and employment realities of Indian Seafarers are adequately reflected in the policy.

The objective of this representation is not to seek preferential treatment or an indiscriminate tax concession. Our request is for a fair, practical and proportionate framework that ensures that genuine seafarers are not compelled to undertake unsafe or commercially unsuitable employment merely to protect their tax-residency position, particularly during periods of exceptional maritime-security risks and severe employment disruption.

We therefore respectfully request the Hon’ble Finance Minister and the Ministry of Finance to consider appropriate amendments, clarification, relaxation or special provisions for Indian Seafarers and to establish a practical mechanism for recognising documented periods during which a Seafarer is unable to obtain suitable employment because of circumstances beyond his or her reasonable control.

Such a measure would provide much-needed certainty to Indian Seafarers and their families, while preserving the integrity of India's tax administration and recognising the unique contribution and working conditions of India's maritime workforce.

We look forward to the kind consideration of this important issue and appropriate policy intervention in the larger interest of Indian Seafarers and their families.

Yours faithfully,

RP Veettil
National President
Sailors’ Union of India (SUI-BMS)
08104168646
022-22630998

Sailors Union of India (SUI)

13/09/2026

To,
Shri Narendra Modi Ji
Hon'ble Prime Minister,
Government of India
New Delhi.

Date: 13-09-2026

Subject: Sincere appreciation for your Excellency’s historic initiative at the 18th BRICS Summit for establishing a “Seafarers’ Emergency Support Network” , Request for an effective, permanent and internationally coordinated mechanism for the safety, security, welfare and emergency protection of seafarers

Respected Prime Minister,

On behalf of the Sailors’ Union of India (SUI-BMS) and the wider Indian seafaring community, I respectfully convey my sincere appreciation and gratitude to Your Excellency for raising, at the highest international forum of the 18th BRICS Summit in New Delhi, the urgent issue of the safety, security and welfare of merchant seafarers and for proposing the establishment of a “Seafarers’ Emergency Support Network”.

This is a significant and timely initiative which, in our considered view, has the potential to become an important international institutional mechanism for protecting the lives and dignity of seafarers who continue to serve global commerce despite operating in increasingly dangerous maritime environments.

The proposal has particular significance because the present international maritime environment has become exceptionally challenging for merchant seafarers. Armed conflicts, missile and drone attacks, piracy, attacks on commercial vessels, geopolitical tensions, disruption of established shipping routes and instability around strategically important sea lanes have created circumstances in which civilian merchant seafarers are increasingly exposed to risks over which they have absolutely no control. These men and women are not combatants and have no role in the political or military disputes that cause such conflicts. They are simply performing their professional duties on board merchant vessels carrying essential cargoes, energy supplies, food, industrial raw materials and other commodities upon which nations and economies depend.

The international community frequently speaks about freedom of navigation, secure sea lanes, uninterrupted supply chains and protection of global trade. However, Govt. of India has rightly brought attention to the human dimension of maritime security by recognising that there can be no genuinely secure maritime trade without ensuring the safety and protection of the seafarers who physically operate the ships and navigate those sea lanes. A vessel can be insured, a cargo can be insured and a shipping route can be monitored, but the life of a seafarer cannot be replaced. For this reason, the protection of seafarers must be treated as an essential component of maritime security and not merely as an employment or welfare issue.

Sailors’ Union of India therefore strongly welcomes Your Excellency’s proposal for an Emergency Support Network capable of providing coordinated assistance to seafarers facing distress or danger. We particularly appreciate the proposed focus on distress alerts, medical assistance, communication with families and evacuation support. These four areas address some of the most immediate difficulties experienced by seafarers and their families when a vessel becomes involved in a conflict, accident, attack or other emergency. In such circumstances, even a delay of a few hours can have serious consequences, and therefore any international mechanism must function on a genuine 24×7 emergency basis, with clearly designated authorities and clearly defined responsibilities.

We respectfully submit that the proposed network should not remain merely a declaration or diplomatic concept. It should be developed into a permanent, operational and internationally coordinated Seafarers’ Emergency Protection and Support Mechanism, supported by appropriate standard operating procedures, designated nodal authorities, emergency contact points and clear lines of communication between maritime administrations, foreign ministries, diplomatic missions, port authorities, shipowners and other relevant stakeholders. A seafarer or Master facing an emergency should not have to determine which government department has jurisdiction or which diplomatic channel should be contacted. There should be one clearly identifiable mechanism through which an emergency can immediately be reported and escalated to the competent authorities.

SUI respectfully believes that a principal component of such a mechanism should be a 24×7 BRICS Maritime Emergency Communication and Coordination System through which distress information can be received, verified and immediately transmitted to the relevant maritime authority and diplomatic mission. Where necessary, the system should coordinate with the coastal State, flag State, shipowner, employer, port authority and other competent agencies so that assistance can be provided without bureaucratic delay. The mechanism should also provide for the rapid dissemination of verified safety information to vessels and crews operating in high-risk areas.(HRA)

The issue of emergency evacuation and repatriation deserves particular attention. When merchant vessels become trapped in conflict-affected waters or when a port becomes inaccessible because of hostilities, seafarers can remain stranded for prolonged periods. In such circumstances, responsibility can become fragmented between the shipowner, flag State, coastal State, port authorities, maritime administration and diplomatic missions. The proposed BRICS mechanism should therefore establish a coordinated procedure for emergency evacuation, safe crew transfer, medical evacuation, repatriation and assistance to seafarers who are unable to return home through normal arrangements. The objective should be that no seafarer is left behind merely because an emergency has created a jurisdictional or administrative complication.

SUI also considers the proposed family-support component to be extremely important. When a ship is attacked or a serious incident occurs at sea, the families of the seafarers often remain without reliable information for hours or even days. They may learn about an incident through social media, television reports or informal sources before receiving any official communication. This causes enormous anxiety and uncertainty. We respectfully request that the proposed mechanism establish a designated family assistance system through which the next of kin can receive verified information concerning the safety, medical condition, whereabouts or repatriation status of the affected seafarer. In cases involving death, disappearance, serious injury or detention, families should be provided with appropriate institutional assistance and should not be required to approach multiple authorities independently.

The proposed mechanism should also address the financial and employment consequences arising from maritime emergencies. When a seafarer dies, suffers serious injury, becomes permanently disabled, is missing, is abandoned or remains stranded because of conflict, there must be an effective mechanism for ensuring that legitimate wages, contractual benefits, insurance claims, compensation and other statutory or contractual entitlements are protected. A geopolitical crisis affecting a vessel should not result in the seafarer or the family losing legitimate employment and welfare rights.

Dear Prime Minister, SUI respectfully submits that merchant seafarers operating in conflict-prone waters should be clearly recognised as civilian frontline workers of the global economy. They should not be considered an expendable part of the international supply chain. Whenever governments and international organisations seek to maintain freedom of navigation and uninterrupted maritime commerce during a crisis, equal importance must be given to the protection of the human beings who are required to continue operating those vessels.

We further request that the proposed international mechanism include an effective early-warning and risk-information system. Seafarers and ship Masters should receive timely and authenticated information regarding missile and drone threats, armed conflicts, piracy, port closures, navigation restrictions, maritime security risks, evacuation arrangements and other relevant developments. Such information should be communicated through reliable maritime channels and should be sufficiently clear for Masters and crews to take appropriate precautionary measures. Early warning can prevent casualties and should therefore form an important part of the proposed network rather than limiting the system to post-incident assistance.

SUI also respectfully requests consideration of medical and psychological support for affected seafarers. A seafarer who survives a missile strike, drone attack, armed boarding, explosion, hostage situation or the death of colleagues may suffer serious physical and psychological consequences. Emergency medical evacuation should therefore be supported by appropriate post-incident medical care and counselling. The welfare responsibility should not end merely when a seafarer has been physically removed from the danger zone.

We believe that India, under your excellent leadership, is exceptionally well placed to provide international leadership in this field. India has a large and highly skilled seafaring workforce and has consistently demonstrated concern for the welfare of Indian seafarers. The BRICS initiative provides an opportunity to transform this national commitment into an international framework through which participating countries can cooperate in protecting merchant seafarers during emergencies.

SUI respectfully suggests that the Government of India may consider developing the initiative in coordination with appropriate international maritime and labour institutions, including the International Maritime Organization (IMO) and the International Labour Organization (ILO), wherever appropriate. Such coordination would help ensure that the proposed mechanism complements existing international maritime safety, security and labour standards while addressing the specific emergency circumstances created by modern geopolitical conflicts.

We further respectfully submit that the experience and practical voice of serving seafarers and their Representative Organisations should form part of the implementation process. Policies concerning seafarers' safety are most effective when they are developed with an understanding of what actually happens on board ships during emergencies. Sailors’ Union of India is therefore willing to place its experience, observations and case-based knowledge at the disposal of the Government of India for any consultation, committee, working group or stakeholder process relating to the proposed mechanism.

Prime Minister Ji, the recent loss of seafarers in conflict-affected maritime regions is a reminder that behind every vessel casualty there are families waiting for information, children waiting for their parents, spouses waiting for their partners and ageing parents waiting for their sons or daughters to return home safely. The human cost of maritime conflict cannot be measured only through cargo losses, vessel damage or financial claims. Every seafarer lost at sea represents an irreplaceable human life and an affected family.

It is for this reason that SUI regards Your Excellency’s initiative as much more than a conventional international proposal. It is an opportunity to establish a new principle in international maritime governance: that the safety, dignity and welfare of the seafarer must be placed at the centre of maritime security and global trade protection.

We therefore respectfully request Your Excellency to continue pursuing this initiative at the BRICS and wider international level and to encourage the establishment of a time-bound implementation framework comprising a 24×7 emergency communication system, designated international and national nodal authorities, emergency evacuation and repatriation protocols, medical assistance, family information and support mechanisms, early - warning arrangements, protection of wages and contractual entitlements, and appropriate post-incident welfare and counselling facilities.

SUI also respectfully requests that the Government consider establishing a permanent Indian Seafarers’ Emergency Coordination and Family Assistance mechanism as the domestic counterpart of the proposed international network, thereby ensuring that the Indian component is fully prepared to respond whenever an Indian seafarer or an Indian-flagged or Indian-connected vessel is affected by an emergency anywhere in the world. Your statement that the safety of sea lanes and the security of global trade are inseparable from the safety of seafarers has given a strong and much-needed voice to a workforce that is often invisible despite being indispensable to the global economy. We sincerely appreciate this recognition and respectfully hope that India will now lead the international community in converting this vision into a practical, permanent and accountable mechanism.

Ships carry the world’s trade, but seafarers carry the responsibility of carrying that trade safely. Protecting the sea lanes must therefore mean protecting the seafarers who sail them.

On behalf of Sailors’ Union of India, I once again convey our sincere appreciation to our Prime Minister for taking up this important issue at the highest international level.

We stand ready to extend our full cooperation and constructive support to the Government of India in every appropriate initiative aimed at protecting the lives, rights, dignity and welfare of seafarers and their families.

With highest respect and regards,

Yours faithfully,

RP Veettil
National President
Sailors’ Union of India (SUI-BMS)
Mumbai, Maharashtra.
Mobile: 8104168646
Landline: 022-22630998
Website: www.suiindia.org

10/09/2026

https://x.com/sui_union/status/2097890584438644953

06/09/2026

SAILORS’ UNION OF INDIA (SUI)
STATEMENT ON THE INTERVENTION FOR INDIAN SEAFARER STRANDED IN RUSSIA

The Sailors’ Union of India (SUI-BMS) has taken up the serious humanitarian case of Mr. Chodipalli Appalaraju, an Indian seafarer who was serving onboard M.V. NADEZHDA (IMO No. 7702657), which was severely damaged in a drone attack while proceeding from Novorossiysk towards Samsun on 3 August 2026.

Following the incident, all 22 crew members were evacuated by the Russian authorities to Novorossiysk. In the fire, Mr. Appalaraju lost his passport, CDC, educational certificates, other essential seafarer documents, cash, wages and personal belongings. Due to the loss of his travel documents, he has remained stranded in Russia for approximately 35 days, unable to return to India.

Recognising the urgency of the matter, Sailors’ Union of India immediately took up the issue with the concerned Maritime Authorities and the Directorate General of Shipping (DGS) and requested urgent intervention for his repatriation, issuance of an Emergency Certificate/appropriate travel document, settlement of pending wages and contractual entitlements, and examination of his insurance and compensation benefits.

SUI is pleased to note that the matter has received a prompt response from the Directorate General of Shipping. Capt. Bipin Kumar, Nautical Surveyor-cum-Deputy Director General (Tech), DGS, has informed SUI that the matter will be taken up through the e-Navik system/team.

SUI has accordingly requested that the concerned authorities take immediate action to:

1. Facilitate the immediate repatriation of Mr. Appalaraju to India;
2. Coordinate with the Embassy of India in Russia, MEA, Russian authorities and other concerned agencies for the necessary travel documentation;
3. Direct the concerned RPSL/company/employer to provide all necessary assistance;
4.Ensure settlement of his pending wages and applicable WLA/war-like allowance and other contractual dues;
5.Examine his entitlement to insurance benefits, compensation and other statutory/contractual claims arising from the incident;
6.Facilitate the replacement/re-issuance of his CDC and other essential seafarer documents destroyed in the fire; and
7. Ensure that the seafarer is not left stranded due to administrative or documentation difficulties beyond his control.

SUI appreciates the prompt response from the Directorate General of Shipping and expects the concerned authorities, Gurukripa Marine Services Pvt Ltd, and other agencies to complete the necessary action at the earliest.

The Sailors’ Union of India remains committed to protecting the rights, safety, welfare and contractual entitlements of Indian seafarers, particularly when they face extraordinary circumstances while serving at sea.

SUI will continue to monitor the case until the seafarer is safely repatriated to India and his legitimate dues and entitlements are addressed.

R. P. Veettil
National President
Sailors’ Union of India (SUI-BMS)
Mumbai
www.suiindia.org
Mob: 8104168646
022-22630998

01/09/2026

URGENT APPEAL FOR HELP – INDIAN SEAFARERS STRANDED IN LEBANON

The Sailors’ Union of India (SUI) has received a distress call seeking urgent assistance for an Indian seafarer, Mr. Modu Chandra Sekhar Durga Vara Prasad (Chandu), CDC No. 578721, Passport No. Y 7717204, who is reportedly stranded onboard MV PRUVALINE (IMO No. 7615232) at Lebanon.

As per the information received, the seafarers onboard are reportedly facing extremely difficult conditions, including shortage of food and fresh water, non-payment of wages, completion of their contracts without repatriation, and difficulties concerning their documents, which are reportedly being held in connection with Port State Control procedures.

The recruitment agency involved has been identified as Ouvert Marine Solutions Pvt. Ltd.

This is a serious humanitarian concern. No seafarer should be left stranded without food, drinking water, wages or a safe means of returning home after completion of his contract.

SUI appeals to the Directorate General of Shipping, Government of India, Indian Embassy/Consular authorities in Lebanon, Port State Control authorities and all concerned stakeholders to urgently intervene and ensure:

• Immediate supply of adequate food and fresh water
• Payment/recovery of all outstanding wages
• Proper medical and welfare assistance, if required
• Resolution of the documentation/Port State Control issues
• Immediate repatriation of the Indian seafarers to India
• Accountability of all parties responsible for their welfare and contractual obligations

Sailors’ Union of India stands with the stranded seafarers and will continue to pursue the matter with the concerned authorities until appropriate assistance is provided.

Indian seafarers deserve dignity, safety, wages and the right to return home.

RP Veettil
National President
Sailors' Union of India
8104168646
www.suiindia.org

31/08/2026

🚨 FRAUD ALERT!
Serious concerns over the inaction and delay by the concerned Police Department despite a reported fraud complaint.

Such matters require an immediate, impartial and transparent investigation. Delay only causes further hardship to victims and may allow the alleged offenders to continue.

We urge the concerned authorities to act promptly, investigate thoroughly and ensure justice in accordance with law.

27/08/2026

Ref.SUI.COmm/F&DA/Mah/01/08/2026

To,
Shri. Tukaram Mundhe. I.A.S
Hon’ble Commissioner
Food & Drugs Administration,
4th Floor Survey No. 341,
Bandra Kurla Complex,
Opposite Reserve Bank of India,
Bandra (East),
Mumbai:400 051

Date: 27th August 2026

Subject: Proposal for a “Safe Food for Seafarers” initiative, ensuring genuine, hygienic, safe and nutritious food and drinking water onboard Merchant Navy Ships -reg

Respected sir,
I respectfully submit for your kind consideration an important but largely overlooked public-health issue concerning Indian seafarers who work onboard Merchant Navy ships calling at MbPA, Mumbai, Jawaharlal Nehru Port Authority (JNPA) and other ports in Maharashtra. The Food & Drug Administration is rightly taking strong measures to protect citizens from adulterated, contaminated, unsafe and unhygienic food on shore. However, there is another category of consumers, our seafarers who live and work at sea for prolonged periods and are completely dependent upon the food provisions and drinking water supplied to their vessels. The food supply chain serving merchant ships deserves greater attention as an important aspect of seafarers’ health welfare and safety.

A fundamental question arises: Who supplies food items to Merchant Navy ships, whether such suppliers or ship chandlers are genuine and authorised, where are the food provisions procured from, and under what conditions are they transported, stored and supplied onboard? Merchant vessels may receive large quantities of rice, flour, cereals, vegetables, fruits, meat, fish, poultry, dairy products, frozen provisions, cooking oils, packaged food and other essential items for consumption over several weeks or months. Any adulteration, contamination, expired or substandard products, improper handling, inadequate refrigeration or interruption of the cold chain can directly affect the health of the entire crew. Unlike consumers on shore, seafarers cannot simply leave the vessel and obtain alternative food or immediate medical assistance when a food safety problem occurs at sea.

The World Health Organization ( ) recognises food safety as a fundamental public-health concern. Its internationally recognised “ *Five Keys to Safer Food”* are: keep clean; separate raw and cooked food; cook thoroughly; keep food at safe temperatures; and use safe water and safe raw materials. These principles are directly applicable to shipboard catering, where food is received, transported, stored, prepared and served under conditions that require particular attention to hygiene and temperature control.

also emphasises that a healthy diet must be adequate, balanced, moderate and diverse, and importantly, that a diet cannot be considered healthy unless it is safe and free from microbial and chemical contamination. WHO recommends a varied diet containing nutritious foods such as whole grains, vegetables, fruits, pulses, nuts and appropriate protein sources, while limiting excessive salt, free sugars and unhealthy fats. These principles are particularly important for seafarers because their physical fitness, concentration, stamina and overall health are essential for the safe operation of ships.

The Maritime Labour Convention, 2006 ( , 2006) also provides a clear international standard regarding seafarers' food and catering. 3.2* (Purpose: To ensure that seafarers have access to good quality food and drinking water provided under regulated hygienic conditions) and A3.2 require food and drinking-water supplies to be suitable in terms of quantity, nutritional value, quality and variety, taking into account the number of seafarers, the duration and nature of the voyage and their cultural and religious requirements. The Convention further requires adequate, varied, balanced and nutritious meals to be prepared and served in hygienic conditions with appropriately trained catering personnel.

Therefore, the issue should not be limited merely to whether sufficient food is supplied onboard. The fundamental question should be whether the seafarer receives genuine, safe, hygienic, healthy, balanced and nutritionally adequate food of appropriate quality throughout the voyage. Food supplied to ships should be traceable to a legitimate source, properly labelled, within its shelf life, appropriately transported and stored, and protected from contamination. Particular attention should be given to meat, fish, poultry, dairy and frozen products, where temperature control and cold chain integrity are critical. The quality and safety of potable water supplied to ships should also receive appropriate attention, as safe water is an integral part of food safety and shipboard health.

I therefore respectfully propose that the Maharashtra Food & Drug Administration consider developing a “Safe food for seafarers – Maharashtra Initiative ”, initially as a pilot project covering Mumbai Port, JNPA and other suitable maritime locations. The initiative could examine the entire supply chain: food manufacturer / producer or wholesaler authorised ship chandler / food supplier, transportation, cold-chain /storage facility vessel onboard storage, galley preparation, consumption by seafarers. Verification of the genuineness and regulatory status of suppliers, food-safety licences, source of provisions, batch and lot details, expiry dates, storage conditions, refrigeration temperatures, hygiene standards and quality documentation could form part of such a system.

A simple food-supply traceability mechanism could also be introduced for vessels calling at Maharashtra ports, recording the supplier /chandler, vessel name, date of supply, major food categories, batch or lot number, expiry date and relevant quality documentation. Such traceability would enable the authorities to identify the source quickly if a complaint of food contamination, adulteration of food-borne illness arises onboard.

The FDA may also consider developing basic guidance for Indian Ship Owners, ship chandlers and catering contractors covering WHO's Five keys to safer food, hygienic handling of food, prevention of cross-contamination, safe cooking, temperature -controlled storage, safe drinking water, personal hygiene of food handlers, pest control, cleaning and sanitation, and appropriate stock rotation. In addition, nutritional guidance could encourage adequate and varied provision of vegetables, fruits, pulses, whole grains and appropriate protein sources, while avoiding excessive dependence on highly processed foods, excessive salt, free sugars and unhealthy fats, consistent with WHO’s healthy principles.

I further suggest that this initiative may be developed in consultation with the Directorate General of Shipping /Directorate General of Maritime Administration, Port Authorities, shipping companies, shipowners, authorised ship chandlers, maritime training and catering professionals, and representatives of seafarers' organisations. Such coordination would ensure that the proposed system is practical, does not create unnecessary duplication of maritime regulations, and effectively addresses the actual conditions experienced onboard ships.

Sir, a seafarer is not only a worker but also a consumer and a human being entitled to safe, hygienic and nutritious food. The health of a seafarer has a direct connection with maritime safety because a physically unwell or nutritionally compromised crew member may be unable to perform safety-critical duties effectively. A food-borne illness affecting several crew members simultaneously can become a serious operational and safety concern, particularly when a vessel is far from shore.

The Sailors' Union of India therefore respectfully requests your good office to consider this proposal as a new public-health and seafarer welfare initiative, and to explore the possibility of establishing a Maharashtra pilot programme for safe food supply to merchant ships. Maharashtra, with its major maritime gateways and large number of ships and seafarers passing through its ports, has an opportunity to establish a model that could subsequently be considered at other major Indian Ports.

The Sailors' Union of India is willing to extend its full cooperation and provide practical inputs based on health issues and experiences shared by seafarers regarding food quality, food provisions, drinking water, ship board hygiene and catering arrangements.

Thank you,

RP Veettil
National President
Sailors Union of India (SUI-BMS)
8104168646
www.suiindia.org