The Confederation of Employers and Industrialists in Bulgaria, after agreeing with the Bulgarian Association of Shipowners, a collective member of KRIB, the proposed amendments to the Code of the Maritime Labor Convention, 2006 regarding those proposed by IMO/ILOAd-hocexpertWG expresses the following opinion:
1. The changes clarify existing "white spots" in the requirements of two of the Standards, which is correctly reflected in the opinion of the IA "Maritime Administration". After studying the opinion of the BAC members, we have no special comments on the proposed texts (they were adopted by the expert group of the two organizations back in 2009).
2. The bigger problem is that the revised ORDINANCE ON LABOR AND THEIR CONSEQUENTIAL RELATIONS BETWEEN MEMBERS OF THE SHIP'S CREW AND SHIP-CARRIER has not yet been promulgated. The current regulation was promulgated in the Official Gazette in October 2003, effective from 22.01.2004 and does not reflect the new requirements of MTK-2006.
The draft of a new regulation was developed by at least three working groups, appointed by order of MTITS since 2006, and the last draft was ready before the entry into force of MTK - 2006 (20.0-8.2013). Although the last working group was composed entirely on a tripartite basis, with the participation of the representative organizations of employers and trade unions, as well as MTITS and MTSP, the new regulation itself is subject to agreement between the two ministries. Thus, eight years after the adoption of MTK-2006, the Republic of Bulgaria once again has an inconsistent legal base. This is a clear sign of weak administrative capacity and lack of will to implement in practice a ratified international document, as well as the corresponding European directive.
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