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Is your crew agency legally operating in France?
Crew agents operating in France in any way need to be registered to operate legitimately in the country. See the full registry at https://www.ecologique-solidaire.gouv.fr/sites/default/files/Registre_SPRPGM.pdf
The Inspector du travail in France said ‘all must be listed on the French Register. Even operators who are working in France on just a temporary or occasional basis (such as visiting from a
parent company abroad) must declare their activity if it involves interviewing or introducing seafarers.
All the above is regardless of whether the yacht is subject to the MLC 2006 regulation or not – i.e. it is also applicable to Pleasure Yachts.
The obligation is on the shipowner (or representative – captain or manager) to have the evidence that any YCA used to find crew is fully MLC compliant. In France, the hard evidence is whether such YCA is on the French Register.
This is an extract from the PYA bulletin issued in August 2016 and for further information on this please contact them directly via www.pya.org