The Ministry of Ports, Shipping and Waterways has notified the Merchant Shipping (Medicines, Medical Stores, Appliances and Medical Officers) Rules, 2026, replacing the Merchant Shipping (Carriage of Medical Officers) Rules, 1961, and the Merchant Shipping (Medicines, Medical Stores and Appliances) Rules, 1994. UNI reported the notification from New Delhi on Sunday, 27 September. The gazette itself is Extraordinary No. 747 of Wednesday, 16 September 2026, issued as G.S.R. 817(E) under section 113 of the Merchant Shipping Act, 2025 (24 of 2025). The rules come into force on publication. That gazette, and UNI’s Sunday write-through of the doctor-on-board threshold, is the primary for this note. It is not a rewrite of Friday’s India–Liberia Group of Friends launch, of the Cape Dao or El Gaia Indian-seafarer casualty files, or of the separate Merchant Shipping (Medical Examination) Rules, 2026, published the same day as G.S.R. 816(E).
The operator-facing change is narrow and hard. Every foreign-going Indian ship carrying more than one hundred persons, including crew, must carry a Medical Officer as part of its complement. UNI summarised the same threshold as a qualified doctor on Indian vessels carrying more than 100 people. The Medical Officer is not a rating with a first-aid ticket. The person must hold a degree in medicine and surgery from a recognised university, be enrolled as a medical practitioner on the register of a State or Union territory medical council, and hold a valid licence issued by the Health Officer of the port of registry or the port to which the ship belongs. The licence is valid for two years. If it expires while the ship is at sea and outside Indian territorial waters, it is deemed to remain in force until the ship returns to an Indian port. That is a manning and Port Health document, not a flag-state circular that can be closed with a radio-medical subscription.
The medicines half of the same instrument is the part cargo operators will meet first. Every ship must carry medicines, medical stores and appliances on the scale set out in Annexure VIII. Foreign-going cargo ships and passenger ships take the heavier column. Where the total number of persons on board exceeds forty, an additional set of the listed extra items is required for every additional forty persons or part thereof. A ship that is required to carry a Medical Officer starts from a scale written for ninety-nine persons; the Medical Officer then decides what else to carry for the voyage length and area, subject to Port Health Officer approval at the port of departure. Home-trade cargo ships have two lighter scales, one for voyages exceeding ninety-six hours and one for ninety-six hours or less. All ships also carry a locked doctor’s attaché case. The key sits with a person authorised by the Master. Those medicines are for a qualified medical practitioner only. Radio Medical Advice stocks are to be used only on a practitioner’s instruction, and they are not to be left where an unqualified person can administer them.
A gazette is a Port Health inspection, not a hospital ship
The rules do not turn a 12-person handymax into a hospital. They turn the medicine chest, the record book and, on the 100-person hulls, the doctor into inspectable items. The Master must keep an up-to-date record of medicines, stores and appliances. Port Health can inspect the stock and the book at any time. At least once every twelve months the Port Health Officer inspects and issues a certificate in the prescribed form. If the ship is not likely to return to an Indian port within twelve months of the last inspection, the Master must procure sufficient medicines, certify compliance and record the details in a separate register. Consumed stocks are to be replaced at the next major port. Replacement packs must have at least one year of remaining shelf life from the date of purchase. Storage is in lockers or chests that will not shift at sea. Controlled or practitioner-only items stay under lock and key. A batch that produces adverse effects in more than one person is to be sealed and reported, with samples, to Port Health at the next port.
Special ships pick up a second chest. A cargo ship carrying chemicals, or residues of earlier chemical cargoes above the IMDG volume-1 threshold, must carry the Emergency Schedules reproduced in Annexure IX, stored separately from the ordinary scale and sized off the Medical First Aid Guide. The recommended quantities are written for a small complement; they increase by a factor of 1.5 when persons on board exceed twenty-four and by 2.0 when they exceed fifty. Supernumeraries, including family members, need their own special medicines arranged with Port Health before departure. A ship entering an endemic or epidemic area is to carry the extra preventive and curative stocks the Port Health Officer at the port of departure advises. None of that is optional inventory. It is the list a Port Health Officer can ask to see against the certificate.
Infectious-disease response is written as a Master’s duty, not a doctor’s monopoly. If any infectious disease is detected, the Master is to treat the patient, isolate, prevent spread, monitor contacts, dispose of excreta hygienically in cases such as cholera, and report the case to Port Health at the next port. A detected HIV/AIDS case has a separate short list: close surveillance around bodily-fluid exposure, discard of syringes and needles after boiling, PPE for handlers, and the same next-port report. Port Health at a major port may exempt a ship from carrying a particular item by written order, with reasons and conditions, in the prescribed form. An exemption is a paper, not a verbal understanding with the agent.
The 100-person line is a crewing problem before it is a clinic
Most Indian-flag cargo ships will never meet the Medical Officer threshold on a commercial complement. The ships that will are the ones that already carry supernumeraries, riding crews, project teams, or a large hotel party: some offshore and specialist hulls, some livestock or passenger-adjacent foreign-going ships, and any cargo ship that has let the headcount drift above 100 for a voyage. The draft application clause that preceded the gazette also treated passenger and pilgrim ships as a separate statutory class. Operators should not assume a passenger or Hajj/Umrah hull is covered by the cargo Medical Officer rule, and they should not assume it is exempt from the medicines scale. Read the notified instrument against the Act’s own passenger and pilgrim carve-outs, then crew the ship that is actually sailing.
The operational implication for everyone else is still a Port Health file. A foreign-going Indian cargo ship with a crew of twenty-two still has to carry the foreign-going scale, keep the record book, present for the twelve-month inspection, lock the attaché case, and replace expired stock with one-year-shelf-life product. A chemical tanker still has the MFAG chest. A Master who has been treating the 1994 chest as a once-a-year chandler order now has a 2025-Act instrument that a Port Health Officer can enforce on the same visit as a sanitation or pratique inspection. That is the point of replacing 1961 and 1994 in one gazette: the doctor, the chest and the infectious-disease report sit in one rule-set.
Do not fold this file into Sunday’s other India story. Jaishankar’s Group of Friends is a diplomatic channel for seafarer safety after named casualties. This gazette is a manning and stores rule for Indian-flag foreign-going ships. It does not put a doctor on a Liberia- or Panama-flag hull with Indian ratings. It does not reopen Hormuz, change a war-risk notice, or stand in for radio medical advice on a ship that is not required to carry a Medical Officer. It also does not replace the Medical Examination Rules, 2026. Those are the seafarer fitness and approved-examiner rules published as G.S.R. 816(E) the same Wednesday. A company that updates only the medicine chest and ignores the examiner list, or the other way around, will have done half the 16 September pair.
What Operators Should Note
- Count heads against 100 before the ship sails, not after the riding crew joins. The Medical Officer duty is written for every foreign-going Indian ship carrying more than one hundred persons, including crew. A project team, riding squad or supernumerary party that pushes the complement over the line is a crewing event. DPA and crewing should have a named Medical Officer, a two-year Port Health licence, and a relief plan before that voyage is fixed.
- Treat the Medical Officer as a licensed complement, not a contractor who flies in with a kit. Degree, State or Union territory council enrolment, and a Health Officer licence from the port of registry or the port to which the ship belongs are all required. A licence that expires at sea is only a bridge back to an Indian port. Do not send a ship out on an expired paper and hope the proviso covers a six-month tramp.
- Rebuild the medicine chest against Annexure VIII, not against the 1994 habit. Foreign-going cargo and passenger ships take the heavier scale. Add a set of the extra items for every forty persons above forty. If a Medical Officer is required, start from the ninety-nine-person scale and let that officer, with Port Health approval, add voyage- and area-specific stock. Home-trade ships use the 96-hour split. The locked attaché case and the Radio Medical Advice stocks are separate, controlled items.
- Put the twelve-month Port Health certificate on the same tracker as statutory surveys. The Master’s record book is inspectable at any time. The annual certificate is the paper that closes the loop. Ships that will not see an Indian port inside twelve months need a Master’s procurement record, not a promise to catch up on return. Replacement stock needs at least one year of remaining shelf life.
- Chemical, endemic-area and supernumerary voyages need a second conversation with Port Health. IMDG-threshold chemical cargo or residue means a separate MFAG/EMS chest, scaled up above 24 and 50 persons. Endemic or epidemic areas mean extra preventive and curative stock advised at the port of departure. Family members and other supernumeraries need their own medicines arranged before departure. None of that can be improvised at the pilot station.
- Write the infectious-disease actions into the Master’s standing orders. Treat, isolate, prevent spread, watch contacts, dispose of excreta, report to Port Health at the next port. HIV/AIDS has its own PPE and sharps line. This is a Master’s duty even on a ship that does not carry a Medical Officer. The report is to Port Health, not only to the company doctor ashore.
- Keep this gazette separate from the UN seafarer group and from the Medical Examination Rules. Friday’s India–Liberia launch does not crew a doctor. G.S.R. 816(E) is the fitness-examiner instrument. G.S.R. 817(E) is the chest and, on the 100-person hulls, the Medical Officer. An exemption from a particular item is a written Port Health order in the prescribed form, not a WhatsApp from the agent.
Regulas Shipping will keep lining the 16 September medicines and Medical Officer gazette against the same-day Medical Examination Rules and Friday’s seafarer-group launch so operators can treat a 100-person doctor requirement as a crewing and Port Health file, not as a hospital-ship standard for every Indian hull.
