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Section 5 of the 2014 Ministerial Regulation includes such a provision: In cases of emergency or necessity, employers can order employees to work during rest periods by ensuring that rest periods are promptly compensated and that evidence of rest periods is prepared.[197] However, section 5 also omits key language contained in the ILO Work in Fishing Convention, which “permits, for limited and specified reasons, temporary exceptions [to working hours limits].”[198] The 2014 Ministerial Regulation fails to ensure that exceptions are temporary and for limited and specified reasons, imposing no legal conditions or limits on the additional time employers can order fishers to work.[199] Exploitative Payment Systems Labor costs on Thai fishing vessels are second only to expenditure on fuel, and account for about one-third of total operational expenses in key Thai fisheries.[200] Unscrupulous vessel operators reduce labor costs by offering illegal terms of employment and working conditions, using trafficked fishers and exacting forced labor from workers

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