BIMCO has provided a comprehensive look at new SOLAS amendments, which are expected to be adopted later this year.
The IMO Sub-Committee on Navigation, Communications and Search and Rescue (NCSR) convened for its 11th session from 4 to 13 June, and finalised the draft amendments of SOLAS, Regulation V/23 and associated instruments to improve the safety of Pilot Transfer Arrangements. The amendments are expected to be adopted at the Maritime Safety Committee (MSC) 109, in autumn this year, with an entry-into-force date as 1 January 2028. There is also a provision of voluntary early implementation for member states.
– PTAs installed on or after 1 January 2028 shall be designed, manufactured, constructed, secured and installed in accordance with the amended performance standards
– PTAs installed before 1 January 2028 shall comply with the requirements no later than the first survey on or after 1 January 2029
Voluntary early implementation
It must be noted that early implementing states should refrain from imposing new requirements before the entry-into-force date for their port state control measures to ships calling at its ports. Towards this direction, a draft MSC circular on voluntary early implementation was finalised, with a view to approval by the Committee.
1. Operational Readiness, Onboard Inspection and Maintenance
Detailed provisions are established for the periodic inspections, maintenance, stowage, care, documentation, records, and replacement criteria to maintain the fitness of pilot ladders, manropes and all associated equipment, including:
a. 36 months after the date of manufacture or within 30 months after the date of being placed into service, whichever comes first, pilot ladders and manropes (including spares) must be removed from service, replaced with new and not used for the transfer of personnel, regardless of the frequency of their usage.
b. At least one spare compliant pilot ladder and one spare set of compliant manropes shall be carried onboard.
c. Repair or replacement of pilot ladder steps or spreader steps is prohibited.
d. Instructions shall be supplied by the manufacturers with each pilot ladder, manrope and associated equipment.
2. Stowage of pilot ladders on winch reels
If a pilot ladder is to be stowed on a winch drum, the drum diameter shall be not less than 0.16m and the drum shall be provided with sunken securing points.
3. Training
Personnel responsible for the inspection, maintenance, rigging or operation of any equipment for pilot transfer arrangements are now explicitly required to receive proper onboard familiarisation so that they have the necessary knowledge and skills to perform their assigned duties.
4. Design, manufacture and construction
a. Marking: All pilot ladders and manropes shall be permanently marked by the manufacturer with a minimum of required information, to enable identification of each item for survey, inspection and record-keeping.
b. Ropes:
i. The side ropes of the pilot ladder should be not less than 20mm and not more than 22mm in diameter.
ii. Instructions have been developed on the securing arrangements of side ropes above and below each step.
c. Securing Arrangements
i. The required strength of strong points, shackles and securing ropes is double compared to the existing requirements (required breaking strength increased to 48 kN from 24kN). In this respect, manufacturers are required to provide means of securing a pilot ladder at intermediate lengths to strong points, and a text to this effect will be developed to provide clarity.
Documentation of the conformance of the strong points, shackles, and securing ropes shall be maintained onboard and available for inspection purposes.
d. Side doors opening
The existing requirement under regulation V/23.5 has been rephrased to read “Ship’s side doors used for the transfer of pilots or other personnel shall not open outwards unless located below the freeboard deck”, to align with the Load Lines Convention requirements.
Conclusions
Although these amendments place additional requirements to the shipowners, they come to address some longstanding issues which could have significant impact on vessels’ operations and, thus, it is BIMCO’s view that shipowners eventually stand to benefit. The most important among them is the guarantee of the safety of all personnel boarding the vessel. Almost equally notable is the fact that vessels and operators will now be alleviated from the uncertainty usually facing with several port authorities and local regulations, often resulting in significant costs of operational delays and off hires. Therefore, potential delays to the ships will be reduced and the cost of procuring a new pilot ladder is minimal when compared to the associated costs and time lost if involved in a boarding ladder-related accident or pilot refuses boarding.
Nevertheless, there is a concern that these new requirements could create a situation where counterfeit or re-used expired ladders are supplied to the vessels. This concern aligns with the already increasing reported cases of marine casualties, where investigation revealed that the failed ladder was a counterfeit. Consequently, it is highly recommended that each pilot and embarkation ladder is inspected with particular attention given to the markings to determine if they might be counterfeit. Pilot and embarkation ladders should be obtained from original equipment manufacturers or their local approved suppliers, while care should be exercised that the product supplied meets the applicable requirements and is accompanied with all necessary certifications.
