1 Purpose
1.1 These performance standards provide for requirements for the design, manufacture, construction, rigging, installation of pilot ladder winch reels, operational readiness, onboard inspection and maintenance, familiarization and approval in relation to pilot transfer arrangements required under regulation V/23 of the 1974 SOLAS Convention, adopted by resolution MSC.[…].
The performance standards outlined in this legislation serve to ensure the safety, reliability, and compliance of pilot transfer arrangements in maritime operations. Their purpose is to provide detailed requirements for the design, manufacture, construction, and operational maintenance of pilot ladder winch reels, ensuring they meet the safety expectations established under regulation V/23 of the 1974 SOLAS Convention. The descriptive nature of these standards arises from the need to provide clear, technical guidance that leaves no ambiguity regarding the safety and functionality requirements. This level of detail supports uniformity and minimizes the risk of non-compliance due to misinterpretation. Furthermore, these standards are mandatory because they form an integral part of the SOLAS Convention, a globally binding treaty designed to enhance maritime safety and protect human life at sea. Compliance ensures international consistency and safeguards the well-being of seafarers and pilots during critical transfer operations.
2 Definitions
For the purpose of these performance standards, the following definitions apply:
2.1 Pilot transfer arrangements refer to all equipment and arrangements used solely for the embarkation and disembarkation of pilots and other personnel, including pilot ladders, accommodation ladders, embarkation platforms, manropes, pilot ladder winch reels, securing arrangements and other associated equipment.
2.2 Point of access means the location at which pilots or other personnel transfer between a pilot ladder or accommodation ladder and the deck or side opening of a ship.
2.3 Manropes means ropes hung on either side of a pilot ladder for assistance in ascending and descending.
2.4 Trapdoor means an aperture with a cover located in a platform allowing the pilot ladder, manropes to pass through without obstruction or distortion and used by pilots or other personnel to transfer between the pilot ladder and the accommodation ladder.
2.5 Securing a pilot ladder at intermediate length means securing a pilot ladder at a point other than the thimble ends.
3 General
3.1 Pilot transfer arrangements shall be designed, installed, inspected, maintained, and rigged to enable pilots and other personnel to embark and disembark safely in all seagoing conditions of draught and trim.
3.2 The height of climb on a pilot ladder shall not be less than 1.5 m and not more than 9 m from the surface of the water to the point of access in all seagoing conditions of draught and trim. Whenever the height of climb on a pilot ladder from the surface of the water to the point of access exceeds 9 m, the ship shall be provided with and rig an accommodation ladder in conjunction with the pilot ladder (i.e. a combination arrangement).
3.3 Where the height of climb is less than 1.5 m from the surface of the water and a pilot ladder is not used as part of a pilot transfer arrangement, this does not relieve any vessel or anyone involved with the transfer to ensure that the transfer is completed safely, is adequately risk assessed and that any equipment, other than a pilot ladder, which may be used shall be done so in accordance with these performance standards.
3.4 Pilot transfer arrangements shall be provided to enable pilots and other personnel to embark and disembark safely on either side of the ship. Necessary equipment shall be carried on each side unless the equipment is capable of being transferred for use on either side.
3.5 All pilot ladders and manropes used for the transfer of pilots and other personnel shall be clearly identified with permanent marking so as to enable identification of each appliance for the purposes of survey, inspection and record-keeping.
3.6 Reference in these performance standards to an accommodation ladder[1] includes a sloping ladder used as part of the pilot transfer arrangements.
3.7 The onboard inspection and rigging of the pilot transfer arrangements and the embarkation and disembarkation of pilots and other personnel shall be supervised by a designated responsible officer. During the transfer of pilots or other personnel, the responsible officer shall have means of communication with the navigation bridge and shall arrange for the escort of the pilot by a safe route to and from the navigation bridge and other personnel to an appropriate safe location.
[1] Refer to SOLAS regulation II-1/3-9 on Means of embarkation on and disembarkation from ships.
Article 3 specifies the general requirements for pilot transfer arrangements under the performance standards mandated by maritime safety regulations. These provisions are designed to ensure the safety of pilots and other personnel during embarkation and disembarkation in various seagoing conditions. These standards are descriptive to provide clear, actionable instructions, minimizing ambiguity and ensuring consistent global implementation. Their mandatory nature reflects their critical role in safeguarding lives and supporting compliance with international maritime conventions like SOLAS.
3.1, 3.2 and 3.3: The requirement in SOLAS that the height of climb on a pilot ladder shall not be less than 1.5 meters ensures pilots have adequate vertical range to establish a secure grip and footing during boarding or disembarkation. This minimizes the risk of slips or falls and enhances overall safety during the transfer process.
Furthermore, the maximum climb height of nine meters specified in SOLAS likely originates from safety considerations informed by maritime operations and ergonomics studies, although it is not explicitly stated in SOLAS that this height directly correlates to the fatality risk of a drop. Instead, it reflects a balance between practical operational limits and minimizing risk. The following factors should be considered:
- Ergonomic Limits: Climbing a vertical ladder is physically demanding. A nine-meter climb represents a threshold deemed manageable for most individuals without causing undue fatigue, which could lead to slips or errors.
- Risk of Injury from a Fall: While not directly stated as correlating with fatality risk, a fall from heights greater than nine meters is increasingly likely to result in severe injury or death. Keeping the climb height below this threshold reduces the likelihood of life-threatening accidents.
- Operational Feasibility: In many ship designs, a nine-meter climb accommodates most common scenarios for pilot transfer while still being practical for safe operations without excessive infrastructure modifications.
- Safety Enhancements with Combination Arrangements: For heights above nine meters, the use of a combination arrangement with an accommodation ladder ensures that pilots are not required to undertake excessively hazardous climbs, further mitigating risks.
Although the precise origins of the nine-meter limit may not be explicitly tied to a single study, it aligns with principles of risk reduction, physical capability, and maritime safety best practices. This standard ensures a reasonable balance between operational requirements and the safety of personnel.
3.4: The requirement in SOLAS for ships to have pilot transfer arrangements (PTAs) on both sides addresses significant safety and operational concerns. Previously, some ships were designed with PTAs on only one side, but this is no longer permitted because of the following issues:
- Flexibility for Safe Operations: The inability to use both sides for embarkation or disembarkation can limit the ship’s ability to make a safe lee (sheltered side) for pilot transfer. This can lead to unsafe conditions for the pilot and crew, particularly in adverse weather or sea conditions.
- Traffic Flow Disruption: Ships restricted to using only one side may be forced to maneuver awkwardly to accommodate the pilot boat. This can disrupt traffic flows in busy pilot embarkation areas, causing delays and increasing the risk of collisions or near misses.
- Navigational Safety Risks: Making lee with restricted PTA options may compel a ship to take undesired courses, potentially bringing it closer to shallow waters or other navigational hazards. This increases the risk of grounding or accidents, especially in congested or confined waterways.
By mandating PTAs on both sides, SOLAS ensures that ships can accommodate pilot transfers safely and flexibly under varying conditions, reducing risks to personnel and improving the efficiency and safety of maritime traffic management.
3.7 The requirement for a designated responsible officer to supervise the inspection, rigging, and embarkation/disembarkation process for pilot transfer arrangements (PTAs) introduces essential safety measures but also presents challenges for ship management:
- Adequate Personnel Availability: Ensuring that an officer is available to attend to the rigging of the PTA and oversee the transfer process can be a logistical burden, particularly on vessels with limited crew. Ships operating with reduced manning levels may struggle to allocate a dedicated officer without impacting other critical duties, especially during busy operational periods.
- Training and Competence: The responsible officer must be well-trained and competent to inspect and rig PTAs, assess their condition, and oversee safe operations. This includes understanding the relevant performance standards and identifying potential hazards. Without proper training, there is a risk of improper rigging, inadequate inspection, or unsafe practices, undermining the safety goals of the regulation.
These challenges emphasize the need for ship operators to invest in adequate crew training and workforce planning. This includes ensuring officers are familiar with PTA safety requirements and procedures and that staffing levels are sufficient to meet these obligations without compromising other operational responsibilities. Proper planning and resource allocation are essential to comply with the regulation while maintaining overall ship safety and efficiency.