REGULATION 23
1. Ships on which pilots may be employed shall be provided with pilot transfer arrangements.
2. Pilot transfer arrangements shall enable pilots and other personnel to embark and disembark safely in all seagoing conditions of draught and trim.
Not all vessels utilize the services of maritime pilots regularly. For example, ferries and other ships that primarily operate without pilots on board may not always adhere to proper pilot ladder regulations. However, all ships eventually require pilotage services at some point—whether during ownership changes, visits to shipyards, or other operations.
Unfortunately, many vessels that seldom take pilots are inadequately or improperly equipped to comply with pilot boarding arrangement standards. This can create hazardous situations, such as the presence of overly wide fendering systems or pilot door openings located dangerously close to the ship’s stern. Additionally, ships that undergo modifications during their lifespan often fail to meet compliance requirements after modification.
SOLAS-regulations
The new amendments to SOLAS Chapter V, Regulation 23, play a crucial role in enhancing safety for pilot transfer arrangements by introducing a structured safety framework. The Introduction provides the rationale, highlighting past incidents and risks, setting clear objectives to improve safety, and aligning with IMO’s broader maritime safety goals. This establishes a proactive mindset for continuous improvement.
Part A ensures uniform standards for the design and construction of equipment, while Part B mandates safe operational practices for rigging and securing pilot ladders. Part C focuses on regular inspection and maintenance, ensuring equipment reliability. Part D emphasizes crew training and competency, fostering awareness of risks and safe practices. Part E ensures effective communication and coordination between crew and pilots, crucial for operational safety. Finally, Part F reinforces compliance through inspections and audits. Together, these elements form a comprehensive and proactive framework, reducing risks and ensuring pilot safety.
ISO-standards
The updated SOLAS Chapter V, Regulation 23, concerning pilot transfer arrangements, references international standards to ensure the safety and reliability of pilot ladders. Specifically, it acknowledges ISO 799:2004, titled “Ships and marine technology – Pilot ladders,” as an acceptable standard for compliance. This ISO standard outlines detailed specifications for the design, construction, and maintenance of pilot ladders, ensuring they meet safety and performance criteria essential for secure pilot transfers.
ISM-code
Under the ISM Code Section 1.2.3, it is explicitly stated that all ships must comply with applicable international regulations and codes, ensuring the safe operation of ships and protection of the marine environment. This includes adherence to the SOLAS Convention, under which Chapter V, Regulation 23, mandates specific requirements for pilot transfer arrangements to enhance safety during pilot boarding and disembarkation. Compliance with ISM Code 1.2.3 inherently requires ships to meet the standards set out in SOLAS V Regulation 23, as it is a critical international regulation aimed at mitigating risks in maritime operations. By following the ISM Code, ship operators are obligated to incorporate the design, maintenance, and operational standards specified in Regulation 23 into their safety management systems, ensuring alignment with global safety benchmarks. Failure to do so would constitute a breach of the ISM Code’s overarching requirement to comply with relevant maritime regulations.
3. Pilot transfer arrangements provided in accordance with paragraph 1 and installed on or after [1 January 2028] shall be designed, manufactured, constructed, secured and installed in accordance with the introduction andparts A, B and C of the performance standards adopted by the Maritime Safety Committee by resolution MSC.[…], as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
4. Pilot transfer arrangements installed before [1 January 2028] on ships to which chapter I applies shall comply with the requirements provided in paragraph 3 not later than the first survey * on or after [1 January 2029]. * Refer to Unified interpretation of the term ʺfirst surveyʺ referred to in SOLAS regulations (MSC.1/Circ.1290).
5. Pilot transfer arrangements installed before [1 January 2028] on ships to which chapter I does not apply shall comply with the requirements provided in paragraph 3 no later than [1 January 2030].
Articles 3, 4 and 5 outline the phased compliance requirements for pilot transfer arrangements under the SOLAS Chapter V, Regulation 23 amendments. Here’s the summary with an explanation of Chapter I applicability:
- For Installations on or after 1 January 2028:
Pilot transfer arrangements installed from this date must comply with updated performance standards outlined in the Introduction and Parts A, B, and C of the standards adopted by the Maritime Safety Committee (MSC). These standards ensure that the arrangements are designed, manufactured, secured, and installed to meet stringent safety criteria. - For Installations before 1 January 2028 on Ships Subject to Chapter I:
Ships covered under Chapter I of SOLAS include cargo ships of 500 gross tons or more, passenger ships on international voyages, and other ships engaged in international trade as defined by SOLAS. These ships must ensure compliance with the updated requirements by their first survey conducted on or after 1 January 2029. - For Installations before 1 January 2028 on Ships Not Subject to Chapter I:
Ships not covered under Chapter I typically include smaller vessels (e.g., those under 500 gross tons), domestic vessels operating solely within one country’s jurisdiction, fishing vessels, and certain warships. These ships must comply with the updated requirements by 1 January 2030.
By defining compliance timelines based on Chapter I applicability, the IMO provides a clear pathway for the maritime industry to transition to updated safety standards, balancing the need for improved safety with practical implementation considerations for different vessel types.
6. Inspection, stowage, maintenance, replacement and familiarization of all pilot transfer arrangements, regardless of the installation date, shall comply with the introduction and parts D and E of the performance standards adopted by the Maritime Safety Committee by resolution MSC.[…], as may be amended by the Organization, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
This article 6 explains that all pilot transfer arrangements, no matter when they were installed, must follow specific rules for:
- Inspection – Regular checks to ensure the arrangements are safe and in good condition.
- Stowage – Proper storage of pilot ladders and related equipment when not in use.
- Maintenance – Keeping the equipment in working order to meet safety standards.
- Replacement – Replacing equipment when it no longer meets safety or operational requirements.
- Familiarization – Ensuring crew members are trained and familiar with the proper use of the equipment.
These rules are outlined in Parts D and E of the performance standards adopted by the IMO’s Maritime Safety Committee (MSC). Future updates to these rules will only take effect if officially approved and adopted according to the IMO’s amendment procedures. This ensures all pilot transfer arrangements meet consistent safety and operational standards over time.
7. For the purpose of the present regulation, the expression “installed on or after [1 January 2028]” means a contractual delivery date for the pilot transfer arrangement or, in the absence of a contractual delivery date, the actual delivery date of the arrangement to the ship on or after [1 January 2028].
This (article 7) means that if a pilot transfer arrangement is considered “installed on or after [1 January 2028],” it refers to one of two things:
- Contractual Delivery Date: The date agreed upon in a contract for the equipment to be delivered to the ship on or after [1 January 2028].
- Actual Delivery Date: If no contract specifies a delivery date, it means the date the equipment was physically delivered to the ship on or after [1 January 2028].
In short, it’s about when the equipment is delivered—either as per a contract or the actual delivery—starting from [1 January 2028].
8. Pilot transfer arrangements provided for in paragraph 3 shall be approved by the Administration in accordance with part F of the performance standards adopted by the Maritime Safety Committee by resolution MSC.[…], as may be amended by the Organiztion, provided that such amendments are adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
This (article 8) means that all pilot transfer arrangements described in paragraph 3 must be officially approved by the ship’s flag state authority (the Administration). The approval must follow the rules outlined in Part F of the performance standards adopted by the Maritime Safety Committee (MSC).
If these rules are updated in the future, the changes will only take effect if they are formally adopted and enforced according to the IMO’s established amendment process.
So, the arrangements must meet strict safety standards and be approved by the appropriate authority to ensure compliance.
9. Pilot transfer arrangements provided for in paragraph 3 on ships to which chapter I applies shall be inspected in accordance with regulations I/6 and I/7 or I/8. Pilot transfer arrangements on ships to which chapter I does not apply shall be inspected to the satisfaction of the Administration.
This regulation (9) specifies that pilot transfer arrangements on ships must undergo regular inspections to ensure safety and compliance:
- Ships Covered by Chapter I:
- These ships are subject to detailed survey and certification requirements as outlined in Regulations I/6, I/7, and I/8 of SOLAS Chapter I.
- Regulation I/6: Covers general procedures for the inspection and survey of ships, ensuring they meet safety standards.
- Regulation I/7: Details survey requirements for passenger ships, including initial, renewal, and additional surveys to verify compliance.
- Regulation I/8: Specifies survey requirements for cargo ships’ life-saving appliances and other equipment, ensuring they are fit for service.
- Ships Not Covered by Chapter I:
- For these vessels, pilot transfer arrangements must be inspected to the satisfaction of the Administration (the relevant maritime authority), ensuring they meet appropriate safety standards.
All ships must have their pilot transfer arrangements regularly inspected, following specific regulations for those under Chapter I, and adhering to the Administration’s standards for those not covered by Chapter I.
10. Mechanical pilot hoists shall not be used.
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These are not allowed anymore.
11. Adequate means of illumination, either fixed or portable, shall be capable of illuminating all pilot transfer arrangements overside and the position on deck where pilots and other personnel embark or disembark. Portable lights, when used, shall have brackets to permit their positioning.
This article states that all pilot transfer arrangements must have adequate lighting to ensure safe boarding and disembarking of pilots and personnel. Lighting can be fixed or portable, but it must effectively illuminate the transfer area over the side of the ship and the deck positions involved.
- Portable lights: If used, they must have brackets for secure positioning. This means lights hanging loosely from ropes or wires are not allowed, as they could obstruct the pilot, provide poor illumination, or fail due to instability or damage.
- The term “adequate” means the lighting must be suitable for the challenging conditions of a seagoing environment. This requires equipment to be wear-resistant, corrosion-resistant, and watertight to withstand harsh maritime conditions and ensure reliability.
This regulation emphasizes safe, stable, and durable lighting to prevent accidents and maintain operational safety during pilot transfers.
12. Where a pilot or person suspects the pilot transfer arrangement provided is non-compliant, they should inform the master and refuse to use the arrangement until it is made compliant.
This article underscores the critical role of safety in pilot transfers, advising that pilots or other personnel who suspect the pilot transfer arrangement is non-compliant should:
- Inform the Master: Notify the ship’s captain about the issue.
- Refuse to Use the Arrangement: Decline to use the equipment until it is compliant with required standards.
Since the article uses “should” instead of “shall,” it is advisory rather than mandatory. This means pilots and pilot boat crews are not legally obligated to refuse non-compliant arrangements, but failure to follow the guideline could have serious implications:
- Insurance Coverage: Pilots who knowingly use non-compliant arrangements may risk jeopardizing their insurance coverage in the event of an incident. Insurers might view non-compliance as negligence, potentially invalidating claims.
- “Comply or Explain” Rule: This principle could apply, requiring pilots to justify their decision to use a non-compliant arrangement. While this might provide flexibility, it introduces risks if the justification is not deemed reasonable after an incident.
This article indirectly places responsibility on pilots and their organizations to uphold safety standards. While it doesn’t impose direct liability, failure to act on suspected non-compliance could:
- Expose pilots or organizations to legal or reputational risks in the event of an accident.
- Shift some responsibility onto pilot organizations to ensure proper training and protocols for identifying and addressing non-compliance.
Although a guideline is not legally binding, following it protects the safety of pilots and crew, ensures compliance with best practices, and minimizes potential liability. It emphasizes the shared responsibility of individual pilots and their organizations in promoting safe pilot transfer operations.