Unified Interpretation of SOLAS Regulation V/23.3.3
23 January 2015 / C15002
The Maritime Safety Committee, at its ninety-fourth session approved a unified interpretation of SOLAS Regulation V/23.3.3 on pilot transfer arrangements.
SHIP OWNERS / MANAGERS / OPERATORS
DBS STATIONS / SURVEYORS
Through MSC.308(88), amendments have been adopted to SOLAS Regulation V/23 requiring pilot ladders on all ships (new and existing) to be clearly identified, new equipment and arrangements for pilot ladders to be certified by the manufacturer and it has been prohibited to use mechanical pilot hoists.
For further information on the revised SOLAS Regulation V/23 as well as its effects on existing ships please refer to Dromon Circular C12011 here.
The Maritime Safety Committee, at its ninety-fourth session held in London on 17 to 21 November 2014 approved a unified interpretation of SOLAS Regulation V/23.3.3 as prepared by the Sub-Committee on Navigation, Communications and Search and Rescue (NCSR), at its first session.
What SOLAS Regulation V/23.3.3 requires?
The regulation states:
“Safe and convenient access to, and egress from, the ship shall be provided by either:
.1 a pilot ladder requiring a climb of not less than 1.5 m and not more than 9 m above the surface of the water so positioned and secured that:
.1.4 the single length of pilot ladder is capable of reaching the water from the point of access to, or egress from, the ship and due allowance is made for all conditions of loading and trim of the ship, and for an adverse list of 15O; the securing strong point, shackles and securing ropes shall be at least as strong as the side ropes; or
.2 an accommodation ladder in conjunction with the pilot ladder (i.e. a combination arrangement), or other equally safe and convenient means, whenever the distance from the surface of the water to the point of access to the ship is more than 9 m.”
What is the interpretation of SOLAS Regulation V/23.3.3?
Subparagraphs 1 and 2 of SOLAS regulation V/23.3.3 address two different and distinct arrangements – the former when only a pilot ladder is provided; the latter when a combined arrangement of “an accommodation ladder used in conjunction with the pilot ladder” is provided.
- SOLAS regulation V/18.104.22.168 limits the climb to not more than 9 m on a single ladder. If only a pilot ladder is to be used, the maximum height of 9 m from the “safe and convenient access to, and egress from, the ship” to the surface of the water is to include consideration of an adverse list of 15°.
- SOLAS regulation V/22.214.171.124 and section 3 of resolution A.1045(27) applies to a combined arrangement of “an accommodation ladder used in conjunction with the pilot ladder” for “Safe and convenient access to, and egress from, the ship” for which a 15° list requirement does not apply.
Dromon Surveyors are invited to use the unified interpretation provided above as guidance when applying the relevant provisions of SOLAS Regulation V/23.3.3 for pilot transfer equipment and arrangements.
Dromon Surveyors are also referred to our reports SWP04/Form 06 and SWP04/Form 07 Section 2.37 during the annual and periodical SOLAS/SAFEQ survey respectively. When completing this section of the reports, they shall use this unified interpretation.