The IMO Navigation, Communications and Search and Rescue Eleventh Session (NCSR 11)

took place between 4 – 13 June 2024, where key SOLAS amendments were adopted to
enhance the safety of pilot transfers.

As explained, the amendments to SOLAS aim to improve compliance and address

inconsistencies and ambiguities in existing regulations. The Sub-Committee also finalized a
draft MSC resolution on Performance standards for pilot transfer arrangements, including
detailed requirements for 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 SOLAS
regulation V/23.
Pilot transfer arrangements and amendments to SOLAS regulation V/23 agreed

Maritime pilots with local knowledge are employed to guide ships into or out of port safely,
or wherever navigation may be considered hazardous. Getting pilots on board a ship must be
done with the highest safety standards.

To improve compliance and address inconsistencies and ambiguities in existing regulations,

the Sub-Committee finalized draft amendments to SOLAS regulation V/23 and associated
instruments on the safety of pilot transfer arrangements.

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All the above will be submitted to the upcoming session of the Maritime Safety Committee
(MSC 109) in December 2024, with a view to approval.
Do you know why ships need a marine pilot?

A marine pilot, also called maritime pilot, harbor pilot, port pilot, ship pilot, or simply pilot,
is a mariner who maneuvers ships through dangerous or congested waters, such as harbors or
river mouths. They are navigational experts possessing knowledge of the particular
waterway, licensed or authorised by a recognised pilotage authority.

When a ship needs to enter or leave a harbor, marine pilots are sent aboard via a small pilot
boat to safely navigate the vessel through the local waterways. This operation is known as
pilot transfer arrangements.

Unlike the captain and crewmembers who travel onboard the ship, marine pilots are usually
stationed at the ports. While due to the nature of the work, many pilots have previously
worked as a ship’s officer or master.
Safe pilot transfers: An ongoing challenge

Ensuring safe pilot transfers remains crucial for the maritime industry. The results of the
2023 IMPA Safety Campaign show that historical trends in non-compliance continues. The
headline non-compliance rate remains over sixteen percent, and the main determinant of
noncompliance remains pilot ladders.
Meanwhile, from 10 July to 9 August 2023 the Paris Memorandum of Understanding (MoU)
on Port State Control conducted a Focused Inspection Campaign (FIC) on Pilot Transfer
Arrangements (PTAs). According to Paris MoU, a total of 1,262 Port State Control
inspections were carried out, during which 100 ships were found with one or more
deficiencies with the pilot transfer arrangements.

Latest IMPA Safety Campaign on pilot ladders raises awareness of the need for pilot transfer
arrangements to be procured, inspected, maintained and rigged in compliance with SOLAS
regulation V/23, taking complete account of the ISO 799 standards. IMPA highlights the
need to secure pilot ladders at intermediate length and conduct mandatory training, inspection
and maintenance.

The results of the 2023 IMPA Safety Campaign show that historical trends in non-
compliance continue. The headline non-compliance rate remains over sixteen percent, and the
main determinant of noncompliance remains pilot ladders. Pilot ladder observations are
included in more than fifty percent of reports of non-compliant arrangements.

2023 has been an important year for the safety of pilot transfer arrangements. The
International Maritime Organization (IMO) is working now to amend SOLAS regulation
V/23 and its associated recommendations. This work is anticipated to result in an enhanced
and more robust safety regime for pilot transfer arrangements for the benefit of pilots and
other users.

..Capt. Adam Roberts, Vice President & Chairman of the IMPA Safety Sub-Committee.

Critical aspects of the proposed amendments speak directly to the results presented
here and in previous years. Those aspects are :

 Mandatory requirements and the removal of extensive grandfathering risk

 Approval by Administrations, quality management systems and third-party
certification
 Addressing trapdoor arrangements based on ISO 799-3:2022
 Standards alignment between IMO instruments and ISO 799
 Securing pilot ladders at intermediate length
 Mandatory training, inspection and maintenance requirements
 Mandatory maximum service life for pilot ladders and man-ropes
 Amendments to SOLAS Chapter V, Regulation 23

But, that change is not expected to enter into force until 2028. In the meantime, the focus
must be on raising awareness of the need for pilot transfer arrangements to be procured,
inspected, maintained and rigged in compliance with SOLAS regulation V/23, taking
complete account of the ISO 799 standards.
Credit: IMPA

Following the campaign, IMPA concludes the following:

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 We consider SOLAS regulation V/23, its associated IMO Assembly resolutions, and
the ISO 799 series standards the minimum requirement, not an aspirational target.
 IMPA advocates for pilots not to use and to report arrangements that do not conform
to these standards.
 Trapdoor arrangements remain a perennial challenge, and we would encourage more
shipowners and operators using them to take proactive steps to provide compliant and
safe arrangements based on ISO 799-3:2022.
 Similarly, procurement and maintenance policies focused on quality and a finite
service life are critical to ensuring that safe equipment is always available.
 We recommend that those responsible for procuring pilot ladders and associated
equipment rely on the services of reputable manufacturers and do not accept
equipment that does not have valid third-party certification against the requirements
of SOLAS regulation V/23 and ISO 799-1:2019. If in doubt, do not accept the
equipment – the lives of pilots, seafarers, inspectors, and surveyors may depend on it.
 Company procedures in approved safety management systems should be clear and
effective, at least reflect the latest IS0 799- 2:2021, and emphasise timely pilot ladders
and man-ropes replacement. Where the safety of life is concerned, it is better to
replace before failure than maintain to the point of failure.
 From 10 July to 9 August 2023 the Paris Memorandum of Understanding (MoU) on
Port State Control conducted a Focused Inspection Campaign (FIC) on Pilot Transfer
 Arrangements (PTAs). According to Paris MoU, a total of 1,262 Port State Control
inspections were carried out, during which 100 ships were found with one or more
deficiencies with the PTA.
 The Paris MoU is trialing an alternative approach to the regular Concentrated
Inspection Campaigns (CICs) by conducting several short targeted inspection
campaigns referred to as Focused Inspection Campaigns (FICs). In the coming
months more such FICs are scheduled.
 After completion of the trials, the results, ease of implementation and effectiveness
will be assessed and, on this basis, further decisions will be made on inspection
campaigns and their format. Part of the trial also involves assessing with whether or
not to pre-announce the inspection campaign.
 The first FIC was carried out on PTAs. This subject was chosen as several incidents
during pilot transfer, within the Paris MoU region and beyond, occurred which
warranted carrying out this campaign. Most of the time pilot transfers are carried out
safely, but the potential consequences of a person falling from a ladder can be fatal
and the high-risk embarkation and disembarkation of the pilot by ladder requires
constant management and supervision.
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 The purpose of the campaign was to verify whether the PTAs on board the ships
inspected were fulfilling the SOLAS requirements.
 A total of 1262 Port State Control inspections were carried out, during which
100 ships were found with one or more deficiencies with the PTA.
 Deficiencies found indicated that:
• when requested by Port State Control Officers to demonstrate, pilot ladders were not
properly rigged to allow pilots to embark and disembark safely. On several occasions
it was found that the weight of the ladder was not taken by its strongest point but, for
example, by the steps;
• pilot ladders were damaged and/or not properly maintained;
• identification of ladders and record keeping of surveys and repairs were missing.
 As the transfer via an embarkation ladder is a high-risk operation, flag States, Ship
Management companies and ship crews should be aware of the associated risks and
PTAs should be rigged in line with the SOLAS requirements.
 As usual, if deficiencies are found, actions by the port State may vary from recording
a deficiency and instructing the master to rectify it within a certain period of time, to
detaining the ship until the serious deficiencies have been rectified. In the case of
detention, publication in the monthly detention lists of the Paris MoU website will
take place.