UK-based aviation and maritime confidential incident reporting company CHIRP Maritime has said that it was continuing to receive many reports of pilots encountering difficulties when boarding and leaving ships due to problems with ladders.
CHIRP analyzed the reports and concluded that “every introduction of a change to regulation can lead to unintended consequences”.
CHIRP said that the last major SOLAS revision on the subject, (Chapter V – Regulation 23), was in 2012 and was accompanied by IMO Resolution A.1045(27).
One of the new requirements related to the safe access at deck level. Fixed handhold stanchions were required at the point of entry and the ladder had to be secured at a strong point or points on the deck. This effectively meant that securing a pilot ladder by means of the ships side handrails was prohibited.
CHIRP said that this was correct as ships’ side rails were not designed or certified to be load-bearing.
This meant that there was a pilot ladder that had to be be rigged at a gate in the railings, or at the bulwark with support stanchions and a bulwark ladder. This was straightforward if the freeboard was less than 9 metres and if the pilot ladder required raising or lowering a little to match the size of a pilot launch.
But if the freeboard was greater than nine metres, problems arose. Because the pilot ladder was now in a fixed position a combination ladder arrangement would only work at one position. The problem might equally apply to a fixed reel pilot ladder when it had to be used in a combination arrangement.
CHIRP said that crews were ingenious and tried many different methods to circumvent the issue, but it remained a fact that the introduction of regulation had created an unintended problem.
For new ships constructed after the regulation change it was equally plausible that the regulation was not given proper consideration at the design stage.
CHIRP said that Class, Shipyards, and Company Management should address potential non-compliance at the design stage, not as an afterthought.
CHIRP said that the introduction of a longitudinal track with suitable securing arrangements to lock the ladder and stanchions in place would enable a ladder to be effectively rigged in a combination arrangement. The modification would need Class certification that the strength was equal to or greater than the 24 kiloNewtons (close to 2.5 tonnes) required by SOLAS V Regulation 23. One pilot told CHIPR: “I just left a tanker with a totally compliant ladder on a reel with tracks to have it moved sideways to deal with any changes in draft. Not complicated or expensive and easy for the crew to use. It can be done …”
CHIRP concluded that there remaine a great deal of work to do in order to make the transfer of pilots to and from a vessel safer. A change in regulation might help, but all mariners could assist by ensuring that their pilot ladders and combination rigs were properly and safely rigged and inspected regularly. CHIRP said that all pilot ladders should now be certified. “We at CHIRP Maritime continue to be astonished at the poor level of seamanship regularly presented to us in these pilot ladder reports. We accept that there is no current good practice available on securing ladders but seafaring is about applying common sense with practical skills to solve problems.”
It emphasized that there was a right way to rig and maintain ladders, but “as we see so many deficiencies it leads us to ask the question: Is the quality of basic training meeting the requirements of STCW? It would appear not. In fact, it seems to be getting worse as the years go by.”