Unified Interpretation of SOLAS Regulation V/23.3.3

The Maritime Safety

Committee, at its ninetyfourth

session approved

a unified interpretation of

SOLAS Regulation

V/23.3.3 on pilot transfer

arrangements. 

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.

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/23.3.3.1 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/23.3.3.2 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.