Pilot Ladders – Error Enforcing Conditions and Deficiencies

CHIRP Maritime continues to receive reports related to problems for pilots getting on and off ships.

Looking beyond the easy scenario of blaming the crew, CHIRP has analyzed the reports to look a little more closely at what is going wrong. It was Sir Isaac Newton who stated in his Third Law that “Every action has an equal and opposite reaction.”

Fast forward a few centuries and an apt corollary might be that “Every introduction of a change to regulation can lead to unintended consequences.” Pilot embarkation and disembarkation is a case in point.

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 are now required at the point of entry and the ladder must be secured at a strong point or points on the deck; this effectively means that securing a pilot ladder by means of the ships side handrails is prohibited. 

Quite right too – who has not seen bent or fractured handrails? Ships’ side rails are not designed or certified to be load bearing. So now you have a pilot ladder which must be rigged at a gate in the railings, or at the bulwark with support stanchions and a bulwark ladder. This is straight forward if the freeboard is less than nine meters, and if the pilot ladder requires raising or lowering a little to match the size of a pilot launch then this should not pose a problem for the crew.

But what happens if the freeboard is greater than nine meters? In effect, because the pilot ladder is now in a fixed position (i.e. you cannot move it forward or aft), a combination ladder arrangement will only work at one position. This may be fine when you have vessels which carry a homogeneous cargo, but frequently today's trading patterns may make this less likely. The problem may equally apply to a fixed reel pilot ladder when it has to be used in a combination arrangement. 

Crews are ingenious and try many different methods to “get around” the issue, (more on this further in the article), but it remains a fact that the introduction of regulation has created an unintended problem. For new ships constructed after the regulation change it is equally plausible that the regulation is simply not given proper consideration at the design stage. 

Class, shipyards and company management should address potential non-compliance at the
design stage, not as an afterthought.

Solutions? There are solutions of course, but it takes a little thought and the assistance of naval architects either at the design stage or in the refit period of a vessel. If the problem is that a ladder (whether it be a pilot ladder or fixed upon a reel) cannot be moved in a fore and aft direction to meet a certain height for an accommodation ladder, then surely 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. This is not impossible – in the words of a pilot who regularly corresponds with CHIRP, “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 agrees – it can indeed be done with a little thought.

Additionally, it may involve having several removable sections of a ship’s side rail, but it is not difficult to comply. “Easy on a tanker with loads of deck space,” we hear you mutter, but what about vessels which are tight on space such as container vessels? Often a pilot ladder reel is squeezed onto a space between container stacks so there is no possibility for a longitudinal track. True, but we are not suggesting that the reel needs to be on a track, and the track can easily be located on the adjacent deck if sufficient slack is arranged where the ladder comes off the reel.

What have we missed? The solution above appears ideal to overcome the problem but in the introduction, it was stated that every new regulation introduces problems… so, what have we missed? For all of the good points which were added to Regulation 23 in 2012, one was missing – there is absolutely no mention of how to rig the ladder at deck level! 

Again, we hear howls of outrage – “We know how to rig a pilot ladder!” Judging by the large number of reports that we receive on the subject, CHIRP would disagree. Since there is no description of how to do it, and since we now appear to live in a world where, if it is not laid down in black and white it just does not get done, crews have invented their own methods and, in many cases, traditional seamanship has been ignored.

The full article is available here.

Captain Ian Shields is a CHIRP Maritime advisor.