Pilot Embarkation platforms

by Kevin Vallance deep sea pilot and author - published on 17 December 2019

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An earlier, shorter version of this article written by Deep Sea Pilot Kevin Vallance was included in the UKMPA Pilot Magazine. Kevin Vallance is the author of the Pilot Ladder Manual and Rule 10 TSS both published by the Witherby Publishing Group.

During the transit time on the pilot launch between the shore and the vessel, marine pilots will spend at least a portion of that time carrying out (either consciously or subconsciously) a risk assessment of the forthcoming operation.

Most pilots will be using a pilot launch they are familiar with; surrounded by a crew they know in an area that can at times seem like a second home. The vessel they are boarding may be one they have worked before and hopefully the pilot transfer arrangement will be compliant with current IMO requirements.

However, this is not always the case. Due to severe weather conditions in the North Atlantic a container vessel who regularly use the services of Hammonds deep sea pilotage was weather routed to enter the North Sea via the Pentland Firth.

Travel arrangements were made, because it was the weekend there were only limited flights available, so it was 12 hours on a train and a night in a hotel. A bright Sunday morning with a stiff breeze and a couple of metres swell was no problem on the tug supplied for the short run out from the harbour.
After the pilot transfer was ‘safely completed’ the vessel set off on her passage towards Bremerhaven.


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Photograph 1 shows the combination ladder arrangement provided with a trapdoor in the bottom platform, SOLAS refers to this as an ‘embarkation platform’.


During the passage on board the container vessel I had time for a fuller reflection on the condition of the pilot transfer arrangement provided:


  • On approaching the vessel it was observed that the pilot ladder being used, in the arrangement, an embarkation platform was a little high, the boat coxswain requested the ladder be lowered, which happened instantaneously. This action clearly illustrated that the platform was not secured to the vessel, a requirement of SOLAS V Chapter 23

  • Although it’s not clear too see in the photograph the retrieval line is rigged leading aft and at the wrong height also making it noncompliant with SOLAS.



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  • Photograph 2 shows the pilot ladder securing arrangement which is directly onto the embarkation platform structure.  Just above the height of the platform a 100 mm box section is welded to the platform, the pilot ladder side ropes are behind this box section which hampers the pilots climb.

  • When approaching the top of the pilot ladder it is necessary to manoeuvre through approximately 90° to transition from the pilot ladder on to the platform.   IMO Resolution A 1045 requires that the minimum size of the access hole should be 750mm X 750mm, the regulation also requires that stanchions be provided with a spacing of not more than 800 mm, this arrangement had no outboard stanchion to assist the pilot when making the transfer across.

  • Pilots who persist in carrying a bag when climbing a pilot ladder may find it even trickier when ascending through the platform door.


This particular vessel and its pilot transfer arrangement were constructed in 2014, well after the 2012 date which would have allowed it, under the so called ‘grandfathering clause’ to be not required to comply with the revised regulations which came into force in July 2015.

When ship staffs are asked about the safety of such arrangements the answer is invariably that the system is class approved. In the case of the arrangement in photographs 1 & 2 how have a major European Classification Society and a UK based P&I club allowed such a system to be certified and used?

To put it bluntly this arrangement does not comply with the requirements of SOLAS, which begs the question why did I use it?

Recent discussions on our #dangerousladders Facebook page have included an extended one about pilot embarkation platforms. There is a feeling that such arrangements although intended to make things safer, have in most instances had the opposite effect.

Embarkation platforms are not all of the same design and different version show up different deficiencies which are also non-compliant.


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The arrangement in photograph 3 clearly shows that the pilot ladder is secured to the bottom of the platform, although the regulation clearly and unambiguously states ‘the pilot ladder shall be rigged through the trapdoor extending above the platform to the height of the handrail’. This allows the pilots body to remain vertically upright throughout the climb until transitioning from the pilot ladder onto the platform. It is this transfer of the pilot’s weight from the pilot ladder to the embarkation platform and the resultant stresses which cause the single biggest concern for users.

Depending on the specific design of the platforms different acrobatic skills are required to make the transition. When climbing a pilot ladder it is important to keep one’s body as vertically upright as possible, the arrangement in photograph 3 does not allow this. Twisting your torso for the transition increasing body stresses particularly to the lower back. Posture when climbing has been suggested to be a risk factor for increasing body stressing. It is difficult when climbing a pilot ladder to maintain a balanced posture; a non-compliant embarkation platform puts additional stress and strain onto the pilot’s body.

SOLAS requires that where accommodation ladders are used in conjunction with pilot ladders (this includes embarkation platforms) the accommodation ladder should be secured to the ships side; this aligns the pilot ladder with the ships side helping with body posture during the climb and reducing the angle of swing.

For anyone who has not encountered such an arrangement on a dark windy night possibly with rainwater gushing down the platform think for a few seconds how you would make the hand transition when transferring from the pilot ladder onto the platform.


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Photograph 4 shows a hybrid arrangement which most certainly is not compliant, although it is as shown on the ships drawings shown in photograph 5, which must have been approved at various stages of construction. It could be said that this particular arrangement is non-compliant by design.


This hybrid transfer arrangement appears to be trying to present a combination ladder arrangement but by misusing the regulation for embarkation platforms. Specifically the pilot ladder is secured to the base of the platform which is a noncompliance for either arrangement.

If the ship builders had considered the content of SOLAS V Regulation 23 or if the relevent class societies or flag state administrations had been concsiencious this pilot transfer arrangement would not have been allowed.


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Photograph 5 also illustrates another major concern with regard to these embarkation platforms. The combined weight of the accommodation ladder/platform, the pilot ladder and the pilot are all fully suspended on the wires of the accommodation ladder. If during the transfer operation the pilot boat comes into contact with the pilot ladder the weight of the pilot boat is also indirectly transferred to these wires, there is no back up safety feature or redundancy within the system.

Under SOLAS V Regulation 23 no guidance is given with respect to standards for manufacturing or maintainace of these embarkation platforms, which may explain why we are seeing a variety of different designs which are not compliant with the intention or spirit of the regulations.

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