1. IntroductionDear reader,
Before you, you see my third article on pilot boarding arrangements. After my two previous articles ‘1000 ways to secure a pilot ladder’ and ‘1000 ladders around’, I have received a lot of feedback and also questions to get deeper into the matter of combinations and embarkation platforms.
Since the last two articles were published a lot has happened, more and more shipping companies as well as pilot associations worldwide are getting more aware of pilot boarding safety issues and the
way to get pilot boarding arrangements safe and compliant. As you might know, sometimes it is a very easy fix.
Concerning embarkation platforms… to get them compliant it often takes more effort: some constructional features must be changed; class agencies will have to approve etc. etc. but the costs to get it right will not be that high.. In this next article I would like to show you the rights and wrongs of these pilot boarding arrangements and what can be done to make them compliant as easy as possible.
In the next chapters we will also, as in the previous articles, get into the rules and I’ll try to explain as good as possible what is correct and what is not correct, of course illustrated with pictures out of my own database and from the database of facebook’s “dangerousladders”.
In this article names of shipping companies/ships and manufacturers will only be displayed for educational purposes, it’s not my goal to favor or bash around any company.
Hope you will enjoy reading this article!!
2. When to rig a combination or a single pilot ladder?Some vessels present themselves with a single rigged pilot ladder and some vessels present themselves with a ombination, or embarkation platform. Of course, there is a reason for these two different types of pilot boarding arrangements and in this chapter, I will explain why these two arrangements exist.
In SOLAS ch. V reg. 23 it is stated when to rig a normal pilot ladder and when to rig a combination:
3.3.1: a pilot ladder requiring a climb of not less than 1.5m and not more than 9m above the surface of the water…….
3.3.2: 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 9m. These simple rules tell us when the distance from the water to the pilot entry point is under 9 m you can rig a single pilot ladder and when the distance is more, a combination must be used…
Back to the pilot mark.
We know already that the separation of the white and red indicate the 9 meter mark, some vessels and shipbuilders however still seem to think the pilot mark is merely an indication for the pilot boat where the ladder is situated, but as we know now this is not the case.
Having a pilot mark displayed on the correct position of the ship is a very good asset and the approaching pilot launch can very easily asses whether the single pilot ladder is the correct pba or a combination should have been rigged.
On top of that we know from one of my previous articles that the ladder has to be secured to the ships hull at 1.5 meters above the platform (SOLAS ch.V V reg 23 18.104.22.168), which has been done as you can see but also (there’s always a but…) the ladder should run 2 meters past the platform (IMO A.1045 3.6: …… and should extend at least 2 m above the lower platform.) and that’s not the case here. The drawing below, which is a section of the pilot ladder poster shows how this setup should be done correctly.
3. 3. Combination arrangementIn the previous chapter we have seen when a single pilot ladder can be rigged and when a combination must be rigged. In another section of this article, we’ll discuss a different type of combination: the embarkation platform. In this section we’ll focus on the so-called standard combination arrangement.
We can also see the pilot on the ladder stepping upwards from the ladder to the platform, again a bad practice, he should only have to step sideways.
As we have seen there are some mistakes in the poster: the climbing sentence printed above the pilot launch is wrong…
SOLAS V ch 23 also tells us requirements in how to rig a combination.
In the previous chapter we already saw some regulations passing by 3.3.1 and 3.3.2)
22.214.171.124 tells us that the pilot ladder and manropes (manropes only on request of the pilot 7.1.1!!) must be secured at a point 1.5 m above the lower platform. Without these securing methods, the ladder can swing free and of course that is a dangerous practice.
3.3.2 tells us the platform also must be secured to the ship’s side
When the ladder has been secured at a point to close to the platform, it will obstruct your access to the ship. Worst cases would be losing your grip an falling back to the pilot launch (seriously injured) or into the water (seriously injured and wet).
The horizontal distance from the pilot ladder to the platform looks all right.
Of course there is a rule for that as well. IMO A. 1045(27) tells us: the horizontal distance between the pilot ladder and the lower platform should be between 0,1 and 0,2 m. Well, this makes sense: just a small sideway step from ladder to platform, after all we are no acrobats. Big distances from ladder to platform can easily again result in an accident.
Furthermore, we can see in the photo that the platform is not horizontal.
IMO A. 1045(27) tells us the platform should be in a horizontal position (makes sense doesn’t it) and secured to the ships side when in use. The lower platform should be at a minimum of 5m above sea level. This is done to prevent the combination and pilot launch ever touching eachother. Bigger heights may be required by the pilot boat.
In the first photo on the next page we can clearly see a badly rigged combination:
- platform not horizontal
- platform not secured to the ship’s hull
- ladder not secured to the ships hull at 1,5 m above the platform
- retrieval line not rigged properly (we have discussed this in a previous article: retrieval line is optional but when used it must be rigged at or above the bottom spreader and lead forward so it can never get caught to the pilot launch)
- we can also see it is a way to big step from pilot ladder to the platform, this photo shows very well why the distance from ladder to platform must be 0,1-0,2 m
Wires can break and situated leading aft; the dropping combination will move away from the pilot launch instead of on top of it. Should you be on the combination when it breaks…. Well good luck…. Injuries will occur of course….or worse…
the ladder is not firmly against the ship’s hull; steps are not horizontal, and the combination can swing free.The guy working on the combination when this photo was taken, isn’t wearing a life jacket or safety harness, tells us something about the safety culture on this vessel. SOLAS ch V reg 23 tells us in 2.2: personal engaged in in rigging and operating any mechanical equipment shall be instructed in the safe procedures etc etc…
As from 2012 when IMO A.1045(27) came into force, the maximum slope of the accommodation ladder was decreased from 55 degrees (IMO A.899) to a maximum of 45 degrees. To me this seems obvious: the steeper it gets, the harder it gets, and will lead to an increased risk of slipping away.
To be able to transfer yourself safely from the ladder to the platform you need stanchions to be able to grab during this step over, as stated in IMO A.1045(27) in rule 3.5: the ladder and platform should be equipped on both sides with stanchions and rigid handrails, but if hand ropes are used, they should be tight and properly secured. The vertical space between the handrail or hand rope and the stingers of the ladder should be securely fenced.
Of course you need fencing when you get on to at platform 60x60 cm dimensions, imagine the ship rolling and pitching dueto swell and you would be there without anything to hold on to, again a dangerous practice, but very often we see at least one stanchion is missing. Solution is to just tell the vessel went wrong and come back for round 2 about ten minutes later. I have told before that a lot of non-compliances are very easy fixes and can all be sorted within a few minutes. Even though of course it is rather silly not to put stanchions, what were they thinking?
This photo shows no stanchions on the platform, how to cross over? At least it will be very hard to reach the platform in this case: platform is in front of the ladder and that will make getting onto this platform nearly impossible. Also ladder and platform are not independently of each other secured to the hull, and as you can see on the photo the ladder is not firmly against the ship’s hull as required.
In my opinion ask them to get it sorted and come back after 10 minutes..
4. Embarkation platformAnother version of a combination arrangement we see quite often on bigger vessels, mostly container vessels, is a so-called embarkation platform (aka trapdoor).
Rather recently a drawing popped up on the #dangerousladder page showing how a compliant embarkation platform should be rigged:
Rules concerning these pba’s have been in force since at least 1979:
SOLAS ch. V reg. 23, 126.96.36.199: ….In the case of a combination arrangement using an accommodation ladder with a trapdoor in the bottom platform (i.e. embarkation platform), the pilot ladder and manropes shall be rigged through the trapdoor extending above the platform to the height of the handrail.
Mind you: manropes are optional and shall only be rigged on request of the pilot (SOLAS ch.V reg. 23 7.1.1)
A lot of vessels do not comply with these regulations and refer themselves as being built before 2012; 2012 was the year SOLAS ch.V reg. 23 first came into force. Basically what they are saying is: we don’t have to be safe… because of some grandfather clause..
SOLAS ch.V reg. 23 clearly states in 2.1:
All arrangements used for pilot transfer shall efficiently fulfil their purpose of enabling pilots to embark and disembark safely… seems quite easy to me that when people get will hurt or worse using non-compliant embarkation platforms, they don’t really follow this rule, but… yes yes grandfather clause..
SOLAS ch.5 reg. 23 was preceded by resolution MSC 99(73) (renumbering reg.17 as reg.23) which came into force July 2002. This rule states the same in 2.1, no changes have been made, well that makes things a bit easier.
IMO A.1045(27) states in 3.7:
The trapdoor should open upwards and be secured either flat on the embarkation platform or against the rails at the aft end of the outboard side and should not form part of the handholds.
Let’s continue with IMO A.1045(27) 3.7:” …. And the pilot ladder should extend above the lower platform to the height of the handrail and remain in alignment with and against the ship’s side.” We can clearly see on the photo that the ladder does not run to the height of the handrails. It has been put under the platform, hanging at the beam. Why is this dangerous? When you reach the top of the ladder, you have to lean back and grab some pieces of steel (slippery when wet) on the upward side of the platform (in this case even the trapdoor itself) then you have to pull yourself on your arms up through the gap (whilst loosing grip with your feet) turning sideways as you attempt this and get your body onto the platform.. all of this 5-7 meters above the surface of the water in all possible weather… going down on this particular setup. I had to sit on the platform with my feet through the gap, hold on to pieces of steel with my hands and lower myself through the gap until I felt the first step of the pilot ladder… sounds lovely doesn’t it??
Also because the ladder is hanging under the beam, it is not resting firmly against the ship’s hull and basically moves all over the place.
Back to some rules:
IMO A.1045(27) was preceded by IMO A. 889(21) from 1999 until 2012 and states in 3.7:
if a trapdoor is fitted in the lower platform to allow access from and to the pilot ladder, the aperture should not be less than 750mm x 750mm. in this case the platform should also be fenced as specified in par 3.5 (stanchions and handrails etc (ap)) and the pilot ladder should extend above the lower platform to the height of the handrail.
So even in 1999 they concluded that the ladder had to go through the gap to the height of the handrail but wait… it will get even worse when we go back a little bit further in time….
So after having looked at the regulations that have been in force even since 1979, we can conclude that 41 years of regulations regarding embarkation platforms have not resulted yet in compliant pilot boarding arrangements. We can now also conclude that vessels referring to the 2012 grandfather clause basically are full of bullocks to put it as politely as I possibly can…. When most of us were still playing with our toy cars, these old rules were already simple and in force….
One of the leading companies, I shall not reveal their name, but main office in Geneva, and the vessels are black (lol) has taken serious steps to modify each vessel in their fleet that still has a noncompliant embarkation platform.This is a big task and will take some time.
More and more companies are following up to ban the non-compliant embarkation platforms by changing them into correct ones, a big task lies ahead of most companies. Some companies (will not reveal their name) still show a stubborn behavior and refuse to change their systems. All they say is: class approved…. We know class approved doesn’t mean compliant in accordance with IMO and SOLAS regulations.
Also a lot of pilots just keep climbing them without making remarks and of course as long as we keep climbing, they’ll keep coming and captains then wonder why some pilots complain: mr. pilot you are the first one to complain…
Luckily a lot of pilot associations are also publishing letters, memo’s and articles concerning noncompliant embarkation platforms:
5. EpilogueAfter reading this article I can only hope you are more aware about the do’s and don’t concerning combinations and embarkation platforms.
Basically this article was only about a few rules from SOLAS ch V reg 23: rule 3 in total and IMO A.1045(27) rule 3 in total. Of course all the rules I have mentioned in previous articles are applicable to these systems but as you saw the focus was on these few simple rules this time. As I have stated before, the rules must be revised to make them easier and more understandable, because everything that can be misinterpreted, will be..
I am looking forward to your remarks and feed back on this article, please do not hesitate to contact me, should you have any!
For now please stay safe and have a good watch!
Arie Palmers (reg. pilot)