How many Navy vessels are compliant to SOLAS ch.V reg23?

by Arie Palmers - published on 25 April 2022 494 -

Photo’s courtesy of the Dangerousladders page on Facebook


As a pilot you come across a wide variety of ships. Amongst all those ships we bring in and out of ports all over the world several of them belong to the navies of the various countries of this same world. Quite often those vessels have the tendency of presenting themselves with a pilot transfer arrangement which is non-compliant i.a.w. SOLAS ch.V reg.23, IMO A.1045, ISO799-1/2019 etc.etc..

Let’s focus on SOLAS in this article because it has been accepted as international law worldwide (reg. 23 talks about REQUIREMENTS). IMO provides RECOMMENDATIONS and has not been accepted as law worldwide: a recommendation is often defined as a guideline and not a rule, despite the fact the some of the recommendations have been in the IMO A.1045 for over 40 years… And as far as the ISO goes: it hasn’t been accepted as the worldwide standard everywhere (yet…)

We know when SOLAS started; back in 1914, after the sinking of the Titanic the first version of this treaty has passed. In the more than 100 years of its existence it has been amended and updated many times. It provides the basic rules, or the minimum standards for vessels in Safety of Life at Sea.

What would make navy vessels think they don’t have to comply with such important basic rules? Well, I do understand you cannot throw SOLAS approved bombs at each other, but where does this come from?

So, let’s have a look at SOLAS, it’s only 910 pages…. Chapter I, regulation 1 explains:
  • (a) Unless expressly provided otherwise, the present Regulations apply only to ships engaged on international voyages.
  • (b) The classes of ships to which each Chapter applies are more precisely defined, and the extent of the application is shown, in each Chapter.
So, the text above basically excludes all inland marine traffic from these rules. Each chapter will explain to what kind of vessel the specific chapter applies.
Non-compliant and dangerous setup
Non-compliant and dangerous setup
Non-compliant and dangerous setup
Non-compliant and dangerous setup
Regulation 3 provides us with the exceptions:
(a) The present Regulations, unless provided otherwise, do not apply to:
. (i) Ships of war and troopships
. (ii) Cargo ships of less than etc.etc.

Would this mean that Navy vessels don’t have to comply to any rule at all? That’s strange.. SOLAS has just told us that we’d have to look at the specific chapter, so let’s move on to Chapter V (Safety of Navigation) and see if there are any exemptions here.

Chapter V starts with the application and explains:
  • 1. Unless expressly provided otherwise, this chapter shall apply to all ships on all voyages, except:
  • . .1 warships, naval auxiliaries and other ships owned or operated by a Contracting Government and used only on government non-commercial service and….. etc.etc..
This means navy vessels are excluded from ch.V…. BUT (here’s the but…) there is an explanation a bit further down the text saying: However, warships……… are ENCOURAGED to act in a matter consistent, so far as reasonable and practicable, with this chapter.

Well, isn’t that nice? SOLAS encourages the navy, this basically means nothing: you can for example encourage your pet to stop destroying your furniture, but the pet isn’t obliged to comply because it’s not a rule but a kind of recommendation.

This article could stop here, stating navy can do anything, but I thought there must be regulation on navy ships.. they would have to comply with something I would say, every seafarer wants to be as safe as possible and the same goes for navy service personnel.

Regulation 23 starts with the application stating:
Ships engaged on voyages in the course of which pilots may be employed, shall be provided with pilot transfer arrangements. Ok, fair enough, but we have just seen that navy vessels are excluded from chapter V..
Another unsafe example
Another unsafe example
Another unsafe example
Another unsafe example
Since I come from the Netherlands, I thought easiest would be to look at the rules our Royal Navy is subjected to. In national law there isn’t much to find on it but internationally I came across a very interesting set of rules to which our Dutch navy vessels must comply. The Netherlands Royal Navy is a member state of NATO. NATO has currently 30 member states, so that means quite a lot of navy ships worldwide are in NATO. SOLAS has 164 member states, so this is roughly about 20% of the total…

We have read a bit back in the article, that states are encouraged to comply as much as possible etc. etc. Well, NATO has laid down a standard with the official name ANEP-77 NAVAL SHIP CODE Edition E Version 1 (do keep in mind this is all found on the internet and isn’t NATO classified in any way).

I had never heard of this set of rules, and I even have served in the navy many years back, it was well before 2014 so that might explain it.
Would they use it themselves????
Would they use it themselves????
Would they use it themselves????
Would they use it themselves????
First let’s find out what this ANEP thing is.. In the introduction it starts with the AIM, which says:

The overall aim of the Naval Ship Code is to provide a standard for naval surface ship based on and benchmarked against IMO conventions and resolutions that embraces the majority of ships operated by navies (728 pages..)

Are all NATO vessels subjected to these rules? Unless expressly provided otherwise, the present regulations apply only to naval surface ships that are not nuclear powered. In the ladder section we’ll see what is suitable there.

So, NATO took on the challenge of the ‘encouraging’ text and came up with their own set of rules. Basically, you could state it is an amended copy of SOLAS, but more suitable for navy ships. Since you might know I have a professional interest in pilot transfer arrangements, we’ll leaf through the section that covers that item.
Very unsafe again
Very unsafe again
Very unsafe again
Very unsafe again
The rules on pilot transfer arrangements have been laid down in Regulation 11 Pilot Transfer Arrangements (page IX-27) and the functional objective is as follows:

Ships engaged on voyages in the course of which pilots may be employed, shall be provided with pilot transfer arrangements for the safe transfer of pilots from either side of the vessel.

There it is… no loopholes, no exceptions here… This sentence sounds a bit familiar doesn’t it? As I stated above, a lot of the text in ANEP77 is indeed a copy of the text in SOLAS and even some IMO resolutions.

The text ends with: The requirements of SOLAS Chapter V, Regulation 23 and IMO Resolution A.1045(27) shall be met. This is an important one: NATO states here that all pilot transfer arrangements shall be compliant to SOLAS and IMO. So, whenever a NATO navy ship claims they do not have to be SOLAS compliant (a stupid excuse for not having to be safe…), you can revert to the ANEP77 and tell them that according to the ANEP77 their pilot transfer arrangement has to be SOLAS and IMO compliant.

I am very curious how these items are countered in non-NATO countries (which is the vast majority of navy ships of course). Language as well as different types of writing (Chines, Japanese, Korean, Cyrillic etc etc) are a big barrier for me to get into it. If anyone who reads this article, has any information on it, please let me know. At least we have covered about 20% of the world’s navy fleet with this article, only 80% left.. On the next page you’ll find a copy of the respective ANEP text on ladders.
I hope this article will be of any assistance in the attempt of getting to work and back in one piece (commuting is the most angerous part of our job after all). Please stay safe and healthy everyone!!

Kind Regards,
Arie Palmers
Registered Pilot
sea, river, harbor pilot (westerschelde, oosterschelde and adjacent coastal area) active marine pilot - Loodswezen - NEDERLANDSE LOODSENCORPORATIE

50 years old, without a proper birthday party this year ( thank you corona..) 12 years as a pilot 2 years offshore/tugboats 8 years with juvenile delinquents mv Koningin Juliana, mv Smal Agt 8 years Navy: minehunter, explosive ordnance clearance 2 years army: artillery sergeant

Join the conversation...

Login or register to write comments and join the discussion!
René Hartung Lotsenbrüderschaft NOK II Kiel / Lübeck / Flensburg, Germany
on 25 April 2022, 12:45 UTC

Nice to read that they have some regulation -
Next time I board frigate „Sachsen“ I will have a copy with me in case they still think that putting the spreader behind the gangway ist a sage matter if securing the gangway (which unfortunately I only saw when I reached the deck)


Video Timelapse | Ship picks up anchor and proceeds to berth - Singapore straits

published on 18 March 2022

Timelapse of my ship's transit from AEPA Anchorage in eastern Singapore harbour to Universal Terminal Singapore, in the western part of the harbor. The pilot took us out into the traffic lane to avoid inshore traffic. #merchantnavy #deckofficer #tankership #maritime Do enjoy and subscribe for more. Instagram: @officervikrant Facebook: Hi, this is Vikrant. I am a Trainee navigating officer in the merchant navy, soon to be a 3rd officer. Follow me on instagram and...


Opinion 1000 stanchions around… Which ones are correct and which ones are killers?

by Arie Palmers - published on 6 December 2022

Stanchions therefore are an often-overlooked part of a pilot transfer arrangement and therefore I
want to give them more attention in this article. They proved to be the cause of a whole series of accidents, some of which were even fatal.


Article Combinations Ladders: "1,000 combinations around" (by Arie Palmers)

by Arie Palmers, Netherlands - published on 13 July 2020

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.


Article Briese research and Nautitec create a lifelike virtual simulation model of research vessel „Maria S. Merian”

published on 16 November 2021

Briese research are extending their cooperation with Nautitec for their research training projects. As from immediate effect, a model of the research vessel “Maria S. Merian” can be used for tailor made training at NAUTITEC´s Leer-based simulator facilities.


Video Mindfulness in Shipping Webinar

published on 24 July 2020

In this webinar, Rev. David Reid, AFNI looks at why we need to learn this skill and put it to work to promote safety at sea and the wellbeing of our colleagues. Are we mind full or mindful?


Video Shiphandling: Pivot Point and Transverse Thrust

published on 22 May 2022

Gavin Buchanan on YouTube: "Some of the best Ship Handling videos available online. Studying for my Master 3000 and have found these videos incredibly helpful. Thank you for making these free for students!"


Video Fathom Safety (UK): New Online Pilot Ladder Training

published on 13 February 2024

Fathom Safety now offers an online course on Pilot Ladder Training


Article Concept of Reskilling for Automation Collaboration in Maritime Piloting

published on 22 August 2022

Advanced automation has been highlighted as contributory to several accidents involving modern bridge support systems and automation aiding maritime pilots for maneuvering and navigation. This paper argues for reskilling for automation collaboration.


Video Montevideo Pilot boat.

published on 14 January 2022


Video How to build a safe Pilot Ladder. The production at PTR Holland

published on 20 December 2019

PTR Holland - TV Rijnmond 2003