1. What is the application timeline for the new pilot transfer arrangement standards under MSC.572(110) and MSC.576(110)?
The SOLAS Regulation V/23 amendments (Resolution MSC.572(110)) and the supporting mandatory Performance Standards (Resolution MSC.576(110)) enter into force on 1 January 2028. Application is based on the installation date of the pilot transfer arrangements:
- Installed on or after 1 January 2028: Shall fully comply with the amended provisions and the performance standards at the time of the installation
- Installed before 1 January 2028:
- Ships falling under SOLAS Chapter I – seagoing cargo ships of 500 GT and above and all passenger ships on international voyages – shall be brought into compliance at the “first survey” on or after 1 January 2029. These vessels shall be inspected in accordance with SOLAS regulations I/6 and I/7 or I/8.
- Ships not covered by SOLAS Chapter I – such as cargo ships below 500 GT and domestic or non-international vessels – shall comply with the requirements by 1 January 2030. These vessels shall be inspected to the satisfaction of the Administration.
- After entry into force date on 1 January 2028 (Irrespective to installation date): All pilot transfer arrangements, regardless of their installation date, shall comply with the inspection, stowage, maintenance, replacement and familiarization of all pilot transfer arrangements (parts D and E of MSC.576(110)) starting 1 January 2028.
The figure below provides a visual breakdown of these timelines based on vessel parameters.
2. How is the “installation date” defined?
The expression "installed on or after 1 January 2028" means a contractual delivery date for the pilot transfer arrangement or, in the absence of a contractual delivery date, the actual delivery date of the arrangement to the ship on or after 1 January 2028.
3. What does the term “first survey" mean?
The circular MSC.1/Circ.1290 provides the interpretation of term “first survey”. Under this circular, unless indicated otherwise, when the term “first survey” is referenced by a regulation in the 1974 SOLAS Convention, as amended, it means the first annual survey, the first periodical survey or the first renewal survey whichever is due first after the date specified in the relevant regulation (i.e., 1 January 2029 for the current case) or any other survey if the Administration deems it to be reasonable and practicable, taking into account the extent of repairs and alterations being undertaken. For this Regulation and for a ship under construction, when the installation date of pilot transfer arrangements is before 1 January 2028, but the ship is delivered on or after 1 January 2029, the initial survey acts as the “first survey”.
4. The pilot ladder of a new constructed VLCC is installed before 1 January 2028 (contractual delivery date), but vessel will be delivered on 5 January 2029. Do we need to comply with the new requirement?
Yes. Pilot transfer arrangements installed before 1 January 2028 on ships to which chapter I of SOLAS applies shall comply with the requirements not later than the first survey on or after 1 January 2029. With refer to the MSC.1/Circ.1290, for a ship under construction, where the installation date of the pilot transfer arrangement is before 1 January 2028, but the ship is delivered on or after 1 January 2029, the initial survey acts as the “first survey”.
5. Do vessels need to carry extra pilot ladders and manropes?
Yes, the new regulation requires at least one spare compliant pilot ladder and one spare set of manropes shall be carried on board. These are also required even if pilot transfer arrangements are provided on both sides of the ship.
6. What is the validity of the pilot ladder and manrope?
Pilot ladders and manropes, including their spares, shall be removed from service, either at any time not complying with these performance standards, or within 36 months after the date of manufacture or within 30 months after the date of being placed into service, whichever comes first, and shall not be used for the embarkation and disembarkation of pilots or other personnel.
7. Can the vessel crew carry out repairs to the pilot ladder steps or spreader?
No. Repair or replacement of pilot ladder steps or spreader steps onboard shall be prohibited. A spare set of pilot ladder arrangements shall be ready to be moved to either side of the ship to replace damaged equipment as needed. Pilot transfer arrangements installed in accordance with SOLAS regulation V/23 shall be approved by the Administration in accordance with the performance standards (MSC.576(110)) before being put into service for the first time and after repair, alteration or design modifications.
8. When is a combination arrangement needed? Are there any changes to the pilot boarding marking?
The height of climb on a pilot ladder shall not be less than 1.5 m and not more than 9 m from the surface of the water to the point of access in all seagoing conditions of draught and trim. Whenever the height of climb on a pilot ladder from the surface of the water to the point of access exceeds 9 m, the ship shall be provided with and rig an accommodation ladder in conjunction with the pilot ladder (i.e. a combination arrangement). On all ships which may require combination arrangements, a two-tone visual mark, the upper half being white and the lower half being red, not less than 4 m in height and 0.5 m in width shall be provided in the midship half-length of the ship in the vicinity of the pilot boarding position to indicate to the user whether or not a combination arrangement is to be rigged. The dividing line between the upper and the lower halves of the pilot line shall be 9 m below the point of access.
As point of access is defined the top of the coaming, bulwark or platform where the actual pilot transfer takes place. Therefore, it shall be verified that the pilot boarding mark is measured from the actual point of access, as defined above.
9. What is the requirement for existing strong points that lack documented evidence of their breaking strength?
For existing strong points with no documented evidence of their breaking strength, and in order to ensure full compliance with the Performance Standards (MSC.576(110)), ABS strongly recommends the replacement of the strong points with standardized, documented components. The details of eye plates together with welding to the deck, and underdeck supporting structures if any, are to be indicated on the drawings and submitted for review. Proof load testing of new components would generally not be required, while the manufacturer’s mill certificate of eye plates, welding and NDT are to be to the satisfaction of attending Surveyor. Other options (load testing, engineering analysis - i.e. FEA - in lieu of load testing, etc.) may be accepted subject to the approval by the flag Administration. However, as this is a topic that drawn the industry's concerns, the replacement of the existing undocumented strong points is the option that ensures fully compliance. If load testing is approved by the flag Administration, then there is no prohibition to carry out the load test at the Annual Survey. However, proof load testing may lead to deformation or damage of strong points depending on the testing load. In these cases, replacement is unavoidable and may be difficult to carry out the necessary works when the vessel is not gas-free.
10. Does the 915 mm minimum distance requirement from the deck edge apply to strong points for manropes?
No. Strong points exclusively used for securing manropes do not need to comply with the 915 mm criterion.
11. What are the minimum dimensions and door opening requirements for pilot transfer side doors?
The side opening shall have a minimum clearance of 2,200 mm (H) x 915 mm (W) to ensure unobstructed passage of pilots and other personnel. The ship’s side doors shall not open outwards unless they are located below the freeboard deck (refer to Regulation 21 of Annex I of the ICLL)
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