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PILOT BOARDING RISKS
Published: 1 January 2020
The risks associated with the safe transfer of pilots at sea are unfortunately not a new matter, reflected by the many tragic accidents over the years investigated by organisations such as the Australian Transport Safety Bureau (ATSB).
Sadly, such accidents likely represent only a small proportion of the hazardous scenarios faced by pilots. Marine Notice 03/2019, recently issued by the Australian Maritime Safety Authority (AMSA) refers to six incidents since November 2017 where man ropes parted or the securing point failed; it also notes that AMSA regularly receive reports of non-compliant pilot transfer arrangements. Likewise, the UK’s Maritime Confidential Hazardous Incident Report Programme (CHIRP), which Britannia P&I Club sponsors, frequently feeds back on confidential reports received regarding the adequacy of boarding arrangements.
The AMSA notice provides a useful recap to shipowners, operators, masters and crew, as well as other stakeholders, of their obligations to provide a safe means of boarding for pilots. SOLAS Chapter V, Regulation 23 stipulates the mandatory[1] requirements for pilot transfer arrangements, noting that these are minimum standards. In Australia, Marine Order 21 (Safety and emergency arrangements) 2016 (MO21) implements SOLAS V/23 and should be complied with.
It is important to ensure that a pilot ladder is certified by the manufacturer as complying with SOLAS V/23 or “with an international standard acceptable to the Organization”; regulation 23.2.3 specifically referring to ISO 799:2004 “Ships and marine technology – pilot ladders” in this respect, noting that these standards are not identical. Other key considerations include:
- Appliances shall be kept clean and properly maintained and stowed, and shall be used solely for the embarkation and disembarkation of personnel.
- The equipment shall always checked by the responsible officer before being rigged and used in order to ensure that is is fit for purpose, in good condition and correctly secured.
- The rigging of the pilot transfer arrangements and the embarkation of a pilot shall be supervised by a responsible officer with a means of communicating with the bridge.
- Personnel engaged in rigging and operating any mechanical equipment shall be instructed in the safe procedures to be adopted and the equipment shall be tested prior to use.
- Any modifications to a pilot transfer arrangement need to be approved by Class and/or Flag State, as applicable, to ensure continued compliance with SOLAS and/or relevant regulations
AMSA also point out that procedures for the regular inspections of the pilot transfer equipment, and its storage when not in use, should be established and followed as required by paragraph 10.1 of Part A of the International Safety Management Code (ISM).
A useful summary of the key considerations is also provided in the Industry Guidance document on Pilot Transfer Arrangements issued by the International Chamber of Shipping (ICS) and International Maritime Pilots’ Association (IMPA). This includes a copy of IMO/IMPA’s Pilot Boarding Arrangements poster, also issued as part of IMO Circular MSC.1/Circ.1428, and which depicts the pilot boarding arrangements required by SOLAS V/23. The AMSA notice concludes with two final key points:
- Members operating ships in Australia should note that AMSA port State control inspectors will pay particular attention to the material state of all pilot transfer equipment, including the implementation of the relevant IMO circulars and resolutions, as well as MO21 and ISO 799:2004.
- Compliance with the standards does not in itself always assure safety. The master or responsible deck watchkeeper of a ship providing a pilot ladder should assess whether supplementary measures, such as lifejackets, harnesses, lifelines and lifebuoys should also be put in place to assure the safety of personnel transferring onto their ship.
[1] The relevant IMO standards are also provided by IMO Resolution A.1045(27) “Pilot transfer arrangements”, as amended by IMO Resolution A.1108(29) “Amendments to the Recommendations on Pilot Transfer Arrangements” (Resolution A.1045(27)).