Provision of safe access

Accessing a vessel while at berth or anchor is a routine activity which is sometimes taken for granted. The requirement for safe access can be overlooked, particularly where there are limited berthing options, or a vessel is only berthed for a short period. Failing to provide safe access can result in serious harm to people—even more so when poor weather or extreme tidal variation are thrown into the mix.

Legislative requirements

SOLAS Chapter II-1 provides requirements for accommodation ladders and gangways. SOLAS Chapter IX gives effect to the International Safety Management (ISM) Code which requires procedures, plans, and instructions for key shipboard operations. Providing safe access to a vessel is considered a key operation under the ISM Code and should be addressed in the vessel’s safety management system.

In addition, Marine Order 12 (Construction—subdivision and stability, machinery and electrical installations) imposes responsibilities on the masters of vessels to ensure a vessel’s means of access is safe for users.  Seafarers need to be familiar with the risks associated with providing a means of access and ensure appropriate risk controls are in place.

Personnel abilities

The type of vessel access should be selected based on the experience and physical abilities of the people boarding the vessel as per ISO 5488:2015 and MSC.1/Circ. 1331. Their capability must be assessed prior to them embarking or disembarking, particularly when using a combination pilot and accommodation ladder. People using these ladders must be confident in using the equipment safely.

Wharf arrangements

When a vessel is alongside at a berth, the provision of safe access is a shared responsibility between the vessel and the provider of the berth. Often, it is poor wharf design that prevents landing a gangway, and this has a significant impact on safe access arrangements. The master and any provider of the means of access are both responsible for ensuring that a safe means of access is used.

Communication

This is important in identifying obstacles to safe access. Items such as water/fuel manifolds, bollards, and electrical installations on the wharf side are common obstructions and need to be considered when allocating berths to vessels. Co-ordination between shore-side and the vessel’s crew can help to mitigate these issues.

Rigging accommodation ladders and gangways

SOLAS Chapter II-1 Regulation 3‑9 and MSC. 1/ Circ.1331 include requirements for safely rigging vessel access equipment. In Australia, these standards are implemented through Marine Order 12 (section 24) and include:

• Gangways should not be used at an angle of inclination greater than 30 degrees from the horizontal.
• Ship accommodation ladders should not be used at angles greater than 55 degrees from the horizontal, unless designed and constructed for use at angles greater than these and marked as such.
• Adequate lighting, lifebuoys and a mounted safety net sufficient to prevent falls must be provided.

It is also recommended that accommodation ladders and gangways are positioned well forward of the propeller and avoid the lower part of the ladder and gangway overhanging off steep ship sides.

Gangways should be frequently monitored and adjusted as required to ensure they do not become too steep and are firmly landed on the wharf edge. Gangway providers are responsible to ensure adequate resources are afforded to adjust gangways as required by the master.

Assess the risks of rigging access

Rigging or adjusting gangways, accommodation ladders, or other access methods involves a heightened level of risks such as entanglement, falling from heights, or falling overboard. It is important to conduct a risk assessment of the rigging, adjusting and derigging of access equipment, including the selection of appropriate equipment and secondary means of support. 

Suspended accommodation ladders

Arrangements at some berths in Australia prevent accommodation ladders being safely landed on the wharf edge. In such situations it is common practice to suspend the ship’s accommodation ladder at the vessel’s side with a short brow or gangway fitted to the lower accommodation ladder platform to bridge the gap between the vessel and wharf edge.

Accommodation ladders and gangways are designed and tested to be landed on solid surfaces. To do otherwise is impacting on the engineering design of the shipboard access arrangement.

Access by pilot ladder

A pilot ladder, or combination ladder, is often provided to access vessels at anchor. Marine Order 12 (subsection 24(9)) makes it clear that the master may provide a pilot ladder as a means of access if they ensure only pilots and other persons on the business of the vessel use the ladder. The master may allow another person to use the ladder in an emergency (subsection 24(10)).

Recent fall from height fatalities associated with embarking and disembarking a vessel confirm this is a high-risk activity.

Marine Notice 06/2021 – Fatal accidents from falling off pilot ladders on ships provides further information and guidance on risks associated with using pilot ladders as a means of access.

Further reading

• MSC.1/Circ.1331 – Guidelines for Construction, Installation, Maintenance, and Inspection/Survey of means of Embarkation and Disembarkation
• ILO Code of Practice: Accident prevention on board ship at sea and in port (Section 3.4 - Shore-side access to ships; Section 8 - Safe access to ship)
• AMSA Maritime Safety Awareness Bulletin issue 10—Safe vessel access

November 2021

Australian Maritime Safety Authority
GPO Box 2181
CANBERRA ACT 2601

During 2018 and 2019, AMSA received notification of two separate accidents that involved crew members being trapped and crushed by a moving elevator. In both instances, the elevator moved while the crew members were working between the elevator casing and the cage, resulting in fatal crush injuries.

Incidents resulting in crush injuries caused by an elevator are not new, with a similar fatality investigated by the Australian Transport Safety Bureau (ATSB) in 2007. In this instance, a crew member was crushed in the elevator while conducting repairs. Elevator related fatalities have also been reported on multiple ships in other parts of the world.

AMSA believes that such incidents are avoidable through the application of simple and effective risk controls.

Systemic failures related to fatal crushes in elevators on ships

Similar systematic failures have been identified in all of these fatal accidents. The following were considered to be some of the key safety issues:

• Elevator instruction manuals lacked unambiguous and useable safety guidance.
• No proper risk assessments were in place for elevator maintenance as part of the safety management system.
• Risk assessments that did exist were not effectively implemented.
• Crew were not aware of—or did not consider—all of the hazards associated with working in the elevator. An example of this is the counterweights that moved down as the lift cage moved up, causing harm.
• Untrained personnel were used to carry out maintenance and repairs on the ship’s elevators.
• No appropriate safeguards were in place—such as isolation lock-out—to ensure that the elevator cage did not inadvertently move while the crew were working in the elevator shaft.

Expectation

An elevator shaft is a very hazardous environment in which to work. The potential dangers involve:

• height risk 
• injury by falling object(s)
• noise 
• electrocution from live electrical circuits
• unanticipated movement of the elevator cage. 

AMSA cannot stress enough the importance of conducting a proper risk assessment and implementing relevant procedures, which are applied in practice to ensure the safety of crew working on a ship’s elevator. 

AMSA also recommends planning for elevator maintenance or deferring elevator maintenance work until the vessel is in port and utilising a trained manufacturer’s technician. 

Effective risk assessment

AMSA’s Maritime Safety Awareness Bulletin issue 6 provides guidance on tools and methods that can be adopted to support risk identification and the implementation of risk controls.

Download Marine notice 1/2020—Fatal accidents caused by moving elevators on ships (PDF 197 KB) PDF196.25 KB

Mick Kinley 
Chief Executive Officer 
Australian Maritime Safety Authority
January 2020

GPO Box 2181 
CANBERRA ACT 2601

Affected nautical publications

AHO notes a significant increase in demand for digital nautical publications, with a commensurate decrease in demand for printed products. Therefore, the AHO has ceased producing printed versions of Australian National Tides Tables (AHP11) and Mariner’s Handbook for Australian Waters (AHP20).  AHO’s Notice to Mariners Edition 13-2022 of 24 June 2022 refers. 

Equivalent digital publications can be obtained from the AHO website. They provide mariners with the latest information on demand, contributing to improved situational awareness and navigational safety. 

Digital versions of AHP11 and AHP20 can be downloaded to portable electronic devices for free from the Product Downloads section of the AHO website.

Carriage requirements

Mariners are encouraged to subscribe to eNotices at the AHO website, so they can be notified by email when new updates to AHP 11 and AHP 20 become available.  

For more information on carriage requirements for nautical charts and publications, refer to Marine Order 27 or NSCV Part C, Subsection C7C.

British Admiralty publications 

The United Kingdom Hydrographic Office (UKHO) has not advised any changes to their nautical publications.  Therefore, UKHO’s Admiralty List of Lights, Sailing Directions, Tide Tables and other nautical publications should continue to be available in paper and electronic formats for now.

Background

In the first six months of 2020, AMSA received ten separate incident notifications from ships that involved a fall while working at height. Two of these incidents resulted in the deaths of crewmembers who fell during cargo hold cleaning operations. 

While AMSA has previously addressed this issue in a Maritime Safety Awareness Bulletin, incidents involving falls from height continue to occur far too often.

Risks of working at height

Falls can occur anywhere on a ship, such as from ladders, gangways, over the side and stairs in machinery spaces. When adding slippery surfaces and ship motion, the risk of a fall is high. 

Many of the serious fall from height incidents reported to AMSA involve people  working in cargo holds, either while cleaning or preparing the hold for cargo, or while conducting cargo operations. These incidents can involve both ships’ crew and shore-based staff such as stevedores.

Examining height safety is particularly important for the maritime industry because of the inherent risks of working aloft at sea, including slippery surfaces, extreme heights and ship motion. 

As many tasks on a ship require working at height, it is crucial to control and manage the risks involved. 

Recent Australian Transport Safety Bureau (ATSB) investigations into two serious incidents involving falls from height, highlighted a number of common issues. In both incidents, the work was not conducted in accordance with the existing safety management procedures or industry best practice, training was insufficient, and equipment, including fall arrest equipment, was incorrectly used. 

Working at height safely

Eliminating the need to work at height is the most effective way of protecting crew from the risk of falls. However, on ships this may not always be possible, hence, effective risk control measures must be in place to mitigate or reduce the risk of a fall. 

The primary risk control measures are the ship’s safety management system procedures, permit to work processes and training. Procedural risk controls, such as risk assessment and permit to work systems, are essential tools to manage high-risk activities such as working at height. Using these tools helps you to identify risks and measures to control, or reduce the risk.

Physical risk control methods are also important. Temporary work platforms are one method of reducing risk when working at height. These can include scaffolds, elevating work platforms, and personnel cages lifted by cranes. 

Fall arrest harnesses are an essential measure to reduce risk of injury if a fall is still possible after using other control measures. 

However, all these devices need to be correctly installed and used to ensure they effectively reduce the risk of a fall. 

The risk assessment should also consider what to do if something goes wrong – how will you rescue someone who is injured at height, or is suspended from fall arrest equipment?

Strategies to reduce fall incidents 

It is possible to reduce the number of falls from height at sea by addressing the broader issues in height safety practices. 

Managers and ships masters have a role to play in ensuring the safety of ship’s crew by:

• ensuring all crew are familiar with the working at height risk assessment and procedures,
• ensuring all work at height is adequately supervised, 
• ensuring safety training, including that required for working at height, is a top priority,
• ensuring permit to work systems are in place, effective, and are used,
• managing workload and ensuring that fatigue is effectively controlled
• ensuring suitable equipment (including rescue equipment) is available for use for working at height.

Seafarers also have a responsibility to:

• follow procedures,
• ensure they use the proper safety equipment for the task at hand, 
• know how to use safety equipment, 
• report defects, 
• not take any unnecessary risks. 

Further reading

AMSA’s Maritime Safety Awareness Bulletin Issue 1 provides more information on height safety including identifying common safety factors.

AMSA’s Maritime Safety Awareness Bulletin Issue 6 provides guidance on tools and methods you can adopt to support risk identification and control.

AMSA’s Fatigue guidelines – managing and reducing the risk of fatigue at sea, provides more information on reducing fatigue as a factor in workplace accidents.

ATSB’s investigation report MO-2018-001 Serious injury on board Berge Daisetsu, Portland, Victoria on 11 January 2018 provides an analysis of a fall from height incident.

ATSB’s investigation report MO-2017-001 Fall from height and serious injuries to crewmembers on board Shanghai Spirit near Port Alma, Queensland, on 29 January 2017 provides an analysis of a fall from height incident.

Sachi Wimmer
Deputy Chief Executive Officer
11 September 2020
Australian Maritime Safety Authority
GPO Box 2181
CANBERRA ACT 2601

Purpose

This Marine Notice:

• outlines AMSA’s management framework for UKCM in Torres Strait;
• summarises the various responsibilities for UKCM; and
• reminds masters that all coastal pilots transiting ships with draughts of 9m or above through the Prince of Wales Channel, Gannet Passage or Varzin Passage, are required to use the Under Keel Clearance Management (UKCM) system implemented by AMSA, when complying with Marine Order 54 (Coastal pilotage) (MO54).

Background

The UKCM system became operational in 2011 for use in the Prince of Wales Channel and both Gannet and Varzin Passages. The UKCM system contributes to safe marine navigation which facilitates the protection of the marine environment, and enhances the safety and efficiency of transiting vessels.

The purpose of the UKCM system is to ensure that the best possible under keel clearance information, updated in real time, is available to assist in the planning and safe conduct of vessel transits through Torres Strait.

The UKCM system is a web-based aid to navigation (AtoN) for use by ships’ masters, pilotage providers and licensed coastal pilots. When a successful UKCM transit plan has been calculated, coastal pilots can also save and print the plan for use and wider promulgation. The hardcopy printed plan is to be used in the event of any potential loss of connectivity to the web-based system during any UKCM transit.

Area of Operation

The UKCM system is designed to cover navigable ship routes through Torres Strait between the longitudes of 141 degrees  50 minutes east and 142 degrees 27 minutes east. Routes are limited to those areas designated by the Australian Hydrographic Service as having a data quality indicator of Category A Zone of Confidence (ZOC).

UKCM system access

Access to the UKCM system is available for approved users through a vetted registration process. To request registration, please follow the registration application process.

UKCM Training

UKCMS training can be accessed by registered users via the UKCM system’s ‘Help’ menu. Training for pilots includes a one-on-one competency assessment with an AMSA assessor.

Masters’ role in the UKCM system

Masters are strongly advised to provide accurate stability and draught data to pilotage providers in a timely manner. The supply of accurate data by masters will enable appropriate UKCM transit and associated route planning to be conducted by coastal pilots when complying with MO54.

Summary of Roles

Further information

General information about AMSA’s UKCM system can be found on the AMSA website.

Tutorials and fact sheets for coastal pilots about the UKCM system can be found on the AMSA website.

Contact us

For technical information about AMSA’s UKCM system, contact: coastal.pilotage@amsa.gov.au

Background

In accordance with the Navigation Act 2012, vessels over 70 metres in length, loaded oil tankers, loaded chemical carriers, and loaded liquefied gas carriers (irrespective of length) are required to embark a licensed coastal pilot when transiting any of the prescribed compulsory coastal pilotage areas.

Significant penalties may apply for navigating in any of the coastal pilotage areas without an AMSA-licensed coastal pilot onboard.

Naval vessels are excluded from the compulsory coastal pilotage requirements under the Navigation Act. 

It is important to note that the master of a vessel is not relieved of responsibility for the conduct and safe navigation of the vessel whilst the vessel is under pilotage — see section 326 of the Navigation Act.

Coastal pilotage areas

The following areas are prescribed compulsory pilotage areas under MO54:

• Hydrographers Passage;
• Inner Route;
• Torres Strait;
• Great North East Channel; and
• Whitsundays.

Coastal pilotage area definitions and boundaries (WGS84)

Hydrographers Passage pilotage area means the area bounded by a line that progressively joins the following points:

Point:             Latitude:                     Longitude:

1.                     20º 39.11′S                 149º 49.36′E

2.                     20º 35.91′S                 150º 07.36′E

3.                     20º 28.31′S                 150º 18.06′E

4.                     20º 02.91′S                 150º 03.06′E

5.                     19º 54.91′S                 150º 16.56′E

6.                     19º 39.91′S                 150º 10.56′E

7.                     19º 50.91′S                 150º 33.06′E

8.                     20º 01.41′S                 150º 25.86′E

9.                     20º 06.91′S                 150º 17.26′E

10.                   20º 19.91′S                 150º 27.06′E

11.                   20º 32.91′S                 150º 27.06′E

12.                   20º 41.51′S                 150º 11.66′E

13.                   20º 54.41′S                 150º 01.96′E

14.                   20º 39.11′S                 149º 49.36′E

Inner Route pilotage area means the waters bounded by:

1. the Australian mainland; and
2. the outer eastern edge of the Great Barrier Reef Region*; and
3. the northern boundary of the Great Barrier Reef Region* (latitude 10º 41.00′S) ; and
4. latitude 16º 39.91′S; and
5. the Torres Strait, excluding the waters to the north of latitude 10º 28.00′S and east of longitude 142º 39.00′E.

* Great Barrier Reef Region has the meaning given by section 3 of the Great Barrier Reef Marine Park Act 1975.

Torres Strait means the waters bounded:

1. on the south by latitude 10º 41.00’S; and
2. on the east:
   • for a ship moving eastward - by longitude 143º 22.00’E; or
   • for any other vessel - by longitude 143º 24.00’E; and
3. on the north by the line of Australia’s Exclusive Economic Zone (EEZ); and
4. on the west:
   • for a vessel of less than 8m draught - by longitude 142º 05.00’E; or
   • for a vessel of 8m draught or more moving eastward - by longitude 141º 50.00’E; or
   • for a vessel of 8m draught or more moving westward - by longitude 141º 51.70’E.

Great North East Channel pilotage area means the area bounded by a line that progressively joins the following points:

Point:              Latitude:         Longitude:

1.                     10º 41.0′S       141º 50.0′E

2.                     10º 28.0′S       141º 50.0′E

3.                     10º 28.0S′       142º 27.0′E

4.                     10º 18.0′S       142º 48.0′E

5.                     9º 48.0′S         143º 08.0′E

6.                     9º 30.0′S         143º 24.0′E

7.                     9º 45.0′S         143º 24.0′E

8.                     10º 20.0′S       143º 00.0′E

9.                     10º 41.0′S       141º 50.0′E

Whitsundays pilotage area means the area bounded by a line that begins at the northernmost point of Cape Gloucester at low water, at about latitude 20º 03.94′S, longitude 148º 27.51′E, and continues progressively:

1. to the following points:

Point:              Latitude:         Longitude:

1.                     19º 58.02′S     148º 18.60′E

2.                     19º 57.83′S     148º 18.53′E

3.                     19º 58.00′S     148º 21.68′E

4.                     19º 58.28′S     148º 27.05′E

5.                     19º 58.37′S     148º 27.40′E

6.                     19º 59.28′S     148º 33.62′E

7.                     20º 00.82′S     148º 37.48′E

8.                     20º 02.17′S     148º 53.07′E

9.                     20º 03.58′S     148º 57.92′E

10.                   20º 14.42′S     149º 10.47′E

11.                   20º 15.20′S     149º 11.15′E

12.                   20º 28.93′S     149º 08.03′E

13.                   20º 31.20′S    149º 09.07′E

14.                   20º 34.28′S     149º 10.50′E

15.                   20º 33.91′S     149º 07.06′E

16.                   20º 39.73′S     148º 45.82′E

2. west along parallel of latitude 20º 39.73′S to the coastline of the mainland at mean low water, near Midge Point; and
3. generally northerly, easterly, south-easterly and north-westerly along the coastline of the mainland at mean low water to the point where the boundary began.

Exemptions

Masters or vessel owners may apply to AMSA for an exemption from the pilotage requirements of the Navigation Act — see section 172. An exemption application must also be made to the Great Barrier Marine Park Authority (GBRMPA) to navigate without a licensed pilot in the Hydrographers Passage, Inner Route and Whitsundays pilotage areas.

Further information about coastal pilotage exemptions is available at AMSA’s website: Coastal pilotage exemptions (amsa.gov.au)

Further information

General information about coastal pilotage requirements can be found on the AMSA website: Under keel clearance management

Contact us

Any queries regarding coastal pilotage requirements should be directed to: coastal.pilotage@amsa.gov.au

Background

Maritime safety information (MSI), as defined in regulation IV/2 of the International Convention for the Safety of Life at Sea, 1974, as amended, means navigational and meteorological warnings, meteorological forecasts and other urgent safety-related messages broadcast to ships.

Every ship, while at sea, shall be capable of receiving MSI (regulation IV/4) and search and rescue related information through the entire voyage in which the ship is engaged (regulation IV/7).

All ships transiting METAREA X and NAVAREA X, or navigating the Australian coast, should ensure they can receive all MSI necessary for the intended voyage.

Masters should ensure receivers capable of receiving MSI are configured appropriately for their intended voyage, including whilst in port. This may be confirmed by an Australian Maritime Safety Authority (AMSA) Port State Control Officer during a Port State Inspection

Receiving MSI

AMSA as Joint Rescue Coordination Centre (JRCC) Australia and the Australian Bureau of Meteorology (BoM) broadcast MSI through the International Enhanced Group Call service, using the International SafetyNET service (Inmarsat) and the International SafetyCast service (Iridium).

These services are supplemented by HF radiotelephone broadcasts (callsign: VIC).

Navigational warnings are made to NAVAREA X and coastal warning areas A to H.

Meteorological warning and forecasts are made to METAREA X, the high seas (North Eastern, South Eastern, Western, Northern and Southern) and coastal waters (Bass Strait, Torres Strait, Northern Territory, Western Australia and Northern Australia).

Further detail, the limits of these areas and broadcast times are provided on the:

• AMSA website Warnings current 

Australia does not provide a NAVTEX service.

International SafetyNET service

MSI broadcast for NAVAREA X and METAREA X, the high seas and coastal waters are available through the Pacific Ocean Region (POR) and Indian Ocean Region (IOR) satellites. MSI broadcast for coastal warning areas is only available through the POR satellite.

International SafetyCast service

MSI broadcast for NAVAREA X, METAREA X, the high seas and coastal warning areas is available via the Iridium SafetyCast service.

Australia's sanction laws

Sanction laws may, among other things, prohibit:

• the export or import of certain goods to or from certain countries, entities and individuals; and
• the provision of related services, including transport.

Offences arising under Australian sanction laws have extended geographical jurisdiction— category A status under the Criminal Code Act 1995 (the Criminal Code). This means the offences apply in a range of circumstances, including where conduct constituting an alleged offence occurs on board an Australian aircraft or an Australian ship, or by an Australian outside of Australia.

For these purposes, ‘Australian ship’ is defined by the Criminal Code to mean:

1. a ship registered, or required to be registered, under the Shipping Registration Act 1981; or
2. an unregistered ship that has Australian nationality; or
3. a defence ship.

Australian sanction laws implement two types of sanctions regimes—United Nations Security Council (UNSC) sanctions regimes and Australian autonomous sanctions regimes.

Sanctions regimes are amended regularly. Full and current details of UNSC and Australian autonomous sanctions are available on the Department of Foreign Affairs and Trade (DFAT) website at sanctions.dfat.gov.au

United Nations Security Council sanction regimes

UNSC sanctions regimes are implemented under the Charter of the United Nations Act 1945 (UN Act) and its regulations. As a United Nations Member State, Australia is obliged to implement UNSC sanctions regimes as a matter of international law.

UNSC sanctions regimes apply to:

• ISIL (Da’esh) and Al-Qaida
• Counter-Terrorism
• the Central African Republic
• the Democratic Republic of the Congo
• Guinea-Bissau
• Iraq
• Mali
• Lebanon
• Sudan
• South Sudan
• Somalia
• the Taliban
• Yemen.

Australian autonomous sanctions regimes

Australian autonomous sanctions regimes are implemented under the Autonomous Sanctions Act 2011 (AS Act) and its regulations. Australia implements autonomous sanctions regimes as a matter of Australian foreign policy.

Australian autonomous sanctions regimes may supplement UNSC sanctions regimes or be separate from them. Australia implements autonomous sanctions regimes in relation to:

• The Former Federal Republic of Yugoslavia
• Myanmar
• Syria
• Ukraine/Russia
• Zimbabwe.

Application of both sanction regimes

Australia implements both UNSC sanctions regimes and Australian autonomous sanctions regimes in relation to:

• Iran
• the Democratic People’s Republic of Korea (DPRK)
• Libya
• Syria.

Offences arising under Australian sanctions laws

Offences arising under Australian sanctions laws may apply to conduct that occurs on board an Australian ship, as well as conduct by Australians on foreign flagged vessels. It can be a criminal offence under both the UN Act and the AS Act for an individual or body corporate to:

• make a ‘sanctioned supply’ of ‘export sanctioned goods’ or a ‘sanctioned import’ of ‘import sanctioned goods’ without authorisation; or
• to provide the services of an Australian ship to assist with, or in relation to, a ‘sanctioned supply’ or a ‘sanctioned import’ without authorisation.

Punishment for individuals

As at 1 July 2020, these offences are punishable by:

• imprisonment for up to 10 years, or
• a fine of the greater of three times the value of the transaction/s, or
• 2,500 penalty units ($555,000).

Punishment for bodies corporate

As at 1 July 2020 these offences are punishable by:

• a fine of the greater of three times the value of the transaction/s, or
• 10,000 penalty units ($2.2 million).

For bodies corporate these are strict liability offences.

Further information

This document is explanatory only, does not have the force of law and does not in any way constitute legal advice. This document does not supplement or modify regulations made under the Charter of the United Nations Act 1945 or the Autonomous Sanctions Act 2011.

The Australian Government strongly recommends that those seeking to trade overseas consider obtaining legal advice in relation to Australian sanctions laws, as well as any other relevant Australian or foreign laws.

Australian Sanctions Office

The Australian Sanctions Office (ASO) within the Department of Foreign Affairs and Trade can provide further information on specific queries relating to Australian sanctions. To contact the ASO submit an enquiry through the contact us form via the Australian Sanctions Portal at pax.dfat.gov.au

Aviation and Maritime Security Transport Security Coordination Team

The Aviation and Maritime Security Transport Security Coordination Team accepts reports relating to transport security incidents.

1300 791 581 (Option 1)

+61 2 5127 8995 (from outside Australia)

transport.security@homeaffairs.gov.au

Background

Since November 2017 several pilots’ lives were placed at risk, in multiple separate incidents where a man rope parted, or its securing point failed. Additionally, AMSA received several incident reports on safety issues related to pilot transfer arrangements.

Ship owners, operators, masters and crews are reminded that pilot transfer arrangements, including pilot ladders, must comply with Marine Order 21 (Safety and emergency arrangements) 2016 (MO21) which sets out Australia’s obligations under the International Convention for the Safety of Life at Sea (SOLAS) Chapter V Regulation 23 (SOLAS V/23). 

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Pilot transfer arrangement standards

Whenever a pilot or other person embarks or disembarks from a ship by ladder, they entrust their safety to the pilot transfer arrangements provided by the ship and the pilot boat crew.

SOLAS V/23 sets out the minimum standards for pilot transfer arrangements on ships on or after 1 July 2012. The International Maritime Organisation (IMO) standards related to pilot transfer arrangements are found in:

• IMO Resolution A.1045(27) – Pilot transfer arrangements.
• IMO Resolution A.1108(29) – Amendments to the Recommendations on Pilot Transfer Arrangements (Resolution A.1045(27)). 
• MSC.1/Circ. 1428 – Pilot Transfer Arrangements – Required boarding arrangements for pilots
• MSC.1/Circ.1495/Rev.1. – Unified Interpretation of SOLAS Regulation V/23.3.3 on Pilot Transfer Arrangements 

SOLAS V/23.2.3 also states a pilot ladder shall be certified by the manufacturer as complying with SOLAS V/23 or “with an international standard acceptable to the Organization” and refers to ISO 799-1:2019 “Ships and marine technology – pilot ladders”.  Compliance with this particular provision of SOLAS V/23 can be met when a manufacturer has certified the pilot ladder complies with either of the IMO or ISO standards, noting they are not identical.

Where a pilot ladder has been certified under the ISO standard, AMSA expects that the ladder is strength tested according to the standard. Where this test has not been conducted within 30 months, the ladder should not be used until the test is conducted, or the ladder is replaced.

When purchasing a pilot ladder, care should be exercised that the product supplied actually meets the above requirements - relying on the manufacturer’s documentation may not be sufficient in some cases. If in doubt, the ship’s Recognised Organisation should be requested to confirm that the ladder meets the minimum standards.

Pilot transfer arrangements

IMO Circular MSC.1/Circ.1428 illustrates the pilot transfer arrangements required by SOLAS V/23.

When using a combination pilot ladder arrangement, the pilot ladder and accommodation ladder are required to be secured to the ship’s side. A common means of securing both the pilot ladder and accommodation ladders is with magnetic pads (refer to photo 1 below as an example).

Photo 1: Example of securing both the pilot ladder and accommodation ladders with magnetic pads (Reproduced with permission from Fremantle Ports).

Clear and efficient communication with the pilot boat master is essential to ensure the safety of the pilot transfer arrangements before a person uses the ladder. The pilot boat master is best positioned to judge correct height of the bottom of the ladder and identify any potential issues with the ladder or ropes once in place.

One common issue found is that the pilot ladder does not extend the required 2.0 m past the accommodation platform when a combination arrangement is used. Photo 2 illustrates an example of a pilot ladder not extending the required height past the platform.

Photo 2: Example of non-compliant combination pilot ladder arrangements.

As shown in photos 2 and 3 persons cannot climb the pilot ladder to a level where they can move safely onto the accommodation ladder. 

Photo 3: Person unable to safely access accommodation ladder platform from pilot ladder. 

Securing of Pilot Transfer Arrangements

The pilot ladder is normally secured at its thimble end with shackles. However, due to the varying freeboard at specific loading conditions, the pilot ladder cannot always be secured at full length by the thimble ends. Under such circumstances it must be secured at an intermediate length. That can only be done in a safe way by ensuring that the weight of the ladder is transferred from ladder’s side ropes to the approved strong point on deck directly.

The ladder’s steps, spreaders or chocks should not be used to carry the weight of the ladder as they are not designed for this and do not have sufficient strength. For this reason, shackles, bars and tongues should not be used to secure the ladder to the deck. They will damage the ladder and put weight on the parts which are not designed to carry the weight.

Photo 4 shows an example of an unsafe use of shackles to secure pilot ladders.

Photo 4: Unsafe pilot ladder securing arrangements (Reproduced with permission from Fremantle Ports).

Photo 5: Unsafe pilot ladder securing arrangements. 

Photos 5 shows the pilot ladder being secured to the strong point by using a shackle passed through the pilot ladder side ropes. This puts increased load on the single part of the side rope and the chock securing arrangements.

It is common industry practice to use a rope stopper usually in the form of a rolling hitch knot between the pilot ladder sides ropes and the approved strong point on the main deck. This will transfer the weight of the ladder arrangement directly onto the designated strong point and will not damage the ladder.

It is suggested that two strong (at least 2 x 24 kN) manila ropes be used to secure the pilot ladder. Photo 6 illustrates a method of tying a rolling hitch knot.

Photo 6: The rolling hitch knot. (Reproduced with permission from Fremantle Ports).    

Photo 7 provides an example of rolling hitch knots being used to secure pilot ladders to approved main deck strong points.

Photo 7: Rolling hitch knots being used to secure pilot ladders to approved main deck strong points (Reproduced with permission from Fremantle Ports). 

Inspection and Maintenance

Ongoing inspection and maintenance of pilot boarding arrangements are an essential part of ensuring their continued safe operation.

Paragraph 10.1 of Part A of the International Safety Management Code (ISM) requires ship operators establish procedures to ensure a ship is maintained in conformity with the relevant rules and regulations, including pilot transfer arrangements.

Such procedures should include regular inspections of the pilot transfer arrangements and storage to prevent damage of such equipment when not in use.

Photo 8: Pilot ladder where side ropes parted when in use (Reproduced with permission of the MAIB).

Common areas of defects can be the thimble ends of the pilot ladder. Corroded end point thimbles as illustrated in photo 9, can damage the side ropes leading to failure.

Photo 9: Example of corroded end point thimbles (Reproduced with permission from Fremantle Ports). 

Another common area is the frayed or damaged side ropes as illustrated in photo 10. These should be detected during routine visual inspections.  

Photo 10: Frayed side rope. 

If side ropes are frayed, or in any way degraded the ladder should not be used.

The man ropes which are used as part of the arrangements should also be regularly inspected. There have been two recent incidents of man ropes parting during transfer operations. Though rope type is not specified in SOLAS the Australasian Marine Pilots Institute recommends grade 1 manila be used. 

These should be tagged and included in onboard inspection and maintenance procedures. Good practice dictates these should be removed from service at the same intervals of not more than 30 months or sooner if required.

Trap door arrangements and use of combinations ladder  

There has been an increase in ships fitted with trapdoor arrangements. The additional requirement for their use is "the pilot ladder and man ropes shall be rigged through the trapdoor extending above the platform to the height of the handrail”.

Figure 1: Pilot card depicting trap door arrangements. 

If the pilot ladder and man ropes are not rigged through the trapdoor this creates an unsafe arrangement for persons as illustrated in photo 11.

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Photo 11: Unsafe trapdoor pilot transfer arrangement.

Responsibility for safe pilot transfer arrangements

Responsibility for safe practices for personnel transfers rests with each person involved in the activity including the ship owners, operators, master and crew, pilotage providers, pilots and pilot boat crew, as well as the person being transferred. All parties should observe both the spirit and intent of the regulations, to ensure safety is not compromised.

Where a person suspects that the pilot transfer arrangement provided is unsafe, they should refuse to use the arrangement until it is made safe by the master and crew and report the circumstances to AMSA and their employer. Where such situations occur, AMSA will endeavour to follow-up to determine the cause and actions taken. Where a ship is not calling into an Australian port, AMSA will follow up with the flag State.

When not in use, the pilot ladder and man ropes should be stowed appropriately to avoid exposure to contaminants or other elements that will degrade the ladder and man ropes. The ladder and man ropes should be regularly inspected by the ship’s crew to ensure they remain ready for use.

Additional information

The I... Pilot Ladder Poster provides further guidance on pilot transfer arrangements This and other useful guidance material are available on the AMSA website and in the AMSA Pilot mobile App. 

Implementation of standards

When conducting port State control (PSC) inspections, AMSA inspectors will pay particular attention to the material state of all equipment and the implementation of Marine Order 21, Res.A.1045(27) as amended by Res.A.1108(29), ISO 799-1:2019, MSC.1/Circ.1428 and MSC.1/Circ.1495/Rev.1. The relevant IMO circulars and resolutions can be obtained from AMSA or www.imo.org. 

During recent PSC inspections AMSA surveyors have noted pilot ladders which have been constructed with splices in the side ropes.

Photo 12: Example of non-compliant pilot ladder with splices in side ropes.

Pilot ladders constructed like this are considered non-compliant by AMSA. Ship operators and masters are recommended to check their pilot ladders for splices in the side ropes. It should be noted by operators coming to Australian ports that the availability of compliant pilot ladders is limited in Australia. To prevent avoidable delays operators are recommended to have spare compliant pilot transfer arrangements onboard.

Compliance with the referenced standards does not of itself assure safety in each case. A pilot transfer arrangement that complies with the standards but is incorrectly rigged still presents a hazard to anyone using the arrangement. Crew members assigned to rig a pilot transfer arrangement should be sufficiently familiar with the task. The master or responsible officer supervising the rigging of the pilot transfer arrangements should assess whether supplementary measures, such as lifejackets, harnesses, lifelines be made available to enhance the safety of personnel rigging the pilot transfer arrangement. Where a pilot transfer arrangement is rigged incorrectly, this may contribute to evidence that the master or crew are not familiar with essential shipboard procedures relating to the safety of the ship. A number of documents have been produced as referenced in this Marine Notice to assist in the rigging of a pilot transfer arrangement correctly.

AMSA has received reports of serious incidents, including fatalities, involving hatch covers on board ships. 

During inspections, AMSA continue to identify deficiencies in hatch covers, mostly as a result of lack of maintenance or improper operation. Some of these include unsafe securing – or no securing at all – of hatch covers, whilst the hatch covers are either partly or fully opened. The common finding in these situations is not following manufacturer’s instructions during operations. Additionally, defects pertaining to poor maintenance of hydraulic systems that are critical to hatch cover operation have also been identified. 

The International Safety Management Code (ISM Code) 

The ISM Code sets out safety objective requirements for safety management systems (SMS).  

On vessels fitted with hatch covers the SMS should include: 

• a risk assessment for opening and closing hatch covers and working in cargo holds;  
• instructions and procedures to ensure the safe operation of hatch covers and associated equipment; and 
• defined levels of authority and lines of communication between shipboard personnel when such operations are being undertaken. 

Training and instructions to seafarers 

Seafarers must be trained and provided with instructions for safe operations and maintenance of hatch covers. Training should include instruction in the correct operation of the specific type of hatch covers on the vessel; the risks posed by incorrect operation of the hatch covers; and maintenance of the hatch covers in accordance with manufacturers’ guidelines. 

Safe work practices should be always emphasized including: 

• Ensuring hatch covers are secured at all times, whether in an open or closed position, unless they are being operated; 
• Keeping personnel clear of moving or pressurized machinery; and  
• Safe working at height practices when working near an open hatch cover. 

Communication 

Communication among seafarers is important for safe hatch cover operation. Co-ordination between vessels’ crew and ensuring there is a culture onboard for crew to speak up when they see something unsafe, can help prevent these types of serious incidents.  

Reporting 

All incidents must be reported to AMSA at reports@amsa.gov.au. See AMSA’s website for more information on how to submit an incident report. 

Further reading 

Risk Focus: Hatch Covers (nautinst.org) 

Mick Kinley  

Chief Executive Officer  

18 February 2022