Embarkation / Disembarkation means under PSC scrutiny

Failures in these arrangements can lead to serious injuries, fatalities, operational delays, detentions and reputational damage. For this reason, Port State Control (PSC) authorities worldwide continue to pay close attention to embarkation and disembarkation means during inspections.

Table 1: Key PSC findings of Embarkation / Disembarkation means during the last 36 months

PSC figures (Table 1) confirm that access equipment is not only a routine maintenance matter, but a critical safety issue directly linked to the prevention of accidents. The data also demonstrates that deficiencies affecting safe access arrangements continue to generate detainable conditions across multiple inspection regimes.

Recurring deficiencies identified during inspections

Several PSC inspection reports over the period illustrate the nature of recurring problems identified onboard cargo vessels.

Common findings include:

• damaged or wasted accommodation ladders
• cracked gangway welds
• missing securing bolts
• deteriorated handrails
• defective pilot ladder steps
• damaged man ropes
• improperly secured pilot ladders
• inadequate embarkation lighting

Particularly concerning are cases where PSC officers identified severe structural deterioration or unsafe operating conditions. Examples include gangways with significant cracks at turning platform connection points, pilot ladder ropes showing signs of dry rot, and pilot ladder winch reels missing brakes or locking arrangements.

In several cases, vessels were unable to provide valid pilot ladder certificates or evidence of compliance with testing intervals. Other deficiencies revealed poor operational practices, including safety nets rigged incorrectly, stanchions not secured with safety pins, and pilot ladders attached to non-approved strong points.

From maintenance issue to serious safety hazard

Such deficiencies expose both seafarers and shore personnel to significant risk. Pilot transfer operations are especially sensitive because they frequently take place in adverse weather conditions, darkness or congested traffic areas.

A single failure involving a ladder step, side rope or securing arrangement can result in a fall from height directly into the sea or onto the ship’s side structure. Similarly, defective gangways and accommodation ladders may cause injuries during cargo operations or crew changes, particularly where corrosion, poor maintenance or improper rigging practices are present.

Beyond the immediate safety implications, such incidents may also lead to operational disruption, vessel detention, commercial impact and reputational damage for operators.

New IMO requirements expected to intensify PSC focus

The importance of this issue is expected to increase further with the implementation of IMO Resolution MSC.576(110), which introduces more stringent requirements related to pilot transfer arrangements and associated equipment.

The amendments strengthen expectations regarding:

• design standards
• maintenance
• inspection routines
• marking and identification
• operational readiness
• equipment traceability

PSC officers are expected to apply closer scrutiny to compliance documentation, equipment condition and crew familiarity with proper rigging procedures. Under the forthcoming requirements, ship operators will need to demonstrate not only that equipment is certified, but also that it is properly maintained, traceable and fit for safe operational use at all times.

Particular attention is likely to be given to:

• pilot ladder identification and certification
• replacement intervals
• maintenance records
• winch operational condition
• securing arrangements
• compatibility between pilot ladders and accommodation ladders used in combination arrangements

Practical compliance expectations onboard

In addition to IMO requirements, practical compliance and operational readiness will become increasingly important during PSC inspections.

PSC officers are expected to verify:

• the physical condition of embarkation equipment
• evidence of maintenance and inspection routines
• testing intervals and records
• correct rigging arrangements
• proper securing points
• operational condition of winches and brakes
• availability and condition of safety nets
• adequate lighting arrangements
• crew familiarity with rigging and transfer procedures

Increasing emphasis is also expected on equipment traceability, including serial numbers, certification records and replacement history for pilot ladders and associated equipment.

Best practices to reduce PSC exposure

The following actions are strongly recommended to reduce PSC findings related to embarkation and disembarkation arrangements:

Inspection and maintenance

• Conduct frequent inspections of gangways, accommodation ladders and pilot ladders, with particular attention to corrosion, cracks, wastage, loose fittings and damaged welds.
• Verify that all pilot ladder steps, spreaders, side ropes and man ropes remain in good condition and free from wear, dry rot or deformation.
• Test gangway and accommodation ladder winches regularly, including brakes, locking devices and emergency stopping arrangements.
• Include embarkation and disembarkation arrangements within planned maintenance systems and defect reporting procedures.

Documentation and traceability

• Ensure pilot ladders are correctly marked, certified and traceable to onboard records.
• Verify that service records correspond with serial numbers and identification plates.
• Confirm that pilot ladders remain within required testing and replacement intervals.

Operational readiness

• Verify that all stanchions, handrails and securing pins are properly fitted and effectively secured before use.
• Ensure safety nets are rigged correctly beneath gangways and accommodation ladders in accordance with regulations and company procedures.
• Maintain adequate lighting at embarkation and disembarkation stations during hours of darkness.
• Verify that pilot ladders are secured only to approved strong points and rigged in accordance with SOLAS requirements and IMO guidance.

Crew training and familiarization

• Conduct regular crew training and familiarization regarding proper rigging, inspection and operational checks for pilot transfer arrangements.
• Encourage senior officers to perform pre-arrival checks before pilot boarding operations and PSC inspections.

Early implementation of new IMO requirements

• Arrange the early implementation of IMO Resolution MSC.576(110) within Safety Management System (SMS) procedures.

Conclusion

PSC statistics clearly show that deficiencies related to embarkation and disembarkation means and procedures continue to occur at high levels throughout the industry.

Beyond the risk of detention or commercial impact, unsafe embarkation and disembarkation arrangements present a direct threat to human life.

As IMO requirements become more demanding under MSC.576(110), ship operators must ensure that maintenance standards, crew awareness and inspection practices evolve accordingly.

Well-maintained, fully compliant and properly operated access arrangements will not only reduce PSC exposure, but most importantly help protect the lives of everyone required to board or leave a vessel.