Text & photos by Arie Palmers.
Recently I was involved in a case with a non-compliant and therefore dangerous pilot transfer arrangement on a bulk carrier heading to Vlissingen anchorage for partial discharging. The vessel was a standard 229m bulker with an arrival draft of 14,8m. At the 17th of August around 2324lt the first pilot boarded the vessel at Wandelaar pilot station via the Swath-pilot vessel. The ladder that had been rigged, was not used because the servicing pilot had been put on board via the retractable gangway of this swath and therefore was able to step directly onto the deck of the vessel. The agent asked me for an English explanation on why this ladder would not be safe. I considered it interesting enough as for educational purposes, to extend my reply a bit and post it online.
Recently I was involved in a case with a non-compliant and therefore dangerous pilot transfer arrangement on a bulk carrier heading to Vlissingen anchorage for partial discharging. The vessel was a standard 229m bulker with an arrival draft of 14,8m. At the 17th of August around 2324lt the first pilot boarded the vessel at Wandelaar pilot station via the Swath-pilot vessel. The ladder that had been rigged, was not used because the servicing pilot had been put on board via the retractable gangway of this swath and therefore was able to step directly onto the deck of the vessel. The agent asked me for an English explanation on why this ladder would not be safe. I considered it interesting enough as for educational purposes, to extend my reply a bit and post it online.
At 0219lt of the next morning (18th of August) the vessel arrived at Flushing roads to change the pilot. During this procedure it was established that the ladder did not meet international standards, regulations and requirements and was therefore not safe to use in accordance with SOLAS ch. V reg. 23 rule 2.1. And 3.1. The non-compliances that were noticed at that time are:
- All wooden steps were loose. (pictures and videos were made). No inspection or maintenance had been carried out in accordance with ISO799-2:2019 ANNEX A. Question: is pilot ladder maintenance and inspection implemented in the SMS system as required?
- All wooden steps were varnished which is not in accordance with IMO A.1045 rule 2.1.2.4, ISO799-1:2019 rule 4.1 and is also mentioned in the well known pilot ladder poster issued by IMPA in cooperation with the IMO (slippery and therefore a tripping hazard).
- No identification tag under the bottom spreader as per regulations ISO799-1:2019 rule 8.1
- Ropes seizings not as per regulations mentioned in ISO799-1:2019 rule 4.7
- Spreaders are not of a one piece construction as per ISO799-1:2019 rule 5.14
The most hazardous topic in this specific ladder was the fact that all steps were loose, in combination with the fact that those steps were also varnished. Steps will tilt when weight is put on them, the varnish will cause a slipping/tripping hazard. Last year 8 people, of which I know, have been killed attempting to board a vessel.
During the attempted transfer, a picture of the pilot ladder certificate was asked at 0223 and received at 0239. According to the provided certificate it appeared that the ladder had been built in December of 2020. A ladder needs to undergo a strength test or to be replaced after 30 months as per ISO799- 1:2019 rule 10.4. Later it became clear that the provided certificate did not match with the presented ladder. This could not be checked at that time because there was no identification tag under the bottom spreader as per above mentioned regulation (that is the reason a tag must be placed under the bottom spreader). The certificates belonging to the used pilot ladder were never presented.
The combination of the above mentioned deficiencies combined with the provided certificate led to an initial rejection to use this ladder to board the vessel. At 0515 the Dutch Swath pilot launch was called away from Steenbank pilot station to Flushing roads (25’) to provide the pilot with access to the vessel without having to use the pilot ladder. During this time the agent had been informed to deliver new ladders to the vessel that would match international law. Unfortunately the agent did not answer the phone at that time so a voicemail message was sent by the chief pilot in the Scheldt Coordination Centre.
Upon boarding at 0515 the pilot (me) informed the captain on the deficiencies that were observed and that a new ladder was required to provide safe access. Images and videos were shown to the captain and a video was shared with the captain on an iphone.
Meanwhile the crew was busy to try and solve the problem of the loose steps. Upon arrival of the agent, he was told new ladders were to be provided. He told me the ladder was only one year old which I later could check by having a look at the tag that was only present under the top step of the ladder.
Meanwhile the crew was busy to try and solve the problem of the loose steps. Upon arrival of the agent, he was told new ladders were to be provided. He told me the ladder was only one year old which I later could check by having a look at the tag that was only present under the top step of the ladder.
Despite the fact that the ladder was only one year old, it was in a deplorable condition. The deck crew had been busy with the ladder for several hours. I could not check if the required repair rope had been used (three-ply tarred Marline of a minimum breaking strength of 800N and with a minimum diameter of 4mm or other suitable material of equivalent strength and diameter as per ISO799-1:2019 rule 4.7). After these repairs, several people boarded and left the vessel again via this ladder. I therefore deemed it safe enough to conduct a pilot change in sheltered waters with the vessel not making way through the water (my bad). Once I was on the pilot ladder to disembark, which I was not able to test with my weight on it before that time, I noticed the steps were still loose.
Port state control has been informed about the situation and has asked the agent to provide new ladders. For your information: I asked a reputable manufacturer for an appraisal on a ladder with a length of 14m and 43 steps and the costs of that will be: 965,- ex. VAT. It is possible to a ladder directly from various manufacturers in the region.
The class of the presented ladder has been asked why this product had been certified by them due to bad seizings and varnish etc. and they are investigating this case.
Should you want to obtain more information regarding pilot ladders, I would like to point out the website www.pilotladdersafety.com to you. It has a lot of information on ladders and also good instructions that can be used in toolbox meetings. My personal Linkedin page can also be used as reference for more information on pilotladders. I am always willing to assist the company in safety on this topic, as I have done for many other companies, pilot-associations and NGO’s.
As we speak, the workgroup I am a part of is finishing the process of writing new and clear regulations on ladders, that will pass the IMO MSC this December. The same goes for the pilotladder poster that has been fully revised and redesigned.
Finally, the vessel has no blame for having a ladder onboard that is not constructed as per international regulations: vessel orders a ladder, a ladder is delivered and the crew should be able to rely on the fact that a proper piece of equipment had been purchased, but unfortunately a substandard quality ladder was delivered. The vessel is however responsible for maintenance to be carried out on the ladder, especially when the ladder is constructed with whippings that will loosen over time. Purchasing a ladder where clamps are used, erases that problem. Equipment like pilot ladders, need to be in the vessel’s SMS system so it is assured that proper maintenance and care will be executed. ISO799 provides you with the correct tools to do so. Also some manufacturers attach a maintenance record booklet to every ladder they supply which is a very good basis to implement it in the SMS system, it will definitely save lives when done the proper way.
I’ll end this article with some questions and remarks that are running through my mind and are of course open for discussion:
Port state control has been informed about the situation and has asked the agent to provide new ladders. For your information: I asked a reputable manufacturer for an appraisal on a ladder with a length of 14m and 43 steps and the costs of that will be: 965,- ex. VAT. It is possible to a ladder directly from various manufacturers in the region.
The class of the presented ladder has been asked why this product had been certified by them due to bad seizings and varnish etc. and they are investigating this case.
Should you want to obtain more information regarding pilot ladders, I would like to point out the website www.pilotladdersafety.com to you. It has a lot of information on ladders and also good instructions that can be used in toolbox meetings. My personal Linkedin page can also be used as reference for more information on pilotladders. I am always willing to assist the company in safety on this topic, as I have done for many other companies, pilot-associations and NGO’s.
As we speak, the workgroup I am a part of is finishing the process of writing new and clear regulations on ladders, that will pass the IMO MSC this December. The same goes for the pilotladder poster that has been fully revised and redesigned.
Finally, the vessel has no blame for having a ladder onboard that is not constructed as per international regulations: vessel orders a ladder, a ladder is delivered and the crew should be able to rely on the fact that a proper piece of equipment had been purchased, but unfortunately a substandard quality ladder was delivered. The vessel is however responsible for maintenance to be carried out on the ladder, especially when the ladder is constructed with whippings that will loosen over time. Purchasing a ladder where clamps are used, erases that problem. Equipment like pilot ladders, need to be in the vessel’s SMS system so it is assured that proper maintenance and care will be executed. ISO799 provides you with the correct tools to do so. Also some manufacturers attach a maintenance record booklet to every ladder they supply which is a very good basis to implement it in the SMS system, it will definitely save lives when done the proper way.
I’ll end this article with some questions and remarks that are running through my mind and are of course open for discussion:
- Why did the pilots in de the port of departure consider this arrangement up to standards? Am I being picky? Why do pilots keep accepting below standard ladders?
- Why did a class association, connected to IACS, approve a ladder, that presumably was built under ISO799 standards. We can all see this ladder was way below any acceptable standard.
- Why doesn’t the manufacturer reply to several emails I’ve sent them: I always like to hear the other side of the story.
- Who is checking the quality of the certifying bodies?
- Why would an agent refuse to provide a new ladder (965,- remember)?
- I really appreciate the perfect cooperation with Port State Control.
- Why does the flag state approve these practices?
- Who checks SMS on every vessel?
Kind regards,
Arie Palmers AFNI
Maritime pilot/ CHIRP-ambassador
Arie Palmers AFNI
Maritime pilot/ CHIRP-ambassador
