Pilot Transfer Arrangements: SOLAS V/23, MSC.572(110) & MSC.576(110) Guide

Pilot embarkation and disembarkation are among the most hazardous shipboard evolutions. A pilot transferring from a rolling, pitching pilot launch to a moving vessel at sea relies entirely on the structural integrity, geometry, and securing of the transfer arrangement. Under SOLAS Chapter V Regulation 23 (Pilot transfer arrangements), all ships on which pilots may be employed must provide approved arrangements that enable pilots and other personnel to embark and disembark safely in all seagoing conditions of draught and trim.

Historically, technical specifications were published in Assembly recommendations (primarily IMO Resolution A.1045(27), as amended by Resolution A.1108(29) and illustrated in MSC.1/Circ.1428). However, widespread non-compliance, defective trapdoor arrangements, uncertified securing clamps, and catastrophic falls prompted the Maritime Safety Committee to overhaul the regime. At its 110th session in June 2025, the IMO adopted two landmark binding instruments:

• IMO Resolution MSC.572(110): Completely replaces SOLAS Regulation V/23, making compliance with performance standards mandatory under the Convention. Existing ships must comply at the first survey on or after 1 January 2029 (new ships from 1 January 2028; non-Chapter I vessels by 1 January 2030). Resolutions A.1045(27) and A.1108(29) are formally revoked as of 1 April 2030.
• IMO Resolution MSC.576(110): Adopts the comprehensive Performance Standards for Pilot Transfer Arrangements (Parts A through F), establishing binding technical rules for design, manufacture, combination rigging, winch reels, onboard inspection, maintenance plans, 30/36-month retirement limits, and Administration type approval.
• Statutory Equipment Records: Amends the Record of Equipment for Passenger Ship Safety (Form P), Cargo Ship Safety (Form E and Form C), and 2008 SPS Code (Form SPS, Res. MSC.577(110)) to require surveyor verification of primary pilot ladders, spare ladders, manropes, and mechanical intermediate securing devices.
• Pilot Right of Refusal: Codifies in SOLAS V/23.12 that pilots suspecting non-compliance must inform the Master and refuse to board until the transfer arrangement is rectified.

A compliant pilot ladder is a purpose-built safety appliance designed to support vertical loads and withstand sea action without twisting, rolling, or shifting against the ship's hull:

Prohibition of Onboard Step Repairs: Under paragraph 28 of Resolution MSC.576(110), the repair or replacement of individual pilot ladder steps or spreader steps is strictly prohibited. If a step is cracked, chipped, broken, warped, or chemically contaminated, the entire ladder must be withdrawn from service and replaced by the ship's certified spare ladder.

Whenever the distance from sea level to the point of access exceeds 9.0 metres in the vessel's prevailing condition of draught and trim, a combination arrangement consisting of an accommodation ladder and a pilot ladder is legally mandatory:

The Trapdoor Platform Danger: One of the most prevalent causes of pilot fatalities has been poorly designed trapdoor arrangements where the pilot was forced to step backward or climb through an awkward, narrow hatch onto the accommodation ladder platform. Under MSC.576(110) § 5.5, a compliant trapdoor must provide a clear aperture of not less than 750 mm × 750 mm open to the ship's hull on the inboard side, the pilot ladder must extend continuously at least 2.0 metres above the lower platform, the trapdoor must open upward and secure flat against a stanchion, rigid round handholds (28–32 mm diameter, at least 1.2 m height) must be fitted, and the frame must be rated for vertical shock loads of at least 48 kN.

The interface between the head of the ladder and the ship's weather deck must provide clean, unencumbered passage supervised at all times by a designated responsible officer:

• Bulwark Ladders & Handhold Stanchions: Where deck access is via a bulwark ladder or gateway, two separate rigid handhold stanchions (diameter 32–36 mm) spaced 0.7 to 0.8 m apart must extend at least 1.2 m above the bulwark or deck threshold (MSC.576(110) § 8). Each stanchion must have an eye or ring (inner diameter >= 60 mm) to lead manropes.
• Strong Points & Securing Strength: All deck strong points, pad eyes, shackles, and securing ropes must have a certified breaking strength of not less than 48 kN (MSC.576(110) § 6.1). Dedicated securing ropes must be at least 3 m long and positioned >= 915 mm from the deck edge.
• Intermediate Securing Means: When a ladder is rigged at intermediate length, it must be secured to strong points using certified mechanical clamping devices or stopper ropes gripping both side ropes with >= 48 kN breaking strength (MSC.576(110) § 6.3). Securing ladders by step chocks alone or with loose shackles around steps is prohibited.
• Manropes: Two manropes (28–32 mm diameter, continuous knot-free mildew-resistant manila) must be rigged whenever requested by the pilot, led through stanchion eyes and secured to deck strong points.
• Safety & Rescue Gear at Access: A lifebuoy with self-igniting light and a clean heaving line capable of reaching the waterline in all conditions must be positioned immediately adjacent to the point of access and ready for immediate deployment.
• Night Illumination: Adequate fixed or portable lighting must illuminate the entire overside transfer arrangement and the deck embarkation position (SOLAS V/23.11). Portable floodlights must be mounted in secure brackets, never hand-held by crew.
• Officer Supervision & Bridge Communications: Embarkation and disembarkation must be supervised directly by a licensed deck officer equipped with two-way radio communication to the navigation bridge, who must escort the pilot along a safe, illuminated route to the wheelhouse.

Port State Control authorities (Paris MoU, Tokyo MOU, USCG, AMSA) inspect pilot transfer arrangements as high-priority safety items under deficiency code 11117 / 15150. A single defective step, seized shackle, or uncertified ladder will result in boarding refusal and detention:

• Mandatory Shipboard Maintenance Plan: Under MSC.576(110) § 27, every ship must maintain a dedicated pilot transfer maintenance plan containing checklists, manufacturer stowage/care instructions, inspection schedules, spare parts sources, and a formal log recording when each ladder and manrope set entered service and its scheduled 30/36-month retirement date.
• Pre- and Post-Use Inspections: A licensed officer must conduct a thorough visual check before each rigging and immediately after disembarkation, verifying step horizontality, side rope seizings, thimbles, and stanchion locking pins.
• Quarterly Formal Inspections: A comprehensive inspection of all ladders, winch reels, securing strong points, accommodation ladder running wire, and spare gear must be executed and logged every three (3) months.
• Top Deficiency 1 — Dirty or Painted Steps: Hardwood steps must never be coated with paint, varnish, or preservative oils that conceal cracks or reduce non-slip friction.
• Top Deficiency 2 — Pilot Ladder Tied to Lower Platform: Securing side ropes to the accommodation ladder platform rather than the ship's hull pad eyes remains the most frequent combination arrangement detention finding.
• Top Deficiency 3 — Missing Spreader Steps: Spreaders missing, unevenly spaced, or replaced by improvised wood blocks violate SOLAS V/23.3 and require immediate replacement.
• Top Deficiency 4 — Absence of Certified Spare Ladder: Failing to carry a full compliant spare ladder and spare manropes violates Resolution MSC.576(110) § 29 and will be cited against the ship's safety equipment certificate.