Pilot ladder and pilot transfer safety

The ladder does not fail in a spectacular way. It fails quietly, over many uses, until the day someone trusts it.

Introduction

Pilot transfer is the first physical act of port entry. It happens before the pilot has spoken a word on the bridge, before the passage plan is reviewed, before any of the familiar rituals of inbound pilotage begin. It is also, consistently, one of the most dangerous routine operations carried out on a merchant vessel.

IMPA’s annual pilot transfer safety campaigns have documented falls, fatalities, and near-misses with a regularity that should have produced change long before now. The equipment is simple. The regulations are clear. The failures are not technical mysteries — they are the product of familiarity, delegation, and the assumption that a ladder rigged last month is still fit for use today.

What follows is not a checklist. It is an account of what the regulations actually require in operational terms, what correct rigging looks like in practice, where the gaps between paper compliance and physical reality consistently appear, and why the master cannot treat this as a bosun’s task with a signature attached.

Contents

• 1. The Regulatory Framework in Operational Terms
• 2. What the Ladder Must Actually Be
• 3. The Rigging Configuration: What Is Required and Why
• 4. The Combination Arrangement — and Where It Routinely Goes Wrong
• 5. The Pilot Hoist Exclusion
• 6. What a Correctly Rigged Ladder Looks Like
• 7. Lighting, Embarkation Area, and Night Operations
• 8. Command Responsibility and the Limits of Delegation
• 9. The Fatality Record
• Closing Reality

1. The Regulatory Framework in Operational Terms

SOLAS regulation V/23 is the primary instrument. It mandates that every ship to which SOLAS applies shall provide, for pilot transfer, equipment meeting the requirements of the regulation and maintained in good order. IMO Resolution A.1045(27), adopted in 2011 and superseding A.889(21), provides the detailed technical specifications that give V/23 its operational meaning.

A.1045(27) is not aspirational guidance. Its requirements carry the force of the SOLAS obligation.

The regulation applies to the transfer of pilots. It does not apply only in certain sea areas, only when a PSC inspector might be watching, or only when the pilot boat crew appears to be paying attention. It applies every time a pilot boards or leaves the vessel, regardless of port familiarity, regardless of weather, regardless of how many times this particular ship has used this particular berth without incident.

Flag states implement V/23 through their own statutory instruments, but the substantive requirements derive from A.1045(27). A ship that fails to comply is in breach of SOLAS. The master is accountable. The company is accountable. The fact that the same ladder has been used thirty times without complaint does not create a defence.

2. What the Ladder Must Actually Be

The pilot ladder must be a purpose-built pilot ladder. Not an accommodation ladder. Not a gangway. Not a combination of whatever is at hand.

Steps must be made of hardwood or other material of equivalent properties — non-deformable, non-slip, and of uniform length not less than 480 mm. The width between side ropes must be not less than 400 mm. Step spacing must be uniform, between 310 mm and 350 mm apart.

The side ropes must be of two continuous lengths of manila or equivalent material not less than 18 mm in diameter. Synthetic material is permitted provided it meets equivalent strength and grip characteristics. The side ropes must be continuous — no joints below the top four steps.

Steps must be secured so they cannot be displaced or rotate. The securing method matters. A step that can twist under load is a step that will displace under a dynamic load — exactly the condition encountered when a pilot transfers in any sea state above flat calm.

The ladder must be long enough to reach the waterline from the point of embarkation under all conditions of loading and trim. This is not a nominal calculation based on summer draft. It means the ladder must be long enough for the deepest anticipated freeboard on that ship, on that passage, at that port. A ladder that falls short of the water forces the pilot to make a dynamic transfer from the pilot boat at height — a fall waiting for its moment.

3. The Rigging Configuration: What Is Required and Why

The ladder must be rigged on the side of the vessel that offers the most shelter from wind and sea, unless the pilot or pilot boat specifically requests otherwise. This is a seamanship requirement dressed as a regulatory one. A pilot transferring into a fresh wind on the exposed side of a vessel moving at reduced speed through a swell is working at the limit of what is physically manageable.

Manropes are required when the freeboard exceeds 9 metres. Two manropes, not less than 28 mm in diameter, must be provided, secured to a strong point on deck — not to a rail stanchion, not to a cleat, not to anything that might carry the load momentarily before failing. Strong point means a properly designed deck fitting capable of sustaining the dynamic load of a person falling.

Spreaders are required to prevent the ladder from twisting into the ship’s side. A.1045(27) requires spreaders at intervals of not more than 9 steps, with the lowest spreader on the fifth step from the bottom and the highest not more than 9 steps from the top. Spreaders keep the ladder tracking plumb. Without them, the ladder wraps the hull in any sea, trapping fingers and feet and making an orderly descent or ascent physically impossible.

The securing arrangement must allow the ladder to be moved rapidly to a different position along the ship’s side if required. A ladder seized to a rail with multiple lashings that take twenty minutes to shift is not compliant — not because the regulation specifies a time, but because the operational requirement for repositioning is genuine and must be met in practice.

Securing to a strong point is not a detail. It is the load-bearing element of the entire arrangement. Every other component of the rigging is irrelevant if the securing point fails.

4. The Combination Arrangement — and Where It Routinely Goes Wrong

When the freeboard exceeds 9 metres, an accommodation ladder is often used in combination with the pilot ladder to reduce the vertical climb. A.1045(27) specifies exactly how this combination must be configured, and the deviations from this specification are among the most common failures documented in incident reports.

The pilot ladder must extend above the platform of the accommodation ladder by at least 2 metres. Not to the platform edge. At least 2 metres above it. This ensures the pilot has a continuous handhold during the transition from ladder to platform. A pilot stepping from a moving pilot boat onto an accommodation ladder platform without this upper extension has nothing to grip during the most unstable part of the transfer.

The accommodation ladder must be topped at the outboard end with a platform rigged horizontally, not at an angle. A sloped platform in any sea state becomes a slope plus dynamic motion. The combination is a fall risk that has been documented in fatalities.

The bottom of the accommodation ladder must not be more than 1.5 metres above the waterline — again, referenced to conditions of loading and trim, not light ship.

What is routinely seen in practice: accommodation ladders with the pilot ladder barely reaching the platform level, platforms rigged at angle because the ladder’s own angle was not adjusted for the vessel’s current draft, pilot ladders lashed to the accommodation ladder rather than to an independent strong point, and combination arrangements where the components are simply adjacent rather than integrated in the manner the regulation requires.

Adjacent is not integrated. The distinction matters when someone falls.

5. The Pilot Hoist Exclusion

A.1045(27) permits pilot hoists as an alternative to the pilot ladder under specific conditions, and many flag state implementations reflect this. The hoist must meet the mechanical and structural requirements of the resolution, must be tested and maintained, and must be operated by a trained crew member.

The critical provision: even where a pilot hoist is used, a pilot ladder rigged to reach the waterline must be available as a backup. The hoist does not replace the ladder requirement — it supplements it.

In practice, the pilot hoist is the arrangement most subject to maintenance neglect, because it is used infrequently and its mechanical condition is not visible in the way a deteriorating ladder step is visible. A hoist that has not been operationally tested under load is an unknown quantity. Discovering this during an actual transfer is not an acceptable test methodology.

6. What a Correctly Rigged Ladder Looks Like

A correctly rigged pilot ladder reaches the water. It hangs plumb, or as close to plumb as the ship’s side geometry allows, without wrapping the hull or swinging free. The steps are uniform, horizontal, clean, and not worn through repeated use to a surface that offers no grip. The spreaders are present at the correct intervals. The manropes, where required, are in place and separately secured, not tied to the ladder’s own side ropes.

The securing point is a ship’s fitting designed for the purpose, visually inspected before use, with the securing method such that the load path is clear and unambiguous. The crew member stationed at the ladder can see the pilot boat, communicate with the bridge, and assist — not merely observe.

Lighting illuminates the ladder, the ship’s side below it, and the water at its foot. Not a torch. Not the spill from a deckhead fitting thirty metres away. Dedicated lighting that makes the full length of the ladder visible from the pilot boat and from the embarkation point on deck.

What is often rigged instead: a ladder that stops two feet above the water at the pilot boat’s deck level in present conditions, potentially reaching nothing at all in a different loading condition. Steps worn smooth. No spreaders below the fifth step because the lower section was replaced and the crew assumed the remaining spreaders were sufficient. Manropes tied to the ladder stanchion. A securing point that is a rail, not a fitting.

The ladder does not announce its deficiencies. It presents as a ladder.

7. Lighting, Embarkation Area, and Night Operations

SOLAS V/23 requires that when a pilot boards or leaves at night, the ship’s side be illuminated at the point of transfer. A.1045(27) is more specific: the illumination must cover the ladder and the ship’s side adjacent to it, sufficient to allow the pilot and crew to see clearly during the transfer.

Night pilotage is not an exceptional circumstance. In many ports, the majority of pilot boardings occur before dawn or after dusk. The lighting requirement is not a supplementary precaution for unusual conditions — it is a baseline operational requirement for roughly half of all transfers.

The embarkation area on deck must be clear. This means clear of stores, ropes, hatch coamings, mooring equipment, and any other obstruction that would prevent a person arriving at speed from a ladder from gaining safe footing. A pilot who has just made a difficult transfer in a swell and steps onto a deck obstructed with mooring rope tails or unsecured equipment has simply moved the point of failure from the ladder to the deck.

A lifebuoy with a self-activating light and a heaving line must be at the embarkation station and immediately ready for use. Not in a locker near the station. Not attached to a fitting that requires a tool to release. Immediately ready.

The crew member at the embarkation deck is not a formality. That person must be capable of assisting a transfer, operating the lighting, and deploying the lifebuoy. A single junior crew member stationed there for compliance optics serves no operational purpose.

8. Command Responsibility and the Limits of Delegation

The rigging of the pilot ladder is understood on most vessels as a bosun’s task. The bosun is experienced. The bosun knows what a pilot ladder should look like. The bosun signs the checklist.

None of that transfers responsibility.

SOLAS V/23 places the obligation on the ship — which means on the master. The master cannot discharge that obligation by delegating inspection to the bosun and treating the completed checklist as proof of compliance. The checklist documents what the bosun found. It does not establish the master’s independent knowledge of the ladder’s condition.

The master should inspect the pilot ladder before use. Not every voyage, not in every port — operational tempo makes that impractical. But regularly enough to have direct knowledge of the equipment’s condition, and certainly when there has been any reason to doubt it: after heavy weather, after extended time in port, after any change to the vessel’s loading condition that alters the freeboard and therefore the required ladder length.

The OOW responsible for coordinating the pilot transfer has a direct role here. Confirming with the bosun that the ladder is ready is not sufficient. Confirming that the ladder is correctly rigged for the present freeboard, that the embarkation area is clear, that the lighting is operational, and that the stationed crew member is qualified and briefed — this is what the OOW’s coordination role actually requires.

When a pilot falls, the investigation will not stop at the bosun. It will reach the master. It will reach the company’s safety management system. It will examine whether the SMS required ladder inspections, whether those inspections were carried out, and whether the bridge team exercised any independent verification. A completed checklist that cannot be corroborated by anyone who actually looked at the ladder is not a defence. It is evidence of a system that was performing compliance theatre.

9. The Fatality Record

IMPA’s pilot transfer safety campaign has tracked incidents annually for over a decade. The pattern is consistent. Pilots die during transfer. Crew members assisting with transfer die. The causes repeat: ladders that do not reach the water, steps that are worn or broken, securing arrangements that fail under load, combination arrangements rigged incorrectly, embarkation areas obstructed, lighting absent or inadequate.

These are not freak accidents. They are foreseeable outcomes of known deficiencies.

The fatality rate for pilots during transfer operations is higher than the fatality rate for most other routine maritime operations. Piloting is a skilled profession conducted in conditions of genuine physical risk, and a significant proportion of that risk is created not by sea conditions or vessel manoeuvring, but by the state of the equipment the pilot must use to board the ship in the first place.

IMPA’s reporting also documents near-misses and equipment failures that did not result in injury. The distribution of these failures shows no particular flag of registry, no particular vessel type, no particular trade route. They appear across the fleet, on vessels with full ISM documentation, on vessels that passed their last PSC inspection, on vessels whose masters have decades of experience.

Familiarity is the common factor. The ladder has always been fine. The bosun knows what he is doing. We have never had a problem here.

That confidence is the condition in which the next fatality is being prepared.

Closing Reality

A pilot ladder is a length of rope and wood that a person’s life depends on for approximately ninety seconds. SOLAS V/23 and A.1045(27) specify precisely what that rope and wood must be, how they must be configured, and what must surround them. The requirements are not complicated. They are not expensive. They are not technically demanding.

The gap is not knowledge. The gap is attention.

The ladder deteriorates between inspections. The freeboard changes with the load. The securing point that was adequate when the ship left the yard is now a rail fitting someone substituted years ago and no one questioned. The checklist says ready. The bosun is confident. The pilot is already on the pilot boat.

The master’s name is on the vessel’s command. The pilot’s life is on the ladder. These two facts are directly connected, and no intermediate layer of delegation, documentation, or checklist compliance changes that connection.

Inspect the ladder. Know its condition. Rig it correctly. Every time.