RightShip Pilot Ladder Webinar Q+A | Rightship

Questions Regarding Brand or Supplier:

• Has the Industry identified the suppliers providing substandard ladders?
• In the presentation I see quite a few substandard, low-quality ladders. It all starts with a good ladder. 
• What are your thoughts on this matter, and do you have a favorite brand?
• Who are suppliers of quality pilot ladders?
• Which are the brands that do not follow SOLAS standards, per your experience?

RightShip’s Answer:

There are a lot of good suppliers out there. However, RightShip cannot endorse a specific supplier over others for obvious reasons. 

What we suggest is that as a vessel’s operator, you must do your due diligence when choosing a preferred supplier. While ISO 9001:2015 does not require suppliers’ audits, it calls for supplier evaluation and approval. You may wish (as a ship operator) to include auditing your suppliers as part of your evaluation and approval. 

 

Questions Regarding Incidents:

• Despite the IMO requirements to flag states to report the incidents, why aren’t the pilot transfer arrangements accidents reported to be used for studies and lesson learned? How can this be improved?
• Are there any recent incidents involving pilot ladder arrangements? 

RightShip’s Answer:

A). RightShip has always (and continues to) encourage industry stakeholders to proactively report all incidents. Not only those related to pilot transfer arrangements. 

B). Yes, there are recent fatalities involving pilot ladders as of this year. As the incidents are still under investigation and all details are not yet available, we did not include those in the insights paper and presentation, but rather chose case studies that have been concluded.

 

Questions Regarding Ladder Construction:

• Are both mechanical crimping and manual whipping acceptable? If so, which is the most preferred?
• Does Rightship accept mechanical clamped chocks?
• From photos we can see some wood steps broken but still being used. As I know some FPSO companies are using new metal to cover wooden plates, can the same be used on pilot ladder?
• There have been some cases where the pilot ladder supplied with required documents had varnished steps. Are these steps considered a slipping hazard?
• lashings on the ladder
• On sketch no 14 - the combination ladder is original fitted from building shipyard – it is wrong and can’t be rectified on board?
• Please highlight that surface of steps should not be slippery, however crews add some anti-skid 3M tape. Is that a good idea? If yes, why doesn’t the supplier make them this way and why is it only considered a best practice?
• Since the metallic clamping was introduced, ropes are getting damaged due to the sharp edges of the clamping. Has this been pointed out to the makers? Because the fingers are still being pointed at crew and operators.
• Thoughts on the so called '8-shaped' clamps?
• What are the acceptable terminations of the pilot ladder below the rubber steps? AMSA was approached, as they have specific requirements, and were unable to provide a relevant answer.
• What is the type of ropes you can recommend when requisitioning a pilot ladder?
• Where should the side rope end (loop back and spliced on top, crossed below the bottom step and spliced on top or open below the bottom step and whipped)?

RightShip’s Answer:

A). Regarding Mechanical crimping and manual seizing: RightShip is neither a certifying body nor are in a position to accept or reject methods of pilot ladders chocks and steps installation. 

That said, RightShip recommends the industry to refer to the Nautical Institute MARS (Mariners' Alerting and Reporting Scheme notice number 17 for the year 2023.  This MARS report highlights the cons associated with mechanical crimping that cause the ladder to sustain sever damages ONLY 6 months after being in use.  RightShip recommends those vessels with such arrangements to increase the frequency of their onboard inspections and verifications taking into consideration that the inspection should focus on the rope’s conditions under/around the mechanical crimping. That said, IMO Res A. 1045(27) 2.2.3 stipulates that the preferred method is seizing. 

B). Regarding the metal covers for pilot ladder wooden steps, and wooden varnish, Anti-Skid 3M tape, side ropes, ropes material: RightShip recommends the industry to consult IMO Res.A.1045(27), US 46 CFR 163, as well as: 

• ISO 799-1:2019 Ships and marine technology – Pilot ladders – Part 1: Design and specification.
• ISO 799-2: 2021 Ships and marine technology – Pilot ladders – Part 2: Maintenance, use, survey, and inspection.
• ISO 799-3:2022 Ships and marine technology – Pilot ladders – Part 3: Attachments and associated equipment.

All these questions are answered within ISO799-1:2019. See below examples:

• The Wooden Parts (Steps):
  “Each wooden part shall be made of hardwood (ash, oak, beech, teak, and other hardwood having equivalent properties) free from knots. Wood shall not be treated or coated with paint, varnish or other coatings, which either change the friction coefficient or hide the natural grain.”
• Side Ropes:
  “Each side rope shall be mildew-resistant manila rope meeting ISO 1181:2004, Quality 1, or a spun thermoset polyester rope with a polypropylene core of a colour that contrasts with the spun polyester.”

The ISO Standard also allows for alternative rope arrangements. The same ISO standard provides guidance for step fixture, metallic materials, plastic materials, and rope seizing.

C). Regarding the combination pilot ladder with trap door: This arrangement has already been banned. We agree that the vessel may not be able to rectify this onboard. However, the management company should be able to arrange for a shore modification/replacement to meet the requirements. 

Regarding '8-shaped' clamps: Some investigations are suggesting that the use of these clamps is a contributing factor to some of these incidents. They move easily, they lose grip especially with mechanically retrieved ladders. That said, IMO Res A. 1045(27) stipulates under 2.2.3 that the preferred method is seizing. 

We suggest that if used, make inspecting them a part of the regular maintenance and inspection scheme, as they may be considered a weak link.

D). Regarding the side rope termination under the bottom step: IMO Res A. 1045(27) 2.2.1 stipulates that “…the side ropes of the pilot ladder should consist of two uncovered ropes not less than 18mm in diameter on each side and should be continuous, with no joints and have a breaking strength of at least 24 Kilo Newtons per side rope.”

To achieve continuity, the side ropes will require either a bottom or a top termination.  (Refer to ISO799:2019 5.4 for full explanation on the rope termination).

 

Questions Regarding Ladder Quality or Fake Ladders:

• Dear Sir, not all SOLAS-compliant new pilot ladders prove to have adequate similar strength... How do you choose the best kind?
• Does a MED Approval Certificate cover me?
• Is Rightship thinking of banning some of the suppliers who have supplied poor quality ladders in the past? What is the standard of ladder set by RS?
• How strict is the organization for approving pilot ladder manufacturing? Most of the time inferior quality pilot ladders are what are received. Industry should regulate quality.
• How does one spot or detect a fake pilot ladder certificate? Any idea what is the best way to have it check the validity of it when issued, particularly in Suez Canal suppliers?
• How can the authenticity of the certificate which mentioned be verified as ISO 799(2019) compliant?
• Is there any online verification for standard and quality to eliminate the counterfeit supply?
• What items need to be checked on the pilot ladder certificate?
• What are the required markings on a valid certificate? Is there a standard model certificate for pilot ladder?
• What are your feelings on IACS members approving low quality ladders?

RightShip’ s Answer:

A). Price and/or availability should not be the only deciding factors when choosing a pilot ladder provider. As explained during the webinar and answered in different questions, it is all about due diligence. Choose quality, reputable suppliers.

B). MED stands for Marine Equipment Directive 2014/90/EU. This is typically seen on the Manufacturer’s name plate on the pilot ladder as well as the Certificate of Declaration of Conformity. This declaration is issued with certain information including: 

• Type approval requirement 
• Carriage and performance requirements
• Testing standards
• Type examination certificate no. (and the issuer which is typically an IACS member)
• Quality system certificate no. (and the issuer which is typically and IACS member)

As far as whether you are covered with this certificate or not, we suggest that you consult your vessel’s Flag State or the Class that is acting on behalf of the Flag. 

C). RightShip neither approves nor rejects suppliers. The acceptable standard by RightShip is the applicable standard as per the requirements and guidelines. 

D). RightShip is unaware of the approval criteria for manufacturers. 

E). Regarding the authenticity of the certificates, please refer to (a) and (b) above. Additionally, you may wish to ask your suppliers to provide evidence of testing and compliance in terms of type examination certificate and quality system certificate then verify them with the issuer (IACS members).

F). Regarding things and required markings to check on a certificate, please refer to (b) above noting that the list is not exhaustive. 

G). We cannot comment on approval bodies processes and procedures. 

 

 Questions Regarding New Technology:

• The pilot ladder designs have been the same for hundreds of years. Even with the new sizes of ships and technologies onboard, the pilot ladder design and materials have not changed. What is the main reason for this and how can we overcome the issue and develop a transfer arrangement which is safer?
• What role do you think technology or automation could play in improving safety in pilot transfer operations?
• Why don’t we proceed towards synthetic ropes & FRP steps which would not be as affected by weather conditions as observed with manila ropes & wooden steps?

RightShip’ s Answer:

A). We are calling upon pilot’s associations, terminals, and port authorities to provide their feedback and suggestions to Flag States, representatives in IMO, industry bodies and other stakeholders.  This is the only way we can influence any future change. 

B). Technological advancement is an enabler and will surely play a huge role in improving safety in pilot transfer operations. 

C). Regarding synthetic ropes please refer to ISO799-1:2019. The standard offers alternative ropes arrangements under 4.2.2.

As far as steps are concerned, IMO Resolution A.1045(27) stipulates the following under 2.1.2:

• “The steps of the pilot ladders should comply with the following requirements: .1 if made of hardwood, they should be made in one piece, free of knots.”
• “If made of material other than hardwood, they should be of equivalent strength, stiffness, and durability to the satisfaction of the Administration.”

 

  Uncategorized Questions: 

• As experienced pilots, could you please clarify for me whether it is mandatory for the OOW to go down on the bottom/end platform of gangway in the cases where the combination ladders are rigged?
• At times in port, some of the pilot or the authorities reject the ladder which is in perfect condition and try to pressure master by saying they will delay the vessel’s movement. En lieu of replacement, they usually ask for a gift. How can we address this problem?
• Is it possible that not only the ship’s crew were at fault and some pilots have made errors as well? I have seen at least 50 pilots in my life who have been too old, too weak, or too clumsy and posed a safety risk for me. 
• Pilots also can help to raise standards, simple fixes like retrieval lines incorrectly rigged or ladder reels not secured can be solved quickly with instruction to the Master and crews, a lot of time the crew do not see the hazard.
• Thank you for your nice presentation. Is there any way to receive the material of the presentation so it can be forwarded to our vessels as an additional safety awareness regarding pilot ladder arrangements?

RightShip’ s Answer:

A). We are unaware of any regulation or guideline that requires the OOW to go down to meet the pilot at the lower platform of a combination ladder gangway. Some might argue that by doing so, the officer is limiting the space for the pilot to transition from the pilot ladder to the gangway. This is a safety concern. 

B). Incidents or allegations of corruption claims maybe be reported through the Maritime Anti-Corruption Network website. 

C). Currently, RightShip is looking at incident prevention from non-compliance and substandard equipment and procedures perspective. 

D). We are of the opinion that the pilot is not there to tell the crew how to rig the pilot ladder correctly. Rather, the crew ought to be properly trained and conversant with the regulations and requirements before undertaking the task.

E). The Pilot ladder insight’s piece can be viewed at this link :  https://rightship.com/insights/safety-insights-paper-pilot-ladder-arrangements 

 

Questions Regarding Regulations:

• Any requirements on the Manropes?
• Are not all parts of ISO 799:2019 already enforced?
• Are there any restrictions for using retrieval rope while rigging pilot ladder?

RightShip’ s Answer:

A). Manropes are to be rigged if required by the pilots. The manropes are to be without notes, minimum diameter of 28 mm and max 32 mm. refer to the pilot ladder poster.

B). Please refer to the ISO 799-1:2019 for further guidance.

C). The retrieval line should be rigged at or above the spreader and facing (leading) forwards, never aft.

 

 

Questions Regarding Service Life of Pilot Ladders:

• What are the usual replacement criteria for Pilot Ladders?
• What are the generic guidelines on the service life of Pilot ladder?
• AMSA marine circular adds -30 months frequency for strength test - can we have your opinion on that aspect?
• Is the AMSA pilot ladder replacement requirement of 30 months mandatory throughout the world?
• Is there a mandatory life span of pilot ladder? If the ladder was supplied but not used until 6 months later, will the service life start from the first date of use?
• ISO certified pilot ladders must be inspected and load tested by manufacturer at 30 month intervals.
• To be clear, the lifespan of the ladder starts from the date of manufacturer NOT from the date in service. Am I correct?
• Is it important to advise on the pilot ladder usage duration? If we follow ISO 299:2019, does the ladder need to be tested every 36 months from the previous date of testing?
• MCA states 30 months for pilot ladder. Also, vessels calling Australia are asked if ladders are more than 30 months old. 
• Regarding 30 months service life, I know ISO799-2:2021 confuses the issue. However the only real way to determine the pilot ladder age is to use date of manufacture. The same way flares, medicines and other onboard equipment. Do you work from date of manufacture?
• Suggestions to have standard interval for renewal of ladder from the time it is put in use. Frequently, we are unable to get new ladders for MONTHS... there are many reasons: proper length unavailable, cost is too high, no suppliers, ladders are not certified etc.
• What if the pilot ladder was not used in the range of 30 months? Do we need to purchase a new one?
• When does the lifespan of 30 months on pilot ladders start?
• Why no restriction on pilot ladder for maximum of a 2-year service life?
• What should be a reasonable frequency for pilot ladder renewal and industry recommendation?

 

RightShip’s Answers:

• While there is no specific retirement age dictated by regulation, the following must be noted: 
  • Industry Best Practice is replacement between 24-30 months. 
  • Regarding start of ladder service life, this also is not set in stone. Some calculate from the time ladder is put into service. Others calculate pilot ladder’s service life from date of manufacture.
  • Some local authorities have mandated pilot ladder replacement interval of 30 months from the time the ladder was received on board. 
• RightShip cannot stress enough that time is only one of the factors that should be considered when determining if a ladder is still suitable for use or not. Depending on trading areas, frequency of use, exposure to weather conditions, storage environment, and maintenance or lack thereof, ladders can wear out sooner than 24-30 months. Therefore, proper training on ladder inspection and maintenance is crucial when considering whether a ladder is unsafe and should be replaced, either before or after the 24–30-month period.
• Ladder manufacturers that are ISO compliant shall supply care, maintenance, inspection, storage, and repair instructions specific to the ladders they produce. (ISO-799-2:2021)
• “Each ladder shall be subjected to the ladder and step attachment strength test in ISO 799-1:2019, Table 2, at intervals of not more than 30 months.” (ISO 799-1:2-2021 6.6)
• As of now, there is not one specific method that can replace pilot ladder arrangements for all scenarios for which they are used. 

 

Questions regarding Maintenance/Inspections/Onboard Repairs:

• Are onboard repairs possible with the ladders? If so, please provide details.
• Does maintenance carried out by crew on pilot ladder affect the integrity of the ladder itself as built?
• If pilot ladder maintenance is allowed for, does it have to be renewed after being found in unsatisfactory condition?
• Is it acceptable that a pilot ladder be repaired by ship staff, and will the certificate still be valid?
• New ladders received damaged! What is the acceptable level and proper repair to an already certified ladder?
• Pilot ladders are required to be load tested, can this load testing be carried out by the crew?
• Any suggestions apart from visual inspection?

 

RightShip’s Answers:

A).  IMO Res. A. 1045 (27): 2.1.3 “No pilot ladder should have more than two replacement steps which are secured in position by a method different from that used in the original construction of the ladder...”

ISO 799-1:2019: 5.18 “The manufacturer should offer replacement steps, including replacement spreader steps, for the ladder that can replace a removed step, without the need for unstringing and restringing the ladder...”

ISO 799-1:2019: 10.1 “...a ladder shall not include more than two replacement steps and one replacement spreader step.’”

ISO 799-1:2019: 10.2 “If a ladder requires a third replacement step or a second replacement spreader step, it shall be rebuilt...”

ISO 799-1:2019: 10.3 “Such ladders shall be rebuilt by the original manufacturer, or an organization or person authorized by the original manufacturer...’”

 

Any onboard repairs other than those allowed by the manufacturer should be avoided. Repairs of the side ropes are considered a major repair in the context of the ISO 799-1:2019, thus shall be undertaken by the manufacturer or manufacturer’s authorized entity. Please ensure to be guided by the full original text of the applicable regulations as well as the instructions provided by the ladder manufacturer. 

B). If the onboard repairs are conducted in strict adherence to the manufacturer's recommendations and in accordance with the current regulations, the ladder integrity and certification should remain unaffected.

C). In case the ladder is found in unsatisfactory condition beyond the scope of the acceptable onboard repairs, this ladder should be removed from service and replaced or repaired.

D). For guidance on the ladder and step attachment test at not more than 30-month intervals, please refer to 10.4 of the ISO 799-1:2019 and/or 6.6 of ISO 799-2:2021.

 

 

Questions Regarding Securing / Rigging:

• Regarding strong points, is there a minimum distance requirement from ship's side edge?
• How do we ensure the pilot ladder is firmly secured to the designated shackles and not to other points like railings, so that the weight should come on side ropes and not steps of ladder or chokes?
• Can they make a standard boarding arrangement rigging procedure mandatory for designated person in charge?
• If not the shackles, then what is the recommended means to secure with to strong point on deck/eye pad?
• If ropes are used for securing the ladder, which points will be the best place to secure them?
• Are magnets for pilot ladders mandatory? If so, is this considered a detainable deficiency?
• Is it mandatory that the retrieval line lead forward even if we arrange a combination ladder?
• Is the securing method of "Rolling hitches” the best selection for pilot transfer operations?
• Isn’t it high time that an approved method of securing the pilot ladder is adopted under SOLAS?
• There is no guidance on placement of securing points and its SWL.
• Please show or guide us as to the correct way for securing the pilot ladder without shackles.
• Shouldn’t the strength of the securing ropes be 48kn rather than 24kn?
• What kind of certificate is required for the eye pads welded on the main deck for fixing the top point of the pilot ladder?
• Should the securing shackles be certified as pilot ladder accessories?

RightShip’s Answers:

A). Refer to the recommendations by the International Organization for Standardization, ISO 799-3:2022.

5.1 “Ring plates used to secure man-ropes or pilot ladders shall be capable of withstanding a load of not less than 24 kN.”

5.2 “When secured to the upper deck, the pilot ladder should be secured at a distance of not less than 915 mm measured horizontally from the ship’s side inwards.’”

5.3 “When a pilot ladder is rigged at less than full length to accommodate changes in freeboard, the ladder shall be secured on both side ropes in the manner specified by the pilot ladder manufacturer. In the case of a rolling hitch, the rope shall be at least as strong as the side ropes and shall be secured to a deck securing strongpoint observing the following...”

For guidance on the magnetic clamps or other methods to secure the pilot ladder’s side ropes to the ship’s hull, please refer to the ISO 799-3:2022.

As for the retrieval line leading forward even in the combination ladder arrangement, we see no exception to this requirement in the current regulations. So yes, if used, the retrieval line must always lead forward.

Regarding the strength of the securing ropes, IMO Res. 1045 (27) says that ‘The securing strong points, shackles and securing ropes should be at least as strong as the side ropes...’. 48kN mentioned in ISO 799-1 refers to a breaking strength of both securing ropes.

 

Questions Regarding Storage:

• Do you suggest collecting rescue boat/life raft embarkation ladder as well to protect them from weather?
• Not so much of a question but an experience to share. We have experienced defects with pilot ladders from a certain reputable maker that were finally attributed to the ships' stowage reels which were of a small diameter. The maker suggested stowing the pilot ladder to a larger diameter reel. Of course, the ship had the usual reels where the reel is basically a thick pipe. Have you experienced such an issue?
• The main deterioration factor for the pilot ladder is storage in an unprotected area, only covered with canvas causing premature rope deterioration.

RightShip’s Answers:

A). ISO 799-2:2021 requires the ISO certified manufacturers to supply care and maintenance instructions as detailed in the text of the Standard. Among other points, these instructions are required to include “...care and storage instructions with specific warning on the proximity to chemicals, effect of sunlight or other possible causes of degradation of the ladder.”

B). Please refer to your ladder manufacturer’s specific guidelines. 

C). In general, it is advisable to store ladders in a compartment that is dry and allows for good circulation of air. When kept outside, it is essential to have a protective cover and place the ladder on a suitable platform that shields it from aggressive substances and provides good circulation of air. In such a case, the ladder must be subjected to stricter inspections.