SSM issued a risk alert, in which highlights that a new regulation refers to the construction, installation, maintenance and testing requirements as detailed in MSC.1/Circ.1331 ‘Guidelines for Construction, Installation, Maintenance and Inspection / Survey of Means of Embarkation and Disembarkation’.
In May 2008 the IMO adopted SOLAS regulation II1/3-9 concerning the ‘Means of embarkation on and disembarkation from ships’, which entered into force on the 1st January 2010.
Whilst the legislation is principally concerned with the provision of a means of embarkation and disembarkation, such as accommodation ladders and gangways, on ships constructed on or after 1st January 2010, the final paragraph of regulation 3-9 applies to existing as well as new ships. The final paragraph states that the means of embarkation and disembarkation shall be inspected and maintained (with reference to MSC.1/Circ.1331) at appropriate intervals (Circ.1331 refers to SOLAS regulation III/20.7.2 which states monthly inspection and maintenance), to ensure they are in a suitable condition for their intended purpose, taking into account any restriction related to safe loading. It is therefore recommended that suitable periodic inspection and maintenance routines along with suitable checklists be included in the vessel’s planned maintenance system.
Inspection and Maintenance
The monthly inspection requirement as detailed in SOLAS regulation III/20.7.2 refers to the instructions for onboard maintenance in regulation III/36. Regulation 36 states that the instructions for onboard maintenance be easily understood, illustrated wherever possible, and as appropriate shall include the following: checklists, maintenance schedules, lubrication instructions, spare parts information and inspection and maintenance records.
Checklists for the inspection and maintenance of accommodation ladders and gangways should include:
It is recommended that records pertaining to the inspection and maintenance of accommodation ladders and gangways include the following: details
of the dates of inspection / maintenance, details of the work undertaken, the name of the person or body undertaking the work, the due date for the next
inspection and the date of the renewal of the fall wires. It is also recommended that the date of fall wire renewal is stencilled in the vicinity of the fall
The new SOLAS regulation II-1/3-9 states that all wires used to support the means of embarkation and disembarkation shall be maintained as specified in SOLAS regulation III/20.4. Regulation 20.4 refers to the maintenance of falls used in life saving appliances and states that these shall be inspected periodically with special regard to the areas passing through sheaves in line with the requirements of MSC.1/Circ.1206/(rev 1) ‘Measures to Prevent Accidents with Lifeboats’ It also states that falls should be ‘renewed when necessary due to the deterioration of the falls or at intervals of not more than 5 years, whichever is the earlier’. MSC.1/Circ.1206/(rev 1) states that wires should be periodically inspected to ensure they are in satisfactory condition and checked for corrosion and damage such as kinks, and kept properly greased with a suitable wire rope dressing. It is recommended that as part of the vessel’s Safety Management System a wire discard criterion be specified to ensure that fall wires are replaced before they deteriorate to an unacceptable degree.
Apart from the periodic inspections and maintenance that are now required to be conducted in line with the new SOLAS regulations, the accommodation ladder or gangway should be subject to a visual inspection each time it is rigged. Members and their vessels’ Masters must bear in mind that the implementation of this new legislation may be part of the focus of a Port State Control inspection and ensure they are fully in compliance with the new regulatory requirements. If the vessel is found to non-compliant with the new SOLAS requirements sanctions will be imposed by Port State Control which may include the detention of the vessel pending rectification of any deficiencies.