Pilot Transfer Arrangements: The New SOLAS V/23 Performance Standard
The pilot ladder is no longer just a technical requirement in the text of the regulation: MSC 110 moves it into a new, standalone mandatory performance standard, with a long implementation timeline that nonetheless needs planning now.
Operational Explanation
The Maritime Safety Committee 110 adopted amendments to SOLAS Regulation V/23 together with a new mandatory performance standard dedicated to pilot transfer arrangements. All the technical requirements previously contained directly in the text of Regulation V/23 are moved into this new standalone standard, a structural change reflecting growing international attention to the safety of pilot embarkation/disembarkation, an operation that remains among the riskiest in shipboard life.
The reorganisation is not a mere formal exercise: separating the performance standard from the text of the Convention allows faster future technical updates, without having to amend the Regulation itself every time. But for the crew and the Company the practical point is a different one, and it is the most misread: 1 January 2028 does not concern new installations only. From that date parts D and E of the standard — inspection, stowage, maintenance, replacement and familiarization — apply to all pilot transfer arrangements, “regardless of the installation date”. An existing fleet has nothing to wait for until 2029: from 2028 it must have the spare ladder, the maintenance plan, the quarterly inspection and the service life limit.
Regulatory Reference
SOLAS Regulation V/23, entirely rewritten by res. MSC.572(110), and the Performance standards for pilot transfer arrangements, res. MSC.576(110): both adopted on 26 June 2025 at MSC 110, both in force from 1 January 2028. The standard is organised into an introduction and six parts: A Design, manufacture and construction, B Rigging, C Installation of pilot ladder winch reels, D Operational readiness, onboard inspection and maintenance, E Familiarization, F Approval. Circular MSC.1/Circ.1428/Rev.1 (5 September 2025) replaces the illustrations and revokes the previous version as of 1 April 2030 — the date on which res. MSC.576(110) invites the revocation of res. A.1045(27) and A.1108(29) as well: the recommended standard becomes a Convention obligation.
There are four dates, not two, and they do not say the same thing. The rewritten regulation keeps them in separate paragraphs. §23.3: arrangements installed on or after 1 January 2028 shall be designed, manufactured, constructed, secured and installed in accordance with the introduction and parts A, B and C. §23.4: those installed before, on ships to which chapter I applies, shall comply “not later than the first survey on or after 1 January 2029”. §23.5: those installed before, on ships to which chapter I does not apply, “not later than 1 January 2030” — a fixed date, tied to no survey. §23.6: inspection, stowage, maintenance, replacement and familiarization of all arrangements, “regardless of the installation date”, follow the introduction and parts D and E. §23.7 settles what “installed on or after 1 January 2028” means: the contractual delivery date of the arrangement or, in its absence, the actual delivery date to the ship.
What part D requires of every ship from 2028. Inspection before and after each use and a detailed inspection every 3 months, in both cases “by a responsible officer on board” (§25); a documented maintenance plan available for inspection, with a checklist, instructions, a schedule, sources of spares, a log of inspections and a record of the date of entry into service and the anticipated date of withdrawal (§27); the outright prohibition on repairing or replacing steps and spreader steps (§28); on board, at least one spare compliant pilot ladder and one spare set of compliant manropes (§29); and withdrawal from service “within 36 months after the date of manufacture or within 30 months after the date of being placed into service, whichever comes first” — or at any time the ladder ceases to comply (§30). Part E ties familiarization to the crew’s onboard familiarization: on ships to which chapter IX applies it is the Company that ensures it in accordance with STCW regulation I/14 (§32); for the others, part E sets out five minimum contents directly (§33). No interval in months: the trigger is the occasion, not the calendar.
Among the technical requirements of parts A–C, those that change shipboard habits most: all strong points, shackles and securing ropes shall have a breaking strength “not less than 48 kN”, permanently marked and with documentation kept on board (§6.1), and the same figure applies to the means of securing the ladder at intermediate lengths (§6.3); where rubbing bands or other constructional features prevent the safe approach of a pilot boat, they shall be cut back “to provide at least 6 m of unobstructed ship's side” (§10); the winch reel drum shall be no smaller than 0.16 m in diameter (§16) and “shall not be relied upon to support the pilot ladder when the pilot ladder is in use”, the ladder being secured to independent strong points (§20). Part F reserves to the Administration the type approval of the ladder, the means of securing at intermediate lengths and the manropes (§36). Two provisions of the regulation need no standard: §23.10, “Mechanical pilot hoists shall not be used”, and §23.12, which gives a pilot who suspects non-compliance the right to inform the master and refuse to use the arrangement.
Scope of Application
Every ship subject to SOLAS on which pilots may be employed, fitted with pilot transfer arrangements (pilot ladder, combination arrangement with accommodation ladder, winch reel, manropes, strong points). Application is differentiated by part of the standard, not by ship type: parts A, B and C to arrangements installed on or after 1 January 2028, to pre-existing arrangements by the first survey on or after 1 January 2029 (ships to which chapter I applies) or by 1 January 2030 (ships to which it does not); parts D and E to all arrangements from 1 January 2028, whatever the installation date.
Procedure / How to Complete It
- Separate the two tracks before planning anything: parts D and E take effect on 1 January 2028 across the whole fleet; parts A, B and C follow the installation date of the arrangement.
- For 2028, on every ship: put on board one spare compliant pilot ladder and one spare set of compliant manropes (§29), and check that the spares too are within the service life limit.
- Draw up the maintenance plan required by §27, with the inspection checklist, the manufacturer’s instructions, the schedule, the sources of spares, the log, and the record of the date of entry into service and anticipated withdrawal of each ladder and each set of manropes.
- Set up the inspection regime of §25: before and after each use, plus a detailed inspection every 3 months, both by a responsible officer on board, with the outcome recorded in the plan.
- Work out, for each ladder and each set of manropes, the withdrawal date: 36 months from manufacture or 30 months from entry into service, whichever comes first; and withdraw the arrangement at any time it ceases to comply. Remember that repairing or replacing a step is prohibited (§28): a defective step means the ladder goes out of service.
- Check familiarization against part E: on ships subject to chapter IX the Company ensures it in accordance with STCW regulation I/14; for the others, cover the five minimum contents of §33, including the special conditions (icing, wind, rough weather).
- For new construction with the arrangement delivered on or after 1 January 2028, require from the yard compliance with parts A, B and C and the Administration’s type approval of the ladder, the manropes and the means of securing at intermediate lengths (§36).
- For arrangements already installed, put the right deadline in the calendar: first survey on or after 1 January 2029 if the ship is subject to chapter I, otherwise 1 January 2030, a fixed date.
- Check the items that need work on the hull or on fixed arrangements, because they need yard time: strong points of 48 kN marked and documented, 6 m of unobstructed ship's side, a winch reel drum of at least 0.16 m and the ladder secured to strong points independent of the reel.
Practical Example
Example: a Company with an existing fleet opens the register in 2027 and finds that the pilot ladders of two ships were manufactured in 2024 and placed into service in 2026, and that neither ship carries a spare ladder. There is no point waiting for the 2029 survey: from 1 January 2028 part D applies regardless, so both ships get the prescribed spare, the maintenance plan and the quarterly inspection schedule — and the two existing ladders fall due for withdrawal within 30 months of entry into service.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| New construction for delivery from 2028 planned without specifying compliance with the new performance standard to the shipyard | Devices compliant only with the old version of Regulation V/23, to be upgraded later at additional cost | Explicitly specify compliance with the new standard in new-construction contracts for deliveries from 2028 |
| Compliance verification planning for existing devices postponed until close to the first survey due after 2029 | Risk of non-compliance found at survey with little time to correct it | Plan compliance verification with adequate lead time before the survey window |
| Existing fleet left untouched until the 2029 survey, in the belief that 1 January 2028 concerns new installations only | From 2028 the spare ladder, the maintenance plan, the quarterly inspections and the service life check are all missing: they are part D and E obligations, which apply “regardless of the installation date” | Keep two separate calendars: the one for parts D and E, which starts for everyone on 1 January 2028, and the one for parts A, B and C, which follows the installation date |
| Damaged step or spreader step repaired or replaced on board, as has always been done | §28 of the standard prohibits repair and replacement of steps: a repaired ladder stays non-compliant and must be withdrawn anyway | Treat a defective step as a reason to withdraw the ladder, and keep for that purpose the spare required by §29 |
What the PSCO Checks
Operational Tips
- The service life limit runs from manufacture, not from purchase: a ladder bought as a spare and left in the store burns its 36 months standing still. Record the date of manufacture on delivery and order accordingly.
- The permanent marking the standard requires — manufacturer, serial number, date of manufacture, approving authority, on the underside of the uppermost step and the lowermost spreader step — is what makes everything else verifiable. A ladder without legible marking has no demonstrable withdrawal date.
- The winch reel is not a securing point. If the ladder is stowed on a reel, the independent strong points must be arranged beforehand, not improvised: that is yard work, not shipboard work.
- In new-construction contracts specify the contractual delivery date of the arrangement, not the ship’s: that is the one §23.7 uses to establish whether the arrangement is “installed on or after 1 January 2028”.
Preparation checklist
Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.
- Spare compliant pilot ladder and spare set of compliant manropes carried on board
- Maintenance plan drawn up and available for inspection, with checklist, schedule, log and sources of spares
- Inspection before and after each use recorded, by a responsible officer
- Detailed quarterly inspection carried out and recorded
- Date of manufacture and date of entry into service recorded for each ladder and each set of manropes, spares included
- Withdrawal date worked out: 36 months from manufacture or 30 months from entry into service, whichever comes first
- Manufacturer's permanent marking legible on the uppermost step and the lowermost spreader step
- No step repaired or replaced on board
- Familiarization of the personnel involved documented (STCW regulation I/14 for ships subject to chapter IX)
- Strong points with a breaking strength of 48 kN marked, and documentation kept on board
- Deadline for parts A, B and C identified: first survey on or after 1 January 2029, or 1 January 2030 for ships to which chapter I does not apply
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Last substantive revision of this page: 19 August 2026 · page fingerprint 40c69ee62a41