Safe access
Relevant documents and M-notices: MGN 533, SOLAS Chapter II A-1, MSC.1 Circ.1331, COSWP Chapter 22
Where does the requirement for safe access come from?
There is a general duty under the Merchant Shipping (Health and Safety) Regulations 1997. It is an integral part of ensuring a safe working environment.
General requirements
From SOLAS Chapter II A-1, Regulation 3-9
Ships constructed on or after 1 January 2010 shall be provided with means of embarkation on and disembarkation from ships for use in port and in port related operations, such as gangways and accommodation ladders
For all ships the means of embarkation and disembarkation shall be inspected and maintained in suitable condition for their intended purpose, taking into account any restrictions related to safe loading.
Any means of access must be fit for purpose, compliant with legislation, well-lit and well maintained.
A lifebuoy fitted with a self-igniting light, and a buoyant lifeline attached to a quoit, must be kept at every access point to the vessel.
Means of access must be properly secured to the vessel and/or the quay.
Adequate lighting must be ensured during hours of darkness, for the gangway/accommodation ladder and immediate approaches.
Where there is a possibility of falling, a safety net is to be rigged. Some accommodation ladders and gangways, particularly those used by cruise ships, are of a ‘totally enclosed’ design; these do not require nets as there is no way anyone can fall from them.
There must be no overhead hazards.
Gangways and accommodation ladders
Vessels of 30m of more in length must carry onboard a gangway.
Gangways:
Should not be used at an angle of more than 30 degrees from horizontal
Should not be secured to a ships guardrails, unless designed for this purpose
Vessels of 120m or more in length must carry onboard an accommodation ladder.
Accommodation ladders:
Should not be used at an angle of more than 55 degrees from horizontal
Can be used in conjunction with a pilot ladder for pilot boarding/disembarking, in which case the maximum angle is 45 degrees from horizontal
Marking, inspection and testing
Gangways and accommodation ladders should be clearly marked at each end with a plate showing the restrictions on the safe operation and loading, including the maximum and minimum design angles of inclination, design load and maximum load and a unique serial number.
Gangways, accommodation ladders, winches and fittings are inspected monthly as per SOLAS Chapter III/20.7.2. They are also visually inspected prior to deployment.
Gangways and accommodation ladders are surveyed every year for the Cargo Ship Safety Construction Certificate or the Passenger Ship Safety Certificate.
What should be checked during the annual survey of an accommodation ladder or gangway (some items are item specific):
Steps and platforms
Pivots and rollers
All suspension points (lugs, brackets etc.)
Stanchions and handrails
Davit structure, wire and sheaves
Winch (controls, motor, brake system)
Decking, deck plates
Gangways and accommodation ladders are load tested every 5 years. Note that this is different to LOLER load tests. They are tested to their maximum operational load, including the winch, wire, davit etc. where relevant.
Wires should be changed out at a maximum of 5 years.
Portable and rope ladders
These should only be used where no safer means of access is reasonably practicable. When used these must be to the same standards as pilot ladders. Prior to using these it is prudent to carry out a written risk assessment to show that other means of access have been considered.
MCAQs
What legislation could the shipowner be prosecuted under, if the MCA were to find thata sub-standard rope ladder or plank was being used to provide access to a vessel?
Does the means of access have to be provided by the ship?
What markings are required for:
Gangways
Accommodation ladders
Pilot ladders
How often should an accommodation ladder be inspected? What would you look for when performing this inspection? How would you inspect the underside?
How often is a gangway load tested?
What are the maximum permitted angles for a gangway and an accommodation ladder?