After fatal fall, pilots urge new scrutiny of ladder arrangements

A fatal accident in December in New York Harbor underscores the safety risks maritime pilots face when boarding vessels.
 
The Dec. 30 accident that claimed the life of Sandy Hook pilot Capt. Dennis Sherwood prompted the International Maritime Pilots’ Association (IMPA) to address the International Maritime Organization (IMO), highlighting the dangers of a particular pilot ladder arrangement called the trapdoor. Pilots from other organizations also have called for enhanced pilot safety measures from the IMO and member states, particularly in regard to the trapdoor arrangement like the one on Maersk Kensington, the containership from which Sherwood fell.
 
Trapdoor arrangements require a pilot to ascend a ladder to a platform, then climb to the deck via a separate accommodation ladder. The pilot ladder arrangement used on Maersk Kensington “involved a trapdoor … with the pilot ladder hanging from a bar near the bottom of the platform, and the top step of the pilot ladder significantly below the level of the platform,” said IMPA President Capt. Simon Pelletier in an address to the IMO on Jan. 17.
 
“This controversial trapdoor arrangement has long been considered unsafe by pilots,” Pelletier also said in the statement.
 
An IMO media representative directed questions about proposed pilot safety regulations to the IMPA. Current safety guidance on pilot transfer arrangements, enforced by IMO member states and contained in SOLAS Chapter V, Regulation 23, entered into force in July 2012.
 
Since January 2015, the U.S. Coast Guard has investigated seven incidents involving pilot ladders. These incidents resulted in seven injuries and one fatality, according to Coast Guard spokeswoman Lt. Amy Midgett.

Capt. Dennis Sherwood of the Sandy Hook Pilots Association fell while boarding Maersk Kensington on Dec. 30 in New York Harbor, landing on the boat that transferred him. He later died from his injuries. 

Courtesy Sandy Hook Pilots Association/Derek Lilley

Midgett told Professional Mariner that the Coast Guard was still collecting evidence regarding the Maersk Kensington incident. A representative for Maersk North America did not return a message requesting comment.
 
Sean Kline, director of maritime affairs with the Chamber of Shipping of America, said his organization briefs members at policy meetings after incidents like the one in New York Harbor. Members are encouraged to inspect equipment and practice due diligence to prevent future accidents.
 
“These ladders take a beating from the elements and nature of their use, and ship’s crew should keep a close eye on their condition,” Kline said. “Embarking a pilot is an extremely dangerous evolution, though it may appear as routine, because ships and pilots must conduct this evolution on a consistent basis, sometimes in the dark, wind, rain, snow, etc., with few other options.”
 
According to pilots, the trapdoor arrangement can make boarding a ship even more difficult. Regulation 23 allows trapdoors, but for ships built after July 1, 2012, it bans a particular configuration where the pilot ladder does not extend through the platform. The U.S.-flagged Maersk Kensington was built in 2007 in South Korea.

Trapdoor arrangements like the one employed on Maersk Kensington take boarding a ship “into the realm of unacceptable risk, as evidenced by the recent tragic loss of Sandy Hook Pilot Capt. Sherwood,” said Capt. J. Stuart Griffin, a pilot who works on the Delaware River. “I strongly believe the (Coast Guard), the IMO and other regulatory bodies should move to outlaw them at once.” 

According to Capt. Jorge Viso, president of the American Pilots’ Association, the regulation stating that a pilot ladder must extend through the platform has been “grandfathered,” endangering pilots.
 
“Some of those things shouldn’t be allowed to be grandfathered,” he said.

This photo of Maersk Kensington from 2010 shows the ladder arrangement on the containership. 

Courtesy Sandy Hook Pilots Association/Derek Lilley

Types of ladder arrangements
Ships with a freeboard height of less than 9 meters (29.5 feet) generally use a single pilot ladder that extends up to the deck or a side door. IMO regulations stipulate that vessels with a higher freeboard height must use a combination arrangement, which involves a pilot ladder and accommodation ladder.
 
While safety issues exist with all transfer arrangements, the trapdoor is the biggest concern for most pilots. When the pilot ladder extends through the platform, it allows the pilot to easily step off. When this is not the case, “the pilot cannot maintain contact with a single climbing surface, and furthermore is forced to lean back away from the ship’s hull to transition in (a manner) that is not vertical,” Griffin said.
 
The most common type of combination arrangement involves a pilot ladder placed beside an accommodation ladder that contains a platform. “You climb up the ladder and when you’re even with (the platform), you just step onto it horizontally,” Viso said.
 
Regardless of a ship’s freeboard height, the manner by which crewmembers attach a pilot ladder has major safety implications. According to SOLAS, rope lashings at the top of a ladder must be affixed to a strong point on deck.

Viso said pilots frequently witness improperly secured ladders and that SOLAS does not govern how to affix a ladder when it is not deployed at its full length — which often occurs when a ship is weighed down by cargo. He voiced doubts about the widespread use of shackles to attach ropes to the deck and called for more detailed regulation governing how to affix a pilot ladder when it cannot extend to its strongest point.
 
Whichever ladder arrangement is used, pilot safety is largely in the hands of crewmembers on the ship being boarded, who are responsible for affixing the ladder. Typically, pilots cannot accurately gauge the safety of a ladder before boarding.
 
Viso added that a single pilot ladder is the most common arrangement. Some pilots rarely see trapdoors, which are mostly employed on large, oceangoing vessels. 

A trapdoor arrangement with the pilot ladder extending through the platform opening. 

Courtesy Adam Roberts-AMPI/Ports of Auckland Ltd.

Ensuring pilot safety
When it comes to improving pilot safety at the national and international levels, IMPA Secretary-General Nick Cutmore called for stronger enforcement of existing regulations. He said that while IMPA does not seek to rewrite SOLAS, it wants ship operators “to offer what is in a (supposedly) binding international convention that the whole planet is signed up to.”
 
Port state authorities like the Coast Guard verify the compliance of ladder arrangements during vessel inspections. Midgett said the Coast Guard cited 64 deficiencies involving pilot ladders in the past five years. Common issues included lack of maintenance records, material condition, control cable or electrical issues, and failure to follow shipboard testing and inspection procedures. Nearly 70 percent of these deficiencies involved a deep-draft vessel, she said.
  
The Coast Guard also shares responsibility for verifying safety compliance during vessel construction. Pilot ladders on ships built in the United States typically must be approved by the Coast Guard under Title 46, Subpart 163.003 of the Code of Federal Regulations (CFR).
 
The service is collaborating on revised pilot ladder standards as part of the International Standardization Organization (ISO) Ships and Marine Technology Technical Committee. This panel published ISO 799-1, which governs ladder design and specification, in 2019. ISO 799-2 and 799-3, which together govern maintenance, use, survey, inspection and attachments for pilot ladders, are under development.
 
“This effort is in response to the international concern for pilot boarding arrangements and will be the basis for future Coast Guard policy and regulations,” Midgett said.
 
When it comes to compliance, Viso said the Coast Guard can increase its scrutiny of safety regulations during the construction process, even if a classification society has already given its approval. For vessels built in the U.S., the Coast Guard either conducts its own inspection during construction or oversees a third party.

A more hazardous trapdoor arrangement, with the pilot ladder rigged to the bottom of the platform.

Courtesy Adam Roberts-AMPI/Ports of Auckland Ltd.

“Certain third-party oversight programs permit the classification society to use (its) own rules instead of the Code of Federal Regulations,” Midgett said.
 
According to pilots, ladder arrangements have been approved that do not comply with SOLAS. Citing conversations with colleagues, Viso said he has heard reports of arrangements “that have been passed by class and OK’d by the Coast Guard” that violate the SOLAS trapdoor regulation that entered into force in 2012.
 
Cutmore said the IMPA expected a more rapid phasing out of the arrangement where the pilot ladder does not extend through the trapdoor. The group initially agreed to the grandfathered provision to avoid industry pushback, expecting that more ladder arrangements would come up for renewal and require adjustment.
 
“There seem to be a remarkable number of vessels whose arrangements have not required renewal or adjustment since 2012,” Cutmore said. “The accommodation ladder platform is not a complex item, nor is it part of the ship’s structure. It’s relatively easy to change to meet the SOLAS 2012 requirements.”

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