Security/Emergency Escape Conflict

Report Text:

The Owners have recently had fitted to all the class “A” machinery escape trunks a padlock system that allows the trunk hatch doors to be opened only in the way of escape.  I believe this to be in contravention of SOLAS Reg 13 general requirements:-

“3.1.5.   Doors in escape routes shall, in general, open in way of direction of escape, except that;

.2            doors in vertical emergency escape trunks may open out of trunks in order to permit the trunk to be used for both escape and for access.”

I fail to see how access can be achieved in an emergency if the trunk is locked from the outside. It is my opinion that the locking of these hatches poses a greater threat to the vessel and its crew than any implied attack on the vessel. These hatches have two independent functions: Firstly every Class “A” machinery space is required under SOLAS to have two means of access; one by stairway, and one, may be, by vertical ladder, the second is as a means of escape, under SOLAS the hatches may open outwards, but must be operable in both directions.

The idiocy of locking emergency escape/access in the name of security should be stopped before someone is injured as a result.

CHIRP Comment

We asked the UK Maritime and Coastguard Agency for an opinion and the following is an extract from their reply, more of which will be published in the next edition:

“The potential conflict between safety and security can be eliminated with some thought being given to both requirements. The November 1997 explanatory note to AMSA Direction 25A/96 identified examples of techniques used by operators which remain valid solutions:

• Digital locks with one way and fail open operation (on bridge doors, engine rooms, radio rooms).
• Fixed locks or bolts where possible (as above).
• Remote locking of car deck doors (with fail to safe or unlocked status) by means of hydraulics, compressed air, electronic systems or a combination of these.
• Micro switches or other electronic Intruder Detection Systems.
• Closed circuit TV (including video recording).
• Alarms (local or remote).
• Dedicated manual/physical guarding.

In MCA the solutions to this dilemma have been the matter of discussions with UK companies during and since the ISPS implementation. Additionally our surveyors are aware of the situation and have given advice to ships’ masters. We have not been specific in requiring one solution over another, it being dependent on pragmatism, the ship type and trading pattern. What is appropriate for a cruise ship may prove inappropriate for a sand dredger.

The situation that your correspondent identifies; escape hatches being padlocked shut from the outside, would be unacceptable on UK ships, or on ships in UK ports.”

The MCA’s 24hr Infoline is on 0870 6006505.