Confidential Human Factors

Incident Reporting Programme

M2719

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Concerns over the lack of a pilot ladder on board

Significant concerns were raised and reported when a pilot authority contacted CHIRP to report that the ladder supplied to a vessel was an embarkation ladder, not a pilot ladder. The pilot refused to board the vessel and requested that the master order a compliant pilot ladder before boarding could take place.

When questioned about the pilot’s refusal to board, the master stated that the embarkation and pilot ladders were the same!

 

The liferaft embarkation ladder is an important item of emergency equipment intended to assist personnel in boarding a lifeboat or liferaft during an abandonment. It is not designed or approved for pilot transfer or for contractors to embark.

CHIRP is concerned that this situation appears to have gone unchecked for an extended period. It is difficult to understand how the continued use of the incorrect ladder for pilot boarding became accepted practice. This suggests that nobody challenged the status quo or questioned whether the arrangement complied with requirements.

There was a clear misunderstanding on board about the difference between an embarkation ladder and a pilot ladder. Such a basic error indicates a lack of equipment awareness and raises broader concerns about whether other safety-critical equipment or procedures may also have been misunderstood or misapplied.

The vessel was not new and had reportedly operated in Northwest Europe for some time. This indicates multiple missed opportunities to identify and correct the deficiency. The failure was missed by the ship’s crew and onboard management, company oversight ashore, and external assurance bodies, including the flag state, port state control, and class. This was therefore not an isolated oversight but a systemic failure.

The vessel’s annual cargo ship safety equipment certification process should have confirmed that a compliant pilot ladder, together with a spare, was carried on board. In addition, SOLAS Chapter V, Regulation 23 specifically requires pilot ladders.

Safety standards improve outcomes only when they are clearly understood and consistently applied. If language, training, or poorly written procedures contributed to this confusion, these issues must be addressed. Instructions for critical equipment need to be practical, unambiguous, and regularly verified in use.

Credit is due to the pilot authority for halting the operation and refusing to board. Their intervention prevented an unsafe transfer and demonstrates the importance of speaking up and taking decisive action when standards are not met.

Factors relating to this incident

Capability – The master’s assertion that an embarkation ladder and a pilot ladder are equivalent indicates a gap in understanding of regulatory and safety-critical distinctions. This aligns with a breakdown in technical knowledge required for safe pilot transfer operations.

Complacency – The acceptance or normalisation of a non-compliant ladder suggests the risk may have been underestimated, possibly due to routine exposure without prior negative outcomes.

Alerting – Appears in a limited sense within the shipboard context. While the pilot demonstrated appropriate assertiveness, there is no indication that crew members challenged the arrangement internally, suggesting a possible reluctance to question decisions.

Communication – The mismatch between the pilot’s expectations and the vessel’s preparation includes both procedural communication (requirements not clearly understood or conveyed) and operational communication between the ship and the pilot authority.

Teamwork – A lack of teamwork may also be inferred, particularly if the bridge or deck crew did not engage collectively in verifying compliance or supporting safe pilot transfer preparations.

“A routine task became unsafe not through a single failure, but through a shared misunderstanding of what ‘correct’ looked like.”

Key takeaways

Regulators“Standards only improve safety when they are consistently understood, not just published.” This incident highlights the importance of ensuring that regulatory requirements, especially those concerning pilot transfer arrangements, are not only clearly outlined but also effectively understood and implemented in practice. Regulators might also consider whether guidance documents adequately distinguish between similar equipment types and whether additional focus is needed during inspections, audits, or awareness campaigns to address common misconceptions. The event underlines the value of strengthening practical understanding, not merely procedural existence.

Managers (Operators / Companies) – “If crews are improvising compliance, the system has already drifted from safety.” Managers should consider whether pilot transfer procedures are actively reinforced and whether crews are routinely exposed to the correct standards through drills, inspections, and supervision. There may also be a need to examine whether “work as done” has diverged from “work as intended,” particularly if non-compliant substitutions are being accepted in practice.

Seafarers “When something ‘looks about right,’ that is the moment to check more closely.” For crew members, the incident underlines the importance of recognising that seemingly similar equipment can have very different safety implications. Maintaining an accurate understanding of requirements, particularly for pilot transfer arrangements, is essential. The situation also highlights the value of speaking up and cross-checking, especially when there is uncertainty about compliance. A questioning mindset and willingness to verify assumptions remain key contributors to safe operations.