Non-compliant by design

3rd June 2019

Non-compliant by design

Initial Report


Two reports – one highlighting a new vessel that is non-compliant with SOLAS, the other describing how an overboard discharge was situated in close proximity to the pilot boarding station.

What the Reporter told us (1):

When disembarking from this new passenger vessel (built in 2018), the pilot boat was caught momentarily on the ship’s belting which caused it to dislodge the pilot boat’s fendering. As the sea conditions were slight it was not a serious problem. However, in heavier seas it could have caused damage to the pilot boat or resulted in the pilot boat suddenly heeling if its belting was caught above or below that of the ship.

The gap in the ship’s belting was estimated to be approximately 1 metre, significantly less than the requirements of IMO Resolution A1045(27) which states “Where rubbing bands or other constructional features might prevent the safe approach of a pilot boat, these should be cut back to provide at least 6 metres of unobstructed ship’s side.” See photo below. There are currently a series of new builds joining the fleet, and online images indicate they are all configured in the same way.

New build passenger vessel – and non-compliant

CHIRP Comment:

The vessel in question should be compliant with all the relevant rules and regulations. Naval architects, classification societies and flag administrations should consider how they assess all legislation that comes from IMO in order to make new builds fully compliant. Note that the vessel is a 2018 new build and the IMO resolution was issued in 2011. CHIRP has addressed this topic before in FEEDBACK 46 – page 3. Same company, different ship, different part of the world and different reporter.

What the Reporter told us (2):

During a pilot boarding operation, the pilot noticed water falling from a discharge adjacent to the boarding position. As the water stopped flowing, he assumed the deck party had blocked the scupper. The pilot commenced boarding but shortly thereafter another stream of water fell from the same discharge onto the pilot. The risk was closely monitored, and boarding effected without further incident.

When on board, the pilot tried to explain the situation to the responsible officer who failed to understand the seriousness of the risk. The water was on deck and it appears that the vessel’s rolling motion led to the intermittent discharge.

Further Dialogue:

CHIRP contacted the vessels DPA who responded positively as follows;

We have investigated the reported incident and discovered that the crew had recently washed the deck, including the pilot embarkation area, with fresh water. During the pilot’s embarkation, as a result of the vessel turning, the vessel heeled causing water to flow through the scupper.

Therefore, in order to avoid re-occurrence of such an incident, we have instructed all our company’s vessels to ensure that the pilot embarkation is clear of any water accumulation and also to ensure that no water can drain from the scuppers during pilot boarding / disembarking.

CHIRP Comment:

SOLAS V 23 Regulation states that pilot transfer arrangements are to be clear of any “possible discharges from the ship” The presence of a discharge pipe in close proximity to the pilot boarding station is a design fault in the vessel. Such faults often only come to light when a vessel becomes operational and it is left to the crew to deal with. Fitting a scupper plug prior to each pilot operation would be an easy solution.

Having initially identified a problem, the pilot failed to positively confirm that the discharge had been stopped before commencing his climb and will undoubtedly not make the same mistake again.

The observation that the responsible officer apparently failed to understand the potential for a serious incident is of concern.


Report Ends…………







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