Marine Notice 13/2014

Means of embarkation and disembarkation from ships in port

The purpose of this Marine Notice is to bring to

the attention of ship owners, ship operators, ship
masters, port authorities, terminal operators and
persons boarding and disembarking ships the
requirements for accommodation ladders and
gangways under section 68 of Marine Order 21.
Section 68 of Marine Order 21 requires access to
be provided in accordance with Schedule 8 of the
order. This section places obligations on both the
master of the ships and those using the access.
It is important to note that the master of the ship
is not required to provide the means of access,
however, where it is provided by the ship the
master must ensure the means of access
complies with MO 21, SOLAS regulation II-1/3-9
and MSC.1/Circ.1331. If the master cannot
provide compliant access with the means
available on board, an alternate arrangement AMSA is aware that arrangements at some
must be put in place rather than employing an berths in Australia prevent accommodation
unsafe/non-compliant arrangement. ladders being safely landed on the wharf edge.
Where a means of access is provided by a port In such situations it is a common practice to
authority or other person, the master must take suspend the ship’s accommodation ladder at the
measures to ensure that any safety concern ship’s side with a short brow or gangway fitted to
identified are bought to the attention of: the lower accommodation ladder platform to
bridge the gap between the ship and wharf edge.
(a) the person providing access; and
In other cases terminal access restrictions are
(b) a person requiring access to or from the being imposed resulting in accommodation
vessel.      ladders being rigged on the outboard side of the
ship with access by launch.
The master and any provider of the means of If the use of these practices results in an unsafe
access are both responsible for ensuring that no means of access to or from a vessel in port, it will
unsafe means of access are used. be a breach of section 68 of Marine Order 21.
AMSA has become aware of the following
Fall prevention devices on suspended
recurring issues:
gangways
Suspended Accommodation Ladders
Where this occurs some terminals are requiring
Where access is provided by mean of the ships or encouraging the ship master to fit fall
accommodation ladder Schedule 8 of Marine prevention devices to suspended ships
order 21 requires that the means of access is at accommodation ladders, especially those that
an angle allowing safe access to the vessel are deployed on the outboard side of the ship.
and firmly landed on the wharf edge.

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There are no requirements under Marine Order Accommodation ladders and gangways at
21 or SOLAS regulation II -1/3-9 for the fitting of steep angles
accommodation ladder fall prevention
arrangements and no standards in
MSC.1/Circ1331 for the construction,
maintenance and operational testing of gangway
fall prevention arrangements. In some cases
ships may be fitted with class approved and
certified gangway fall prevention arrangements,
however, this is not the case in the majority of
ships AMSA has inspected.
AMSA has noted in many cases that the fall
prevention arrangements fitted are inadequate
for their intended purpose and introduce
unacceptable hazards and risks. The fall
prevention arrangements have been found to
have inadequate load bearing capacity because
they are connected to non-load bearing parts of
the accommodation ladder and ship structure or The angle of an accommodation ladder/gangway
the tensile strength of ropes, wires, pullies and is governed by two requirements of MSC.1/
fittings is inadequate. Some arrangements are Circ.1331.
not adjustable and add a further risk to safety
when the ships draft changes or due to tidal Section 3.4.1 of MSC.1/ Circ.1331 requires that
variation. ships accommodation ladders are of sufficient
length that at the maximum design operating
AMSA does not object in principle to a fall angle the lower platform will be not more than
prevention device that is properly designed and 600 mm above the waterline in the lightest
fit for purpose. However, where these devices or seagoing condition, as defined in SOLAS
arrangements pose a safety risk AMSA will take regulation III/3.13.
action as appropriate.
The second relates to the maximum angle of
inclination where section 3.7.1 of MSC.1/
Circ.1331 requires that:
 Gangways (such as shore supplied brows or
gangways) not be used at an angle of
inclination greater than 30° from the
horizontal; and
 Ships accommodation ladders should not be
used at an angle greater than 55° from the
horizontal, unless designed and constructed
for use at angles greater than these and
marked as such, as required by paragraph
3.5 of MSC.1/Circ.1331.
Unsafe arrangements
In order to prevent undue delays in preparation
for loading it has become common practice in
many Australian bulk terminals for ships,
especially where a high loading rate is expected,
to be deballasted beyond their lightest seagoing
condition in preparation for loading.

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This has resulted in ships accommodation Action by AMSA
ladders being rigged at angles of inclination
AMSA wishes to remind masters that they must
greater than their design limits at the
make every effort to comply fully with Marine
commencement of the load. This is especially
evident at wharfs with a minimal height above Order 21 and seek the assistance of port
high water or where access to the ship is via authorities, terminal operators and stevedores as
launch using an accommodation ladder rigged on appropriate in ensuring compliance. It should be
noted that:
the seaward side of the ship. AMSA has noted
accommodation ladders in use where the angle 1. If a means of access is provided by a port
is well in excess of 55. Such angles result in authority or other person, the master must
access being both difficult and dangerous. take measures to ensure that any safety
concern has the attention of the person
AMSA surveyors have also found gangways
providing access and persons requiring
provided by terminals or port authorities are
access to or from the vessel and it is the
frequently rigged at angles of more than 30. master’s responsibility to ensure that only a
This is prevalent in terminals where there is a safe means of access is used. The shore
large tidal range and berth design constraints.
provider of the access is also responsible
Gangways should be frequently monitored and for ensuring it complies with Marine
adjusted as required to ensure they do not Order 21.
become too steep or are not firmly landed on the
wharf edge. Ships may not be able to move or
2. Where an accommodation ladder or
adjust shore gangways due to a lack of
gangway is employed owners and operators
appropriate lifting equipment or the position of of vessels are reminded that any
the gangway on the ship, consequently the accommodation ladder or gangway fall
provider of the gangway is responsible to ensure prevention arrangements fitted to their ships
adequate resources are provided to move /
must be fit for purpose and should seek
adjustment gangways as required by the master. assistance from their flag and/or class
AMSA is increasingly concerned that some society in this regard.
unsafe arrangements are being employed as a  
result of solutions to other perceived concerns.
For example, it has been suggested to AMSA
that some arrangements requiring access only
via launch have been implemented to eliminate
Work Health and Safety (WHS) concerns for
crew/agents/providores etc. transiting through
terminals. When the boarding by launch is
unsafe or actually imposes hazards greater than
terminal transiting, this arrangement needs to be
reviewed. Similarly, employing hanging
accommodation ladders with an attached brow
simply to overcome appropriate monitoring of the
access or to eliminate the need to call in
personnel to adjust the landing of the access on
the wharf is not in principle an adequate reason
to implement arrangements outside the design of
the shipboard access arrangement. 3. Gangways and accommodation ladders
must not be used where the angle exceeds
It is important to note that accommodation the allowable limits or, in the case of
ladders and gangways are designed and tested accommodation ladders, the lower platform
to be landed on a solid surface. To do otherwise is too high above the water.
is impacting on the engineering design of the
shipboard access arrangement, and that in itself
places a higher duty of care on those requiring
the change in access arrangement.

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Where an AMSA surveyor identifies that a shore AMSA wishes to encourage port authorities and
facility has provided an unsafe arrangement for terminal operators to reference the information
access, or does not provide a mechanism where provided by;
the ship can provide a safe access by its own
 Marine Order 21 (Safety of navigation and
means, then an Improvement Notice may be
issued to the relevant person under section 265 emergency procedures) 2012
of the Navigation Act 2012. This will specify the  MSC.1/Circ.1331 – Guidelines for
action to be taken and the time frame for Construction, Installation, Maintenance and
completion. Inspection/Survey of means of Embarkation
If AMSA prohibits use of a means of access, use and Disembarkation
of that access will constitute an offence.  ILO Code of Practice: Accident prevention
on board ship at sea and in port (Section 8 -
Safe access to ship)
 ILO Code of Practice: Safety and health in
ports (Section 3.4 - Shore-side access to
ships)
 Marine Notice 4/2010 – Construction,
Inspection and Maintenance of
Accommodation Ladders and Gangways

and to take all necessary measures to assist ship

masters in providing safe access to their ships.

In addition, all Australian workers are covered by

relevant workplace health and safety legislation
and this places an obligation on employers and Brad Groves
employees to act safely. This means that all A/G Deputy Chief Executive Officer
persons using ships access have an obligation August 2014
not to expose themselves to hazards which
includes using an unsafe means of access.
Australian Maritime Safety Authority
GPO Box 2181
CANBERRA ACT 2601

File No 2014/2492

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