Guidance

MGN 533 (M) Amendment 2 means of access

Published 9 August 2022

Summary

This notice outlines measures that shipowners and employers are expected to take in order to provide a safe means of access on UK ships.

Providing safe access to a ship is considered to be an integral part of ensuring a safe working environment on board, as required by the Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997, regulation 5(2)(e).

The Maritime and Coastguard Agency (MCA) considers that compliance with this notice will generally demonstrate that the shipowner or employer has done what is reasonably practicable to comply with the duty to ensure a safe working environment on aboard ship. Where alternative measures are taken to provide safe means of access, the shipowner or employer will be expected to demonstrate, to the satisfaction of the MCAthat these alternative measures provide at least an equivalent level of safety in the operating conditions concerned.

If the measures in this notice are not complied with, and no measures which MCA agrees are equivalent are in place, MCA will take enforcement action under the merchant shipping and fishing vessels (health and safety at work) regulations 1997.

Amendment 2 updates references and industry best practice in carrying out risk assessments.

1. Introduction

1.1 The merchant shipping and fishing vessels (health and safety at work) regulations 1997, as amended, place a duty on the shipowner and the employer to ensure the health and safety of seafarers, workers and other persons so far as is reasonably practicable. That duty extends to provision and maintenance of an environment for persons on aboard ship that is, so far as is reasonably practicable, safe and without risk to health.

1.2 Providing a safe means of access to the ship is considered to be an integral part of that duty. The duty is placed on the shipowner, the employer and any other person “in control of the matter”, which – in respect that the equipment provided is properly used -will include the master.

1.3 In this notice, any reference to “access” means embarking on or disembarking from a ship.

2. Basic requirements

2.1 In order to ensure the safety of those leaving or joining the ship, a safe means of access is required between the ship and any quay, pontoon, other structure, or another ship alongside which the ship is secured. The master is responsible for ensuring that a safe means of access is provided, even if the equipment is provided from the shore-side.

2.2 The equipment used to provide a safe means of access should be placed in position promptly after the ship has been secured and should remain in position for as long as the ship remains alongside.

2.3 Access equipment when in use should be properly rigged, secured, deployed and safe to use. It should be adjusted as necessary from time to time to maintain safe access. During the rigging process seafarers must maintain awareness of their safety and follow guidance for working at height. See COSWP chapter 17 working at height.

2.4 The means of access and immediate approaches should be adequately illuminated, see COSWP chapter 11, section 11.5 lighting and in annex 11.2 standards for lighting.

2.6 Equipment used for access, and any safety net should be of good construction, of sound material, of adequate strength for the purposes for which it is used, free from patent defect and properly maintained.

2.7 A lifebuoy with a self-activating light and safety line attached to a quoit or similar device should be provided ready for use at the point of access to the ship.

3. Gangways

3.1 A gangway should be carried on every ship of 30 metres or more registered length (or overall length, if the ship is not registered). The gangway should be appropriate to the deck layout, size, shape and maximum freeboard of the ship and considered as lifting equipment with testing according to manufacturer’s instructions and recorded see COSWP 22.2.2 and annex 22.1 standards for means of access, section 2 and annex 22.2 corrosion and fractures of accommodation adders and gangways.

4. Accommodation ladders

4.1 An accommodation ladder should be carried on every ship of 120 metres or more registered length (or overall length, if the ship is not registered). The accommodation ladder should be appropriate to the deck layout, size, shape and maximum freeboard of the ship and considered as lifting equipment with testing according to manufacturer’s instructions and recorded see COSWP 22.2.2 and annex 22.1 standards for means of access, section 3 accommodation ladders and Annex 22.2 corrosion and fractures of accommodation adders and gangways.

5. Portable and rope ladders

5.1 Portable ladders should only be used in exceptional circumstances where no safer means of access is reasonably practicable, whilst taking account of vessel movement and tidal changes, with the ladders regularly inspected by a competent person. See COSWP chapter 22, section 22.6.

5.2 A rope ladder should only be used for the purpose of access between a ship with high freeboard and a ship with low freeboard or between a ship and a boat, and only if no safer means of access is reasonably practicable and when used the same standards apply as for pilot ladders. See COSWP chapter 22.9 access for pilots, 22.10 safe rigging of pilot ladders and annex 22.1.4 standards for means of access.

6. Safety nets

5.4 An adequate number of safety nets should be carried on board the ship, or otherwise be readily available for use. When access equipment is in use, and there is a risk of a person falling from that equipment, or from the ship or from the quayside, a safety net should be mounted in order to minimise the risk of injury. See COSWP chapter 22, section 22.3 safety nets.

7. Duty of workers

7.1 The merchant shipping and fishing vessels (health and safety at work) regulations 1997 require workers to take reasonable care for the health and safety of themselves and others on board the ship who may be affected by their acts and omissions. In particular, they must co-operate with the company or the employer or other person to ensure compliance with health and safety requirements.

7.2 A worker must therefore make use of any means of access provided for their use in accordance with these regulations, and any instructions or guidance as to its safe use.

8. Other guidance

8.1 COSWP chapter 22, section 22.1 introduction and section 22.2 general principals contains further guidance, including on maintenance of equipment for means of access, and alternative boarding arrangements when those described above are not practicable.

8.2 Where alternative measures are used, a risk assessment (COSWP chapter 1 annex’s 1-3) must be carried out and suitable protective measures be put in place following the guidance of COSWP chapter 17 working at height, including use of personal protective equipment (PPS) if there are risks which cannot be avoided by collective means and seafarers must wear the PPE provided, see COSWP chapter 8, section 8.3 seafarers duties and section 8.10 protection from falls for all personnel who are working at height.

8.3 MGN 591 (M+F) provides guidance on safe access for fishing vessels and other small vessels and chapter 22 section 22.11 safe access to small craft.

8.4 There are separate legislative requirements for the transfer of pilots in SOLAS chapter V regulation 23. These are implemented for UK ships by the merchant shipping (safety of navigation) regulations 2002. For further information see COSWP 22.8.6 concerning the transfer of personnel between two unsecured ships at sea and the requirement of risk assessment, taking into consideration the adequate positioning, securing and safe area around the access point. See section 22.9 access for pilots and 22.10 for the safe rigging of pilot ladders.

8.5 MSC.1/Circ.1331 – Guidelines for the construction, installation, maintenance and inspection/survey of means of embarkation and disembarkation – provides specific guidance for accommodation ladders and gangways required under SOLAS Regulation II-1/3-9.

9. More information

Seafarer Safety and Health Branch
Maritime and Coastguard Agency
Bay 2/17
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0)203 81 72250

Email: seafarersafety@mcga.gov.uk

Website: www.gov.uk/mca

General enquiries: infoline@mcga.gov.uk

Please note that all addresses and telephone numbers are correct at time of publishing.

Published: August 2022

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