The International Maritime Organization (IMO) has released new interpretation requirements regarding Permanent Means of Access (PMA) on oil tankers and bulk carriers, emphasizing the necessity for operators to adhere to updated inspection protocols. Under IMO circular MSC.1/Circ.1572/Rev.2, unified interpretations of SOLAS Regulation II-1/3-6 have been introduced, specifically addressing access to cargo areas in these vessels. These amendments pertain to oil tankers of 500 gross tonnage and above, and bulk carriers of 20,000 gross tonnage and above, constructed after January 1, 2006. A significant change includes the mandate for annual inspections of PMA by the crew to ensure safety and compliance.
The IMO’s revisions stem from concerns regarding the condition of access means, particularly PMA in tanks and holds. The new guidelines stipulate that both portable and permanent access means must undergo annual inspections, as outlined in the Ships Structure Access Manual. However, there are practical challenges in conducting these inspections within cargo tanks on oil tankers, which are typically sealed and maintained in an inert atmosphere. Inspecting these areas necessitates gas-freedom and subsequent re-inerting, a process that is both time-consuming and environmentally impactful.
Additionally, under SOLAS Regulation II-1/3-13.3, all anchor handling winches and related equipment must be operationally tested and maintained according to IMO standards. Shipowners and operators are advised to adhere to manufacturer guidelines and ensure that maintenance manuals are accessible. Factors contributing to PMA deterioration include contact damage during cargo operations and corrosion from atmospheric exposure, though oil tanker cargo tanks are less affected due to their inert environments.
While the unified interpretations are not obligatory, they can be subject to the flag Administration’s discretion. Lloyd’s Register recommends that shipowners and operators seek dispensation from their flag Administration, providing necessary documentation such as maintenance schedules and inspection reports. If granted, this dispensation should be documented in the Ship’s Structure Access Manual.
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