PSC deficiency code 10101: Pilot ladders and hoist/pilot transfer arrangements
Code 10101 covers everything a pilot uses to get on and off the ship: the pilot ladder, the accommodation ladder when it's used in combination, the point where the pilot steps onto the deck and the safety gear kept there. The doubt behind it: could a pilot climb this arrangement today without a real chance of falling? Some inspectors write a damaged pilot ladder under the MLC access code 18425 instead; the ladder needs the same fix either way.
What the inspector looks at
Inspectors often hear about the ladder from the pilot who brought them in, or they climb it themselves.
- Ladder condition: steps cracked, loose or painted over, side ropes chafed, spreaders in place, ladder lying flat against the hull
- Securing to strong points on deck, not to rails or the handhold stanchions
- The ladder record: date the identified ladder went into service and any repairs
- Combination arrangement when the climb is over 9 m: accommodation ladder leading aft, lower platform level, pilot ladder secured alongside
- Deck access: bulwark ladder or gateway, handhold stanchions, a clear landing area
- Lighting at night, a lifebuoy with a self-igniting light and a heaving line ready
- A responsible officer attending, in radio contact with the bridge
Common findings
- Pilot ladder steps damaged, several steps loose
- Pilot ladder side ropes secured to ship's rail
- Side ropes worn, ladder not replaced
- No record of pilot ladder date in service and repairs
- Combination arrangement not rigged as required
- Pilot boarding area not illuminated, lifebuoy with self-igniting light not ready
- Handhold stanchions loose at bulwark ladder
The rule behind it
SOLAS chapter V, regulation 23 sets the requirements for pilot transfer arrangements, and IMO resolution A.1045(27), as amended, gives the detailed recommendations on construction, rigging and access. The required boarding arrangements poster (MSC.1/Circ.1428) shows the layouts. Ladders are certified by the manufacturer, usually against ISO 799. Mechanical pilot hoists are no longer allowed, which is why the old title still mentions them. IMO has adopted a revised regulation V/23 with mandatory performance standards (resolution MSC.576(110)), expected to enter into force on 1 January 2028 with phased implementation.
Action codes you are likely to see
A ladder secured to the wrong point and re-rigged on the spot is often marked 10. A damaged ladder that needs replacing usually gets 17, because the next pilot will use it on departure. Missing records may be written as 16 or 17. An arrangement that puts the pilot in real danger can be treated as a ground for detention (30), especially with no spare ladder on board. See action taken codes.
How to close it
The chief officer replaces or repairs the ladder, ideally from a certified spare already on board, and re-rigs it as the IMO poster shows. Keep the new ladder's certificate, the updated ladder record and photos of the rigged arrangement with the Form B. Related: lifebuoys and access and structural features.