PSC deficiency code 18425: Access / structural features (ship)
Area 18 Maritime Labour Convention, 2006
Code 18425 is an MLC health and safety code about the ship as a workplace: how seafarers get around it and what in the structure can hurt them on the way. The inspector writing it has seen something that could make a person fall, trip or hit their head during ordinary work. Railings and walkways on exposed decks also have a load line code (03103), and the pilot ladder has its own SOLAS code (10101), though inspectors sometimes write a damaged pilot ladder under 18425. Read the text on the Form B.
What the inspector looks at
Most of this is noticed on the way to something else.
- Handrails and guardrails present, secure and not wasted, with chains or bars across openings
- Ladders with every rung intact, straight and firmly fixed, including the pilot ladder as a means of access
- Engine room floor plates and gratings complete and secured
- Open manholes and deck openings guarded or covered
- Pipes and raised edges across walkways removed or marked as trip hazards
- Low beams and other headroom obstructions marked or padded
Common findings
- Guardrail on engine room upper platform missing
- Floor plate missing near main engine
- Rungs of vertical ladder to cargo hold bent and corroded
- Pilot ladder not as required, one step missing
- Handrail of stairway to steering gear room loose
- Pipes across main deck walkway not marked as trip hazard
- Open manhole on deck not guarded
The rule behind it
MLC 2006 Regulation 4.3 requires flag States to make sure seafarers live and work in a safe and hygienic environment. Standard A4.3 requires the flag's laws to cover reasonable precautions against occupational accidents, including injury from equipment and machinery, and requirements for inspecting, reporting and correcting unsafe conditions. Guideline B4.3.1 names structural features of the ship, including means of access, among the subjects national guidance should address.
Action codes you are likely to see
A floor plate refitted or a manhole guarded during the visit is often marked 10. Repairs to rails, ladders and gratings that need welding or parts are usually 17, since people work there daily, and minor items may get 16. Under MLC Standard A5.2.1 a ship can be held when conditions are clearly hazardous to seafarers' safety, so a missing rail over a deep drop in a working area could lead to 30 if it can't be fixed before sailing. See action taken codes.
How to close it
Most items are crew work: refit gratings and floor plates, rig temporary rails, mark trip hazards and pad low beams. Record the work in the planned maintenance system, update the risk assessment for the area and raise it at the next safety committee meeting (MLC requires a committee on ships with five or more seafarers). Keep photos, the work order and the committee minutes with the Form B. A pilot ladder written under this code is closed the same way as under 10101: a certified replacement, rigged as the IMO poster shows. Related: pilot ladders, mooring ropes and wires, deck corrosion and ISM.