How a tragic pilot ladder accident led to regulation changes
In a milestone for maritime pilots’ safety, on June 26, 2025, the International Maritime Organization (IMO) significantly improved Pilot Transfer Arrangement (PTA) requirements by adopting amendments to International
Convention for the Safety of Life at Sea (SOLAS) regulation V/23, as well as new mandatory PTA Performance Standards. The Performance Standards are incorporated into SOLAS, giving them the full force of international law.
The path to this achievement began on a tragic day more than five years ago. On December 30, 2019, Captain Dennis Sherwood, a New York State- licensed pilot, was killed in a fall while embarking a container ship using a combination arrangement with a trapdoor. This arrangement did not comply with either V/23 or IMO Assembly Resolution A.1045(27) (“Recommendation on Pilot Transfer Arrangements”), the relevant international standards. While advocating for pilot safety has always been a key role for the American Pilots’ Association (APA), Captain Sherwood’s death was an impetus for APA to immediately redouble its domestic and international efforts in this area.
APA’s domestic strategy included communications with shipping companies, reaching out to state pilot oversight authorities, and working with the U.S. Coast Guard (USCG). In January 2020, APA sent letters to shipping lines stressing the necessity to provide compliant PTAs. These letters also explained existing requirements and recommendations for the three main types of PTAs – a
single pilot ladder for climbs 9m or less, and for climbs over 9m, a pilot ladder combined with a platform (with or without a trapdoor) and an accommodation ladder.
This prompted several shipping lines to improve their PTAs. In January 2020, APA followed up with an alert to state pilot oversight authorities that explained the rules and asked them to reiterate to pilots their right to refuse to use a noncompliant PTAs. It also urged them to remind shipping interests of the obligation to provide compliant PTAs. Numerous state pilot oversight authorities responded to APA’s requests.
APA also reached out to the USCG to ask for assistance. In January and February 2020, APA met with USCG officials to discuss PTA safety. While the USCG’s actions were delayed while Captain Sherwood’s incident was under investigation, the agency eventually issued a safety bulletin and supporting PTA regulatory efforts at IMO.
In addition to working to improve PTA at home, APA reached out to
the International Maritime Pilots’ Association (IMPA), which was able to get PTA on the IMO agenda. IMPA President, Captain Simon Pelletier, and current IMPA Secretary General, Mr. Matthew Williams, were responsive to APA’s requests and particularly effective in advancing pilot safety at IMO. On January 17, 2020, Captain Pelletier made a powerful intervention at the 7th Session of IMO’s Subcommittee on Navigation, Communication, and Search and Rescue (NCSR 7).
Captain Pelletier explained that Captain Sherwood was killed while using a combination trapdoor arrangement which “involved a trapdoor in the platform of the accommodation ladder with the pilot ladder hanging from a bar near the bottom of the platform and the top step of the pilot ladder significantly below the level of the platform. This requires a pilot to pull himself or herself up through the trapdoor while twisting to get a secure footing on the platform.” He noted that this arrangement clearly did not meet IMO’s requirements and urged all parties to help make PTA safer.
116 | ISSUE 113 | SEP 2025 | THE REPORT
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