Because IMO’s process for taking up issues is purposefully deliberate, it took until November 2022 for PTA to be formally placed on IMO’s agenda. APA Executive Director-General Counsel, Clay Diamond, served on the U.S. Delegation to Maritime Safety Committee 106, while Captain Jorge Viso, APA President served on the IMPA delegation. Viso and Diamond would continue to represent the interests of U.S. pilots at IMO throughout the multi-year process of strengthening PTA requirements.
In May 2023, IMO’s Subcommittee on Navigation, Communication, and Search and Rescue (NCSR 10) made a pivotal decision regarding the future of PTA standards. In response to proposals by IMPA and IMO member states, NCSR 10 agreed that all PTA standards should be mandatory and contained in a single “performance standard,” as opposed to the existing structure of a mandatory SOLAS regulation coupled with IMO recommendations. NCSR 10 authorized a "correspondence group” to meet via email between NCSR sessions to begin drafting V/23 amendments and the Performance Standards. IMPA and APA participated in this correspondence group.
At NCSR 11 (June 2024), deliberations concluded on amendments to SOLAS V/23 and the Performance Standards. Within this new international PTA regulatory scheme, the revised SOLAS V/23 is now restricted to essential provisions, such as application dates, while the technical specifications for PTAs are delineated within the
mandatory Performance Standards. The updated PTA safety framework includes key improvements such as:
• Application to existing ships with no “grandfather clause;”
• Application to SOLAS and non- SOLAS ships;
• Third party type approval of pilot ladders, manropes, and means of securing pilot ladders deployed at intermediate lengths;
• Clarification and strengthening of the requirements for combination trapdoor arrangements;
• A maximum service life for pilot ladders and manropes, including spares, of 36 months from the date of manufacture;
• Strengthening requirements for securing pilot ladders deployed at intermediate lengths;
• Making the “pilot mark” (indicating the maximum climb of 9m) on ships’ hulls mandatory;
• Increasing breaking strength requirements of strongpoints, shackles and securing ropes; and
• Explicit recognition of the right of pilots to refuse to use an unsafe or noncompliant PTA.
While NCSR 11 agreed on the text of the amended V/23 and Performance Standards, both then had to be
approved at MSC 109 and then adopted at MSC 110. In December 2024 MSC 109 did approve the revised PTA requirements. At MSC 110 in June 2025, after several days of a MSC 110-established drafting group’s effort to finalize the text, IMO adopted the amended V/23 and Performance Standards.
Because SOLAS is an international convention with mandatory rules for global shipping, sufficient notice of any amendments must be given to allow ships time to comply. As such, the entry into force of the new PTA requirements will be phased in beginning on January 1, 2028 and concluding by April 1, 2030. Considering this unavoidable delay, IMPA successfully advocated for an IMO circular encouraging governments to voluntarily implement the PTA requirements before the entry into force date.
This successful outcome required constant communications with IMPA, regular meetings with the USCG, and numerous meetings of IMO committees, subcommittee, and other subgroups. APA applauds the USCG for its support for enhancing PTA safety and for working with APA prior to and during IMO deliberations. This crucial project also benefited immensely from the work of IMPA, and APA thanks Captain Simon Pelletier and Mr. Matthew Williams for their persistence, support, leadership, and technical expertise. This major safety milestone would not have been possible without IMPA’s efforts.
THE REPORT | SEP 2025 | ISSUE 113 | 117
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