How a Tragic Pilot Ladder Accident Led to Enhanced Protections

 

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.   

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.