Date: 2025-05-13Category: DGS CircularState: Union GovernmentCountry: India
Guidelines for the Safe Transfer of Seafarers, Pilots etc. using Pilot ladders, Gangways or Combination ladder etc. to / from a service boat or launch or a barge or crafts
**Executive Summary**
DGS Circular No. 19 of 2025, issued on May 13, 2025, by the Directorate General of Shipping, addresses the safe transfer of seafarers and pilots using ladders and gangways. The circular highlights two incidents at Ulsan Anchorage and Port Said resulting in fatalities, emphasising the need for stronger safety measures and compliance with existing regulations.
**Key Points / Main Content**
* **Incident Description:**
* **Incident 1 (Ulsan Anchorage, May 24, 2024):** A seafarer fell into the sea during disembarkation due to rough seas, misalignment, and exhaustion, eventually resulting in death.
* **Incident 2 (Port Said, February 15, 2025):** A seafarer fell into the water when a service boat swung away due to sea conditions, leading to disappearance and a tragic outcome.
* **Cause Analysis:**
* Lapses in adhering to critical safety procedures during disembarkation.
* Inadequate risk assessment of prevailing sea conditions.
* Insufficient awareness of environmental conditions.
* Failure to follow established safety protocols.
* Improper use of PPE.
* **Lessons Learned:**
* Comply with safe transfer procedures and risk assessments.
* Ensure proper equipment rigging and maintenance (pilot ladder maximum age 24 months, man ropes 12 months).
* Avoid time pressure and carefully evaluate weather conditions.
* Consider the human element, including fitness and experience.
* Use proper PPE, including life jackets, and avoid carrying baggage during transfers.
* Inspect ladders and equipment, assign experienced personnel, and maintain 3-point contact.
* Implement a safety stop work policy and ensure emergency preparedness with regular drills.
* **Safety Recommendations:**
* Industry to note gaps in compliance with dock safety regulations.
* Vessel owners, technical managers, and RPSL agencies to review safe transfer procedures and risk assessments.
* Use GPS-enabled Personal Locator Beacons (PLBs) for personnel.
* Ship Masters to carry out regular safety drills.
* Avoid creating a sense of urgency during disembarkation.
* Apply the Three-Point Contact Rule and provide Man Overboard (MOB) Training.
**Impact Analysis**
**Industry (Ports/Dock Authorities)**
* **Impact:** Must recognize the importance of ensuring that pilot transfer crews are fully aware of and committed to safe operating practices and verifying that all craft crew are properly briefed, trained, and experienced for such operations.
* **Action Required:** Regularly review procedures to include adequate handholds for safe transfers, availability of life jackets for all personnel, effective communication devices, and reliable survivor recovery arrangements.
**Vessel Owners, Technical Managers and RPSL agencies**
* **Impact:** Responsible for implementing and reviewing company's safe transfer procedures and ensuring compliance with SOLAS Chapter V, Regulation 23.
* **Action Required:** Ensure the use of boat/tug/barge is based on the learnings from the incidents and promote the use of GPS-enabled PLBs.
**Ship Masters**
* **Impact:** Directly responsible for the safety of crew and passengers during transfer operations.
* **Action Required:** Carry out regular safety drills, familiarize crew with emergency procedures, comply with SMS procedures, and discuss the circular's contents.
Key Entities Referenced
Guidelines for the Safe Transfer of Seafarers, Pilots etc. using Pilot ladders, Gangways or Combination ladder etc. to / from a service boat or launch or a barge or crafts.: The main topic of the circular, providing guidelines for the safe transfer of personnel between vessels and service boats.
Ministry of Ports, Shipping and Waterways: The governing body overseeing the Directorate General of Shipping (DGS).
SOLAS Regulation V/23: The international regulation related to pilot transfer arrangements, indicating the existing framework this circular supplements.
Merchant Shipping Act: The national legislation under which violations of safety requirements during personnel transfers will be penalized.
Directorate General of Shipping (DGS): The issuer of the circular, responsible for maritime safety and regulations in India.
File No: 25-19012/5/2025-NT-DGS(comp. no.34250) Date: 13.05.2025
DGS Circular No. 19 of 2025
Casualty Investigation Branch Circular No. 03 of 2025
Guidelines for the Safe Transfer of Seafarers, Pilots etc. using Pilot ladders,
Gangways or Combination ladder etc. to / from a service boat or launch or a barge or
crafts.
This safety circular is issued to highlight the two unfortunate incidents occurred in the recent past at
Ulsan Anchorage (South Korea) and Port Said (Egypt) which resulted in the tragic loss of lives of the
two Indian seafarers. This safety circular is to be read in conjunction with any existing safety circular
issues by individual ports, terminals in addition to the SOLAS Regulation V/23 as amended on pilot
transfer arrangements.
Personnel transfers using a passenger transfer basket, pilot ladder, gangway or combination ladder
to/from a service launch or a barge are high risk operations and compliance with safe work
procedures are of paramount importance to avoid fatal consequences, loss of lives, damages etc.
A. Incident Description
1. Incident No. 1: On 24th May 2024, at Ulsan Anchorage, one of the seafarers signing-off from a
Singapore flagged vessel prepared to disembark through the starboard combination ladder.
While the seafarer descended through the ladder and reached the pilot ladder, the service boat
attempted to come alongside, but rough seas and heavy swells hindered proper alignment with
the pilot ladder. Despite these conditions, the transfer continued. While attempting to disembark
into the service boat, the seafarer lost his grip on the pilot ladder and fell into the sea. Though the
seafarer could initially grab a lifebuoy and rope deployed by the crew, panic and exhaustion
caused him to lose his hold and was swept away by the strong current.Service boat reversing
to the location where
the off signer waited to
board the pilot ladder
Figure 1: Illustration of the weather and sea Figure 2: Indicating the service boat angle of approach. Source: TSIB report
conditions relative to PH at 0800 Hrs.
(Source: TSIB report)
The service boat was unable to rescue him due to the rough seas. He was later recovered by the
Korea Coast Guard in an unconscious state and taken to the hospital, where he was declared
dead upon arrival.
2. Incident No. 2: On 15th February 2025, at Port Said (Egypt), a seafarer disembarking from a
Gabon flagged vessel onto a service boat via a combination ladder lost his balance when the
boat suddenly swung away from the ship's side due to sea movements and fell into the water.
Despite rescue efforts, including throwing lifebuoys, lowering the gangway, and deploying a
lifeboat, the seafarer was unable to secure any assistance. He drifted toward the aft of the vessel
and eventually disappeared from sight. The service boat, which had been tracking him, later
reported losing contact, leading to a tragic outcome.
B. Cause Analysis
Both incidents revealed significant lapses in adhering to critical safety procedures during the
disembarkation process, resulting in seafarers falling into the sea.
In the first case, the prevailing sea conditions were not properly assessed. The rough seas led to a
misalignment between the pilot ladder and the service boat, creating a highly unsafe environment
for personnel transfer. Despite the visible risk posed by strong swells, the operation continued
without implementing any safety interventions. The disembarking seafarer, who was not wearing
appropriate PPE, lost his grip and fell into the water.
In the second incident, similar rough sea and swell conditions caused the service boat to swing
away at a critical moment during the transfer operation. This sudden movement disrupted the
seafarer's balance, resulting in fall into the sea. In both cases, poor coordination and lack of
preventive action in response to adverse sea conditions played a direct role in the accidents.
These incidents highlight the dangers associated with unstable sea states and several systemic
safety failures, including inadequate risk assessment, insufficient awareness of environmentalconditions, failure to follow established safety protocols, and improper use of PPE. They
emphasize the urgent need for stronger safety measures, including proactive planning, better
coordination between ship and service boat crews, and comprehensive training tailored to transfer
operations in varying sea conditions.
It is equally important that service boat operators remain fully aware of and responsive to sea
conditions during such operations. The first incident occurred in daylight, while the second took
place at dawn, drawing attention to the additional risk posed by poor visibility. In such cases,
proper illumination of the pilot ladder is critical to ensuring safe disembarkation.
C. Lessons Learned:
1. Safe Work Procedures: Always comply with the company’s safe transfer procedures and risk
assessment for embarking and disembarking personnel via service boat/barge.
2. Equipment Rigging and Maintenance: Ensure that the means of embarkation/ disembarkation
are properly rigged and maintained as per regulatory requirements, manufacturer’s instructions
and company procedures. Maximum age of the pilot ladder should be 24 Months, maximum age
of the man ropes used with Pilot ladder 12 months. If the condition of the Pilot Ladder or Man
Ropes are not good, it must be replaced immediately.
Figure 3: Illustration of a seafarer disembarking from a vessel through a pilot ladder with inadequate PPE
3. Time Pressure: Avoid scheduling crew changes within tight operational timelines like ETA
deadline, where there is an inherent urgency exists to complete the transfer operation quickly,
compelling to cut corners.
4. Weather Conditions: Evaluate the adverse effects of existing weather and forecasted weather
conditions, with particular attention to factors such as wind speed, swell height, and sea state,
which may significantly impact safe transfer operation. While in doubt, be on the safety zone andpostpone transfers during adverse weather conditions. If required, move the operations in
sheltered areas or provide an adequate lee to facilitate safe transfer.
5. Human Element: Consider the physical fitness, experience and confidence of the person
embarking / disembarking especially those disembarking soon after completion of long work hours
on board. Familiarization and toolbox meeting: Carry out a toolbox meeting with all relevant crew
explaining the hazards, safeguards, means of communication etc.
6. Personal Protective Equipment (PPE): Transfer personnel must wear life jackets and should
not carry backpacks or baggage during the transfer. Transfer the baggage or other items using a
heaving line. Both the victims were not wearing life jackets at the time of incident. Life jacket could
have kept the victim afloat even after falling in water which could have helped in rescue.
7. Operational Safety: Always inspect ladders and equipment to ensure they are not stained with
oil, grease. This inspection to be done prior to rigging. Assign experienced person to supervise
the operations and ensure clear communication between ship and service launch. During the
transfers, always maintain 3-point contact and keep the body weight near to the ladder to prevent
it from swinging. When transferring between a pilot ladder or a gangway and boat, it is crucial to
always use the available handholds on the vessel /boat to maintain stability and prevent falls,
especially when crossing over between the two platforms; make sure to firm grip the handholds
before stepping onto or off the ladder. It is crucial to stay alert to your surroundings. Listen to the
instructions for launch personnel as they will instruct when it is safe to transfer. Adequate lighting
of the transfer area is also very important.
8. Safety Culture and Stop Work Policy: Implement company’s safety stop work policy when
unsafe acts or conditions are noticed, ensuring immediate attention to hazardous conditions.
9. Emergency Preparedness: Crew must be familiar with the operations and aware of required
emergency actions in invent of man overboard (MOB) event by way of regular drills, including
raising of alarm, reporting procedures and rescue measures.
10. Emergency Preparedness: Crew must be familiar with the operations and aware of required
emergency actions in invent of man overboard (MOB) event by way of regular drills, including
raising of alarm, reporting procedures and rescue measures.
D. Safety Recommendations
1. Industry to take Note of Gaps in Compliance
Compliance with dock safety regulations lies with the respective port authorities and designated
safety officers. Pilot transfer procedures—whether involving a pilot boat, tug, barge, or service
launch—are critical to maintaining uninterrupted vessel operations, as berthing and un-berthing
depend on the safe movement of pilots. Ports must recognize the importance of ensuring that pilottransfer crews are fully aware of and committed to safe operating practices. All passenger and
pilot transfers should be conducted with safety as the primary concern and only in calm weather
conditions. Port safety officers must verify that all craft crew are properly briefed, trained, and
experienced for such operations. The Code of Safe Working Practices may be used as a guiding
reference for compliance. Service launch operators should regularly review their procedures to
include adequate handholds for safe transfers, availability of life jackets for all personnel, effective
communication devices, and reliable survivor recovery arrangements. It is hereby emphasized
that any attempt by the Ship Owners/ Ship Managers/ RPSL Agencies/ Port Authorities/ Ship
Masters/ Pilots/ Seafarers to carry out passenger and pilot transfer operations in unfavorable
weather conditions without proper safe guards will be considered as a serious violation of safety
requirements and necessary penal action shall be initiated against the persons involved in
accordance with the provisions of the Merchant Shipping Act.
2. Vessel owners, Technical Managers and RPSL agencies:
Ship owners, managers and RPSL agencies to review the company's safe transfer procedures
and risk assessment for embarking and disembarking personnel via pilot ladder, combination
ladders, and while using services of boat/tug/barge based on the above learnings. Vessel owners
and tech managers shall ensure SOLAS Chapter V, Regulation 23 are complied with.
1
GPS-enabled Personal Locator Beacons (PLBs): In the interest of enhancing personnel
safety during transfers to and from ships, it is strongly recommended that all pilots and
transferring seafarers be equipped with GPS-enabled PLBs. These devices serve as vital
emergency tracking tools that can significantly expedite search and rescue efforts in the event of
a fall overboard or any other incident during transfer operations. The real-time location capability
of GPS PLBs ensures immediate identification of the distressed individual's position, improving
survival chances and response efficiency. Incorporating this equipment into standard transfer
protocols reflects a proactive safety culture and aligns with international best practices for
safeguarding maritime personnel.
3. Ship Masters
Master should carry out regular safety drills to familiarize crew in stopping the operations,
responding to an emergency while passenger or pilot transfer is in progress. Compliance with
SMS procedure and other company guidelines and contents of this circular is to be discussed and
followed.
1 Regulation 23 - Pilot transfer arrangementsAvoid holding personnel on board till the departure of vessel and disembarking into a boat prior
departure creates a sense of urgency among personnel to get down into boat “come what may”.
This kind of attitude is a clear recipe for dangerous incidents.
Fresh risk assessment is to be carried out if there are any changes in conditions prevailing at the
time of planning of operation. inculcate habit of use of wearing PPE during transfer whether for
going ashore or signing off from a vessel
Three-Point Contact Rule: Maintaining three points of contact (e.g., two hands and one foot or
two feet and one hand) when using ladders or handholds is a globally recognized safety practice
to minimize accidents during transitions
Man Overboard (MOB) Training: Always keep in mind Pilot Transfer, Passenger Transfer
poses a potential threat of man Overboard situation, therefore emergency preparedness plays a
pivotal role in saving lives. Crews must be trained in quick rescue actions which can dramatically
improve chances of survival in such events.
(Capt. Harinder Singh)
Nautical Surveyor and Dy. Director General of Shipping (Tech.)
To,
All stakeholders through the DGS Website
Ship Owner / Ship Operators / Ship Manager / Ship Masters