Understanding SOLAS Chapter II-2 Fire Safety Requirements
One of the key fire safety objectives of SOLAS Chapter II-2 is to “provide adequate and readily accessible means of escape for passengers and crew.” To comply with SOLAS Regulation II-2/13, one solution for means of escape from machinery spaces is the installation of a vertical escape trunk from the “lower part of the space.”
According to IMO MSC.1/Circ.1511, “the lower part of the space should be regarded as the lowest deck level, platform, or passageway within the space.” This interpretation is essential for shipowners, technical operators, and surveyors to ensure proper escape arrangements.
Port State Control (PSC) Inspections and Common Deficiencies
Recently, PSC inspections in Asia have flagged deficiencies in ships built after the implementation of IACS UI SC277 and MSC.1/Circ.1511. Specifically, non-compliant engine room escape trunks that do not extend to the lowest level of the engine room have been noted. Some vessels have instead installed short, inclined stairs leading from the bottom level to the lowest escape trunk door, which has resulted in deficiencies being raised by PSC inspectors.
Additionally, PSC inspections have required ship crews to demonstrate the effective evacuation of an injured crew member from the lowest level of the engine room to the escape trunk, as per SOLAS Reg. III/19.3. In cases where the drill was deemed unsatisfactory, deficiencies were recorded. Procedures for conducting PSC inspections, including rescue drills, are outlined in IMO Resolution A.1185(33).
IMO Discussion on Escape Trunk Interpretation
A recent IMO Sub-Committee on Ship Design and Construction (SDC 11) reviewed a proposal to amend MSC.1/Circ.1511 by allowing escape trunks to be positioned up to 2.3m from the lowest level of the engine room. However, this request was rejected, as it was deemed beyond the scope of an interpretation. The sub-committee concluded:
- The lower part of the space should be interpreted as the lowest deck level, platform, or passageway.
- The majority of IMO member delegations agreed that the interpretation was not intended to mean “whichever is lowest.”
- IMO Sub-Committee III 11 (scheduled for July 2025) will consider potential guidance to harmonize PSC activities.
Recommended Actions for Shipowners and Operators
For vessels subject to IACS UI SC277 and MSC.1/Circ.1511, where the escape trunk does not extend to the lowest level of the engine room, shipowners and operators should take the following steps:
Technical Justification for Escape Trunk Arrangement
- Develop a technical justification explaining why the escape arrangement does not extend to the lowest platform.
- The justification should be reviewed by the flag Administration or its Recognised Organisation (RO).
- Justifications may include:
- Structural constraints, such as hull lines, stiffening arrangements, or bulkheads.
- Obstructing equipment, such as shafts, stern seals, or maintenance zones.
- Operational feasibility, ensuring the escape remains practical and effective.
- The justification should demonstrate how the as-fitted arrangements provide a safe escape, considering:
- The inclined ladder width and accessibility.
- Adequate platform area at the escape entrance.
- Ease of movement for crew members during an emergency.
- This document should be kept onboard for presentation during PSC inspections or audits.
Enhancing Crew Preparedness and SMS Compliance
- Ship operators should update their Safety Management System (SMS) to include procedures for conducting rescue drills specific to engine room evacuations.
- Crew members should undergo regular training and practice evacuation drills to ensure compliance with PSC requirements.
- Drill records should be maintained as per the company SMS to demonstrate compliance.
Need Assistance? Contact Our Maritime Experts
For professional guidance on SOLAS compliance, PSC inspections, or developing a technical justification for your vessel’s escape arrangements, get in touch with our team. Our maritime consultants are here to help ensure your fleet meets regulatory requirements while maintaining the highest safety standards
