At its 110th session (June 2025), the Maritime Safety Committee (MSC) addressed a long-standing issue: the divergent interpretations of SOLAS regulations II-2/13.4.1 and 13.4.2 concerning escape arrangements from the “lower part” of machinery spaces.
Why does this matter? Because during Port State Control (PSC) inspections, the lack of a uniform definition has often led to inconsistent findings — and, in some cases, even detentions — despite arrangements already being approved by the flag State.
The MSC, based on the report of SDC 11, confirmed that “lower part of the space” should be understood as either:
- the lowest deck level, or
- a platform or passageway within the machinery space.
This clarification is significant for both shipowners and inspectors. However, a formal amendment to SOLAS will only be discussed in the 2026–2027 biennium, leaving a period of uncertainty in the meantime.
👉 My professional take
From a surveyor’s perspective, this highlights three critical points:
- Risk of PSC discrepancies – Shipowners remain exposed to differing PSC interpretations until SOLAS is amended.
- Importance of Flag Approval – Flag Administrations and their Recognized Organizations must ensure robust approval of escape arrangements, serving as the primary reference during inspections.
- Need for Pragmatism – PSC officers are encouraged to accept Flag-approved designs, avoiding unnecessary detentions driven by semantics rather than safety.
In practice, vessels should ensure documentation of flag approvals is readily available on board and crews are briefed to explain the arrangements clearly during PSC inspections.
Until the regulatory amendments are adopted, proactive documentation and transparent communication remain the best defense against inconsistent enforcement.
🔗 At Marine Surveyor Consultant Sagl, we continuously monitor regulatory developments to support our clients in minimizing compliance risks and ensuring safe, practical escape arrangements on board.
Escape Arrangements in Machinery Spaces: Clarifying SOLAS II-2/13
