Why This Matters More Than Ever
A recent update from the International Maritime Organization is quietly reshaping how vessels manage Permanent Means of Access (PMA)—and the implications are far from minor.
Triggered by a near-miss incident involving unsafe inspection platforms, the revised interpretation of SOLAS Regulation II-1/3-6 (via MSC.1/Circ.1572/Rev.2) introduces stricter inspection, documentation, and accountability requirements.
For operators of tankers and bulk carriers, this is not just a compliance update—it’s a risk exposure issue.
Who Is Affected
The revised requirements apply to:
- Oil tankers ≥ 500 GT
- Bulk carriers ≥ 20,000 GT
- Built on or after 1 January 2006
- Inspections conducted from 1 January 2025 onwards
What Has Changed – Operational Impact
- More Structured and Frequent Inspections
- All PMA systems (including ladders, platforms, fittings) must be inspected annually
- Inspections must be recorded in Part 2 of the Ship Structure Access Manual (SSAM)
- Pre-entry checks are now mandatory before accessing any enclosed space using PMA
Important clarification:
Annual inspection does not require opening cargo tanks every year. Inspections must be carried out when access is already planned and feasible.
- Damage Assessment Is Now Mandatory
If any of the following is observed:
- Coating breakdown
- Corrosion or material wastage
- Structural degradation
A formal assessment must determine whether safety is compromised.
If classified as substantial damage, it must be:
- Clearly documented in the SSAM
- Tracked until rectification
- Enhanced Record-Keeping Requirements
Inspection records must now include:
- Date of inspection
- Name and rank of inspector
- Signature/confirmation
- Areas inspected
- Condition status (safe / deteriorated / damaged)
- Details of repairs carried out
These records must be available to surveyors prior to inspections
Missing or incomplete records = potential finding during audits or class surveys
SSAM: Not Just a Manual Anymore
The Ship Structure Access Manual (SSAM) is now a live compliance document.
Shipowners must:
- Update the SSAM to reflect new IMO requirements
- Align with latest industry templates (e.g. IACS Rec. 90 Rev.2)
- Ensure consistency between:
- Procedures onboard
- Actual inspection practices
- Recorded evidence
Critical point:
Even if re-approval is not required, surveyors will verify alignment during future surveys.
The Real Risk: Compliance vs. Safety Exposure
These changes are not bureaucratic.
They address a recurring gap:
Access arrangements are often assumed safe—but rarely verified systematically.
Failure to comply may lead to:
- PSC deficiencies
- Class observations
- RightShip / SIRE 2.0 negative impact
- Increased liability in case of incident
How Marine Surveyor Consultant Can Support You
At Marine Surveyor Consultant, we support shipowners and managers in:
- Gap analysis of PMA compliance vs IMO requirements
- Review and upgrade of SSAM documentation
- Onboard pre-survey inspections
- Identification of hidden structural risks
- Alignment with:
- SOLAS
- OCIMF expectations
- SIRE 2.0 readiness
Final Takeaway
The revised PMA requirements introduce a simple but powerful shift:
From “installed access” → to “verified safe access throughout vessel life.”
Ship operators who act early will not only remain compliant—but significantly reduce operational risk and inspection exposure.
Want to verify your fleet’s compliance before the next inspection?
Contact Marine Surveyor Consultant today and request a targeted PMA compliance review.
