The LadderWatch Taxonomy

47 deficiency codes, structured by when they become visible.

LadderWatch organizes pilot transfer arrangement deficiencies into 47 codes across 3 phases, ordered by when each deficiency becomes visible during the boarding sequence. This is the complete reference for all deficiency codes used in the LadderWatch reporting system.

Did you receive a LadderWatch notice?

If a pilot association sent you a deficiency notice or letter that references this page, here is the context. LadderWatch is a reporting platform used by maritime pilots to document the condition of pilot transfer arrangements: the ladders, gangways, and combination rigs pilots use to board and disembark vessels. When a pilot observes a deficiency, it is recorded against one of the 47 codes on this page, each tied to its governing regulation.

Your notice lists the specific codes observed aboard your vessel, the severity of each, and the compliance status assigned by the boarding pilot: Compliant, Deficient - Used (deficiencies were found and the pilot used the arrangement), or Deficient - Refused (the pilot declined to board or disembark on the arrangement).

Corrective action means rigging arrangements that meet SOLAS Regulation V/23 and IMO Resolution MSC.576(110). For each code below, the Required line states exactly what compliance looks like and the regulatory citation points to the governing rule. Many notices are generated straight from a pilot's structured report, so the deficiencies, requirements, and photos you received come directly from the boarding. Questions about a notice you received should be directed to the pilot association that issued it.

CATASTROPHICStructural failure causing fall.
SEVEREHigh fall risk.
MODERATEContributes to risk; not a direct fall cause.

Severity is consequence-based, not frequency-based.

Code numbers reflect the order items were added to the taxonomy; on this page they are grouped by the three phases of a boarding, not in strict numeric order.

Citation note: SOLAS V/23 and IMO Resolution A.1045(27) are current authority and guidance. MSC.576(110) is the adopted performance standard that takes effect with the SOLAS V/23 amendments on 1 January 2028 and is shown where it clarifies or will supersede existing requirements.

PHASE 1

Approach

Observable from pilot boat before coming alongside

1.1

Ladder outside midships half-length or rigged near overside discharges

SEVERE

Required: The pilot ladder must be sited within the parallel midship body (or as near midships as practicable) and clear of all overboard discharges, so the pilot boat can lie safely alongside.

Regulatory: SOLAS V/23 §3.3.1.1.2; MSC.576(110) §12.1.2; for combination lower-platform placement: SOLAS V/23 §3.3.2; MSC.576(110) §13.1.3

If unaddressed: Pilot boat may be forced to work in a less sheltered area of the hull, increasing relative motion, hull contact, and fall risk during transfer.

1.2

Height of climb exceeds 9m but no accommodation ladder present

CATASTROPHIC

Required: Where the climb exceeds 9 m, a combination arrangement (accommodation ladder with pilot ladder) or another equally safe means must be used. A pilot-ladder-only arrangement is permitted only for climbs of 1.5 to 9 m.

Regulatory: SOLAS V/23 §3.2 and §3.3.2; MSC.576(110) §3.2

If unaddressed: Excessive single-ladder climb creates extreme fatigue and fall risk; a combination arrangement is required when the height of climb exceeds 9m.

1.3

Combination lower platform less than 5m above water

CATASTROPHIC

Required: The accommodation-ladder lower platform must be at least 5 m above the waterline.

Regulatory: A.1045(27) §3.3; MSC.576(110) §13.1.4

If unaddressed: Pilot boat may be forced too close to the platform in a seaway; the platform, ladder, or boat can strike each other, creating crush and fall hazards.

1.4

Pilot ladder does not extend at least 2m above accommodation platform

SEVERE

Required: The pilot ladder must extend at least 2 m above the accommodation-ladder lower platform, with a 0.1 to 0.2 m horizontal distance between the ladder and the platform.

Regulatory: A.1045(27) §3.6; MSC.576(110) §13.1.7; trapdoor arrangements: MSC.576(110) §5.5.2.4 and §5.5.7.2

If unaddressed: No continuous climb or handhold through the transition; pilot must step off the ladder too early, creating a high fall risk.

1.5

Accommodation ladder too steep (over 45 degrees)

SEVERE

Required: The accommodation ladder must be long enough that its angle of slope does not exceed 45 degrees.

Regulatory: A.1045(27) §3.2; MSC.576(110) §5.1

If unaddressed: The transfer becomes a climb rather than a controlled passage; the pilot can lose balance on the accommodation ladder or at the platform.

1.6

Pilot ladder not resting against hull

CATASTROPHIC

Required: The pilot ladder must rest firmly against the ship's side for its whole length, not hang free over rubbing bands, fenders, or other features.

Regulatory: SOLAS V/23 §3.3.1.1.3; MSC.576(110) §12.1.3; trapdoor alignment: A.1045(27) §3.7 and MSC.576(110) §5.5.2.2

If unaddressed: Without firm contact against the hull, the ladder can twist, swing, or pull away under the pilot's weight, increasing loss-of-grip and fall risk.

1.7

Combination platform not secured to ship's side

CATASTROPHIC

Required: The accommodation-ladder lower platform must be horizontal and secured to the ship's side.

Regulatory: SOLAS V/23 §3.3.2; A.1045(27) §3.3; MSC.576(110) §13.1.3

If unaddressed: The lower platform can swing or shift as the pilot transfers, creating an unstable transition point and increasing fall or crush risk.

1.8

Side door: pilot ladder rigged from deckhead or access to deck obstructed

CATASTROPHIC

Required: For side-door access the pilot ladder must be secured to the deck or sill (not the deckhead), with adequate handholds and clear, unobstructed passage through the door.

Regulatory: SOLAS V/23 §4 and §5; MSC.576(110) §7.1, §8, §14.1, and §15.1.1.3

If unaddressed: Pilot may be forced to climb into an obstructed opening or step around unsupported structure; the transfer can become a squeeze point with no safe handhold.

1.9

Retrieval line leading aft, taut, tied below spreader, or fouling launch

MODERATE

Required: If a retrieval line is fitted it must be secured at or above the lowest spreader step and lead forward, clear of the pilot and of the pilot boat. A missing retrieval line is not itself a deficiency.

Regulatory: A.1045(27) §2.1.5; MSC.576(110) §12.1.5; MSC.1/Circ.1428/Rev.1 Annex, Non-Compliant Practices poster

If unaddressed: The retrieval line can foul the pilot ladder or pilot boat, pull the ladder off the hull, or create a trip or entanglement hazard during transfer.

1.10

Spreaders missing, too short, incorrectly positioned, or lashed instead of seized

SEVERE

Required: Spreader steps must be fitted to keep the ladder from twisting, correctly positioned, of adequate length, and held by seizing rather than lashings.

Regulatory: A.1045(27) §2.1.4; MSC.576(110) §4.2; ISO 799-1:2019

If unaddressed: The ladder can twist or collapse inward against the hull, making the climb unstable and increasing the chance of the pilot losing footing.

1.11a

Manropes missing or too short

MODERATE

Required: Two manropes must be provided when required by the pilot, secured to deck strong points and long enough to reach the embarkation point and the height of the handrails or bulwark.

Regulatory: SOLAS V/23 §7.1.1; MSC.576(110) Part A §11 and Part B §15.1.1

If unaddressed: Without manropes, the pilot has no secondary handhold while descending the ladder and will not be as able to time a quick descent to the pilot boat.

1.11b

Manropes outside 28-32 mm diameter

MODERATE

Required: Manropes must be not less than 28 mm and not more than 32 mm in diameter, mildew-resistant manila or material of equivalent strength, durability, elongation, and grip, and rigged as a pair.

Regulatory: SOLAS V/23 §7.1.1; MSC.576(110) Part A §11.1

If unaddressed: Manropes too thin or too thick cannot be gripped securely, especially with wet gloves, raising the risk of a fall.

1.11c

Manropes knotted, spliced, or joined

MODERATE

Required: Manropes must be a single continuous length on each side, free of knots, splices, or joins in the working length.

Regulatory: MSC.576(110) Part A §11.2

If unaddressed: Knots and splices create slip and snag hazards and mark a rope that may be damaged or improvised.

1.12

Inadequate lighting at night, ladder or transfer area

MODERATE

Required: Adequate lighting must illuminate the ladder, the ship's side, and the point of access during darkness.

Regulatory: SOLAS V/23 §8; SOLAS V/23 §11 as amended by MSC.572(110)

If unaddressed: Pilot cannot clearly see step condition, ladder alignment, or the deck transition; hazards may only become visible after the pilot is already on the ladder.

1.13

Lowest step at the wrong height (too high above the water, or too low or in the water)

SEVERE

Required: The lowest step must sit at the height requested by the pilot: clear of the water yet within safe reach of the pilot boat, neither so high it creates a fall risk nor in the water.

Regulatory: SOLAS V/23 §3.3.1.1.4; MSC.576(110) §4.5 and §12.1.6

If unaddressed: Pilot boat cannot place the pilot safely at the first step; pilot may have to jump, stretch, or transfer from an unsafe boat position.

1.14

Pilot ladder and manropes not rigged through the trapdoor aperture

SEVERE

Required: In a trapdoor combination, the pilot ladder and manropes must be rigged up through the trapdoor aperture and extend to the height of the handrail.

Regulatory: SOLAS V/23 §3.3.2; A.1045(27) §3.7; MSC.576(110) §5.5.2.1 and §13.2

If unaddressed: Pilot must leave the ladder and move sideways at height instead of climbing through a protected opening, creating a severe fall risk.

1.15

Accommodation ladder not leading aft

SEVERE

Required: The accommodation ladder must lead aft.

Regulatory: SOLAS V/23 §3.3.2; MSC.576(110) §13.1.2

If unaddressed: Pilot boat approach and transfer occur in a less protected orientation; the boat, ladder, and platform may move against each other unpredictably.

1.16

Fendering or rubbing bands obstructing pilot boat approach within 6m of ladder

SEVERE

Required: There must be at least 6 m of unobstructed ship's side around the ladder, clear of rubbing bands, fenders, or other features, so the pilot boat can lie safely alongside.

Regulatory: SOLAS V/23 §3.3.1.1.3; A.1045(27) §6; MSC.576(110) §9, §10, and §12.1.3

If unaddressed: Obstruction prevents the ladder from lying flat against the hull; the ladder can bridge, twist, or trap the pilot between the ladder and ship side.

1.17

Two pilot ladders joined together

CATASTROPHIC

Required: A pilot ladder must be a single continuous length. Two ladders must never be joined or shackled together to make up length.

Regulatory: SOLAS V/23 §3.3.1.1.4; A.1045(27) §2.2.1; MSC.576(110) §4.5 and §4.6; ISO 799-1:2019

If unaddressed: Connection points can shift, separate, or create uneven step spacing under load; the pilot may encounter a sudden weak point during the climb.

PHASE 2

Alongside & Climbing

Pilot boat alongside; pilot on the ladder

2.1

Missing permanent length markings or manufacturer tag

MODERATE

Required: The ladder must carry a permanent manufacturer identification mark and permanent length markings. From 1 Jan 2028 (MSC.576(110)): measuring marks at three-step intervals and maker's marks on the underside of the uppermost step and the lowest spreader step.

Regulatory: SOLAS V/23 §2.3 and §2.4; A.1045(27) §2.1.6; MSC.576(110) §3.5, §4.3, §4.4, and §30; ISO 799-1:2019

If unaddressed: Ladder identity, service records, depth marks, approval basis, and future service-life compliance may not be verifiable.

2.2

Steps not horizontal or not evenly spaced (310-350mm)

SEVERE

Required: Steps must be equally spaced 310 to 350 mm apart and must remain horizontal.

Regulatory: A.1045(27) §2.1.2.6-2.1.2.7; MSC.576(110) §4.1.5-4.1.6

If unaddressed: Uneven or sloped steps break the pilot's climbing rhythm and foot placement; a missed or tilted step can cause a fall.

2.3

Steps broken, painted, varnished, icy, or contaminated

CATASTROPHIC

Required: Steps must be sound, clean, and slip-resistant: not broken, painted, varnished, oily, iced, or contaminated. From 1 Jan 2028 (MSC.576(110)): no paint, varnish, or coatings on wooden steps.

Regulatory: SOLAS V/23 §2.1; A.1045(27) §2.1.2.1-2.1.2.4; MSC.576(110) §4.1.1-4.1.3 and §22; MSC.1/Circ.1428/Rev.1 Annex, Non-Compliant Practices poster

If unaddressed: Pilot may lose footing or grip on a damaged or slippery step; contamination can hide damage until weight is already on the ladder.

2.4

Steps secured with non-compliant hardware (cable ties, U-clamps, shackles) or loose seizing

SEVERE

Required: Steps must be held in place by a properly designed mechanical clamping device or by seizing. From 1 Jan 2028 (MSC.576(110)): cable ties, U-clamps, and worm-driven (hose) clips are prohibited as step-securing methods.

Regulatory: A.1045(27) §2.2.3; MSC.576(110) §4.8; ISO 799-1:2019

If unaddressed: Improvised step securing can slip, loosen, or fail under load; a step may rotate or detach while the pilot is on the ladder.

2.5a

Side ropes degraded, mildewed, chemically burned, or brittle

CATASTROPHIC

Required: Side ropes must be sound and uniform, free of degradation, mildew, chemical or heat damage, and brittleness, and rigged as equal-length pairs at equal tension.

Regulatory: SOLAS V/23 §2.1; A.1045(27) §2.2; MSC.576(110) Part A §4.6-4.8, §22, and §23; ISO 799-1:2019

If unaddressed: Side ropes carry the pilot's full weight; degraded rope can stretch unevenly or fail during the climb.

2.5b

Side ropes spliced, knotted, or joined

CATASTROPHIC

Required: Each side rope must be one continuous length with no splices, knots, or joins below the top step. From 1 Jan 2028 (MSC.576(110)): side ropes 20 to 22 mm in diameter with properly finished ends.

Regulatory: A.1045(27) §2.2.1; MSC.576(110) Part A §4.6-4.7

If unaddressed: A splice or join is a weak point that can part under load, and unequal side-rope lengths twist the ladder.

2.6

Heaving line not available for immediate use

MODERATE

Required: A heaving line must be available for immediate use to raise or lower the pilot's bag.

Regulatory: SOLAS V/23 §7.1.3; MSC.576(110) §15.1.3

If unaddressed: Pilot gear may have to be passed by hand or carried on the ladder, distracting the pilot and increasing the chance of loss of balance.

2.7

Handhold or inner stanchion missing at platform or side-door transition

CATASTROPHIC

Required: At the accommodation-ladder platform and at side-door transitions a handhold or inner stanchion must be fitted on both sides, giving the pilot a secure grip through the transition.

Regulatory: A.1045(27) §3.5 and §5; MSC.576(110) §5.3, §5.5.5-5.5.6, §8, and §19; MSC.1/Circ.1428/Rev.1 Annex

If unaddressed: Pilot may have no secure handhold during the transition from ladder to platform or deck, which is one of the highest-risk points of the transfer.

2.8

Trapdoor obstructed, not latched open, or does not open freely

CATASTROPHIC

Required: The trapdoor must open upward and latch flat or against the rails without obstructing the access path, and the aperture must allow free passage.

Regulatory: SOLAS V/23 §3.3.2; A.1045(27) §3.7; MSC.576(110) §5.5.2.1, §5.5.4, and §13.2

If unaddressed: Pilot may have to twist, duck, or release one hand to pass through the opening; obstruction at the transition creates a high fall risk.

2.10

Accommodation-ladder handrails missing or slack (hand ropes not taut)

SEVERE

Required: The accommodation ladder and platform must have stanchions and rigid handrails on both sides. Where hand ropes are used instead, they must be tight and properly secured.

Regulatory: A.1045(27) §3.5; MSC.576(110) Part A §5.3

If unaddressed: Slack hand ropes give no real support and can let the pilot pitch over the side or fall through during the combination climb.

2.9

Step material non-compliant: metal, non-resilient plastic, or unapproved material

SEVERE

Required: Steps must be hardwood or equivalent, in one piece, with a slip-resistant surface. From 1 Jan 2028 (MSC.576(110)): the four lowest steps must be rubber or equivalent resilient material.

Regulatory: A.1045(27) §2.1.2.1-2.1.2.3; MSC.576(110) §4.1.1-4.1.2; ISO 799-1:2019

If unaddressed: Unapproved step material may not provide the required strength, stiffness, or grip; a step can flex, crack, or become slippery under load.

PHASE 3

Top of Climb & Disembarking

Pilot at deck level

3.1a

Unsafe securing method (rail, deck tongue, or clamping the steps)

CATASTROPHIC

Required: The pilot ladder must be secured by its side ropes to dedicated deck strong points, never to rails or bollards, by a deck tongue, or by clamping the steps. Strong points, shackles, and securing ropes must be at least as strong as the side ropes, with a breaking strength of at least 48 kN.

Regulatory: SOLAS V/23 §3.3.1.1.4; A.1045(27) §2.1.1; MSC.576(110) Part A §6.1 and Part B §12

If unaddressed: A ladder secured to a rail, a deck tongue, or by clamping the steps can shift, drop, or pull free when the pilot's weight comes on.

3.1b

Improper securing at intermediate length (shackles over side ropes)

CATASTROPHIC

Required: When secured at an intermediate length the ladder must be held by a device that grips each set of side ropes without slippage (breaking strength at least 48 kN), setting the lowest step at the height requested by the pilot. Shackles, knots, or splices at intermediate securing positions are prohibited.

Regulatory: MSC.576(110) Part A §6.3 and Part B §12.6; MSC.1/Circ.1428/Rev.1 Annex (no shackles, knots, or splices); NCC453 testing report

If unaddressed: Shackles or improper intermediate securing can crush the steps or let the side ropes slip, dropping the ladder under load.

3.2

Manropes not led through stanchion rings or secured to deck strongpoints

SEVERE

Required: Manropes must be fixed to dedicated deck strong points and led through the ring or eye at the top of the stanchions at the point of access, not tied to the rails.

Regulatory: SOLAS V/23 §7.1.1; MSC.576(110) §8.1 and §15.1.1.3

If unaddressed: Manropes can pull out of position or load the wrong fittings, leaving the pilot without a reliable handhold during the climb or transition.

3.3

Handhold stanchions missing or unsecured at embarkation point

CATASTROPHIC

Required: Handhold stanchions must be fitted at the access point, rigidly secured and locked to the ship's structure at the base and at a higher point.

Regulatory: SOLAS V/23 §4; A.1045(27) §5.1-5.2 as amended by A.1108(29); MSC.576(110) §8.1

If unaddressed: Pilot may have no stable handhold when stepping through the gateway; an unsecured stanchion can fail exactly when weight is transferred.

3.4

Stanchion diameter outside 32-36mm or spacing outside 0.7-0.8m

MODERATE

Required: Handhold stanchions must be 32 to 36 mm in diameter, spaced 0.7 to 0.8 m apart, and extend at least 1.2 m above the deck.

Regulatory: MSC.576(110) Part A §8.1; IMO Res. A.1045(27) §5.1 as amended by A.1108(29)

If unaddressed: Stanchions that are too small or too large are harder to grip securely, especially with wet gloves or in vessel motion.

3.5

Embarkation point obstructed or gate not fully opened

SEVERE

Required: The point of access must give safe, convenient, and unobstructed passage: the gate fully open and the deck clear of lines, gear, and trip hazards.

Regulatory: SOLAS V/23 §4; A.1045(27) §5; MSC.576(110) §8 and, where a winch reel is fitted, §17.2

If unaddressed: Pilot may have to step over, around, or between obstructions immediately after leaving the ladder, increasing trip and fall risk at the deck edge.

3.6

Lifebuoy with self-igniting light not immediately available

MODERATE

Required: A lifebuoy with a self-igniting light must be immediately available at the point of access.

Regulatory: SOLAS V/23 §7.1.2; MSC.576(110) §15.1.2

If unaddressed: If the pilot falls, recovery may be delayed because required rescue equipment is not immediately available at the transfer point.

3.7

No responsible officer present or deck crew without PPE/lifejackets

MODERATE

Required: A responsible officer must supervise the transfer with communication to the bridge, and deck crew must wear appropriate PPE and lifejackets.

Regulatory: SOLAS V/23 §2.2; MSC.576(110) §3.7

If unaddressed: No responsible officer supervising rigging and transfer; unsafe crew positioning or missing lifejackets or PPE can delay response if the pilot falls or the arrangement fails.

3.8

No bulwark ladder or safe step-down method at high bulwark

SEVERE

Required: At a high bulwark a bulwark ladder or other safe step-down must be provided, securely fitted, with two separate handhold stanchions that are not attached to the bulwark ladder.

Regulatory: SOLAS V/23 §4 and §7.2; A.1045(27) §5.2; MSC.576(110) §8.1.2 and §15.2

If unaddressed: Pilot may be forced to climb over the bulwark without a proper foothold, increasing the chance of slipping or falling at the deck transition.

3.9

Winch reel not locked or used as sole securing point for pilot ladder

CATASTROPHIC

Required: A pilot-ladder winch reel must be locked, and the ladder must be secured independently to dedicated strong points. The winch reel must never be the sole means of support.

Regulatory: A.1045(27) §7.4-7.5; MSC.576(110) §20 and §21

If unaddressed: If the winch or brake slips, the ladder can drop or surge under load; the pilot may fall before anyone can re-secure it.

3.10

Mechanical pilot hoist in use, banned under SOLAS

CATASTROPHIC

Required: Mechanical pilot hoists are prohibited and must not be used.

Regulatory: SOLAS V/23 §6; SOLAS V/23 §10 as amended by MSC.572(110); A.1045(27) §4

If unaddressed: Mechanical hoists can fail, jam, or move unexpectedly with the pilot suspended over the water, creating a severe fall risk.

3.11

Certification or documentation non-compliant or expired

MODERATE

Required: The arrangement must have valid manufacturer certification, permanent identification, and current inspection and maintenance records. From 1 Jan 2028 (MSC.576(110)): maximum service life of 36 months from manufacture or 30 months from entry into service, whichever comes first.

Regulatory: SOLAS V/23 §2.3-2.4; ISO 799-2:2021; MSC.576(110) Part D §§24-30 and Part F §§34-37; PSC deficiency code 10101

If unaddressed: Ladder identity, certification, inspection history, service-entry date, maintenance records, and future service-life compliance may not be verifiable.

3.13

No roundover or chafing protection where ropes cross a sharp deck edge or sheerstrake

SEVERE

Required: Equipment and arrangements must be designed so side ropes and manropes never bear on a sharp edge. Where contact is unavoidable the edge must be rounded (for example a half-pipe) or fitted with chafing protection.

Regulatory: MSC.576(110) Part A §9 (Protection from chafing); MSC.1/Circ.1428/Rev.1 Annex (half-pipe over sharp edges)

If unaddressed: Side ropes or manropes bearing on an unprotected sharp deck edge or sheerstrake can chafe and part under load, causing the pilot to fall.

3.14

Ship's guardrails used in place of dedicated handhold stanchions

SEVERE

Required: Dedicated handhold stanchions (32 to 36 mm diameter, 0.7 to 0.8 m apart, at least 1.2 m above the deck) must be provided. The ship's permanent guardrails are not an acceptable substitute.

Regulatory: SOLAS V/23 §4; MSC.576(110) §8.1

If unaddressed: Permanent ship's guardrails substituted for dedicated pilot handhold stanchions rarely meet the required diameter, spacing, or height, leaving the pilot without a secure grip at the transition.

3.15

Handhold stanchion used as structural hinge or support for ship's access gate

SEVERE

Required: Handhold stanchions must be rigidly secured and locked to the ship's structure and must not carry the hinge or load of an access gate.

Regulatory: SOLAS V/23 §4; MSC.576(110) §8.1

If unaddressed: A gate hinged on the handhold stanchion can wear and loosen the stanchion base under repeated load and creates a finger pinch-point exactly where the pilot must grip.

3.16

Handholds or stanchions set too far inboard of the deck edge

SEVERE

Required: Handholds at the access point must be reachable from the ladder for a secure grip on stepping off. From 1 Jan 2028 (MSC.576(110)): stanchions and handholds must be no more than 0.12 m (120 mm) inboard of the edge of the deck.

Regulatory: MSC.576(110) Part A §8.1.1-8.1.3 (no more than 0.12 m inboard); SOLAS V/23 §4

If unaddressed: If the handhold is set too far inboard the pilot has nothing secure to grip at the most dangerous moment, stepping from the ladder onto the deck.

4.0

Other

OTHER

Required: Any deficiency affecting the safety of the pilot transfer that is not covered by a specific code above. The pilot describes it in the report comments.

Regulatory: SOLAS V/23 §1.1 and §2.1; MSC.576(110) §3.1

If unaddressed: Variable; the pilot describes the condition and its effect in the comments field.

This taxonomy is the reference used by the LadderWatch reporting system. Codes, descriptions, and severities are aligned to SOLAS V/23 and supporting IMO instruments. The 47-code structure and consequence-based severity model are part of the LadderWatch patent-pending methodology.