The 2028 SOLAS amendments: what the 36-month ladder replacement rule means for ship operators

Jill F Russell
Mar 22
4 min read

Updated: Mar 25

By Captain Jill Russell, USCG-Licensed Master, Alaska Licensed Marine Pilot · LadderWatch

Category: Regulatory Updates · Reading time: 5 min

The most significant overhaul of pilot ladder safety regulations in a generation takes effect 1 January 2028. Here's what every ship operator needs to know, and why the clock is already running.

What just changed

In June 2025, the IMO's Maritime Safety Committee adopted sweeping amendments to SOLAS Chapter V, Regulation 23, the international rule governing pilot transfer arrangements. The amendments were formally adopted at MSC 110 and enter into force on 1 January 2028. For ships already in service, the compliance deadline is the first class survey on or after 1 January 2029.

These are not guidance documents or recommendations. They are binding international law.

Having spent over four decades on the water, one of those boarding vessels as a marine pilot in Southeast Alaska, often in the dark, in horrible weather, on ladders that ranged from decent to alarming, I can tell you that these amendments are overdue. Let me walk you through what they actually require.

Pilot ladders are now consumables

The most consequential change: pilot ladders are no longer equipment that lasts until it fails. Under the new rules, every pilot ladder must be removed from service within 36 months of its manufacture date, or 30 months from when it was placed into service, whichever comes first.

Read that again. The earlier deadline applies. A ladder manufactured in January 2026 and put into service in July 2026 must be retired by January 2029, 30 months from service entry, not 36 months from manufacture.

Ships must also carry a spare pilot ladder at all times. The spare is subject to the same 36/30-month limits. Long-term storage of 'new' ladders as a cost strategy no longer works, that stored ladder's manufacture date clock is already running.

The shackle ban

As of 1 January 2028, securing pilot ladders at intermediate lengths using shackles on deck is prohibited.

Shackles have been implicated in roughly 25% of pilot ladder incidents over the years. The failure mode is well documented: shackles can rotate, work loose under load, or create a rigid point that transmits shock loads into the ladder when a pilot's weight is applied suddenly. The new rules require dedicated securing means with documented breaking strength.

Speaking from experience: this is the deficiency I flag more than any other. I've boarded vessels where the ladder was secured with whatever hardware someone found nearby. That ends in 2028.

Stronger breaking strength requirements

The minimum breaking strength for strong points, shackles, and ropes used to secure the pilot ladder has been doubled, from 24 kN to 48 kN. Every piece of securing hardware needs to meet this standard and have the breaking strength permanently and clearly marked on the equipment.

New rope diameter specification

Side rope diameter requirements have been tightened to a specific range: not less than 20mm and not more than 22mm. The previous standard only set a minimum of 18mm. This matters because ropes outside this range affect the pilot's grip, both too thin and too thick create handling problems in sea conditions.

Documentation and inspection requirements

The new rules formalize what should already have been happening: certificates for all transfer equipment must be kept in a file and available for inspection. Transfer arrangements must be inspected by a responsible officer before each use, after each use, and every three months. Training for crew is mandatory.

Port State Control officers will be checking this documentation. Non-compliance is now an actionable deficiency with a paper trail.

The counterfeit problem

BIMCO and other organizations have flagged a concern worth taking seriously: the new rules create commercial incentive for counterfeit ladders. A vessel needing to replace its ladder every 30-36 months represents a recurring revenue stream, and there are already documented cases of marine casualties where the failed ladder turned out to be counterfeit.

Verify your suppliers. Buy from original equipment manufacturers or their approved distributors. Keep the documentation.

What operators should be doing right now

Audit your current ladder inventory. Check manufacture dates on every pilot ladder and spare across your fleet. Calculate when each one hits its 36-month manufacture limit and its 30-month service limit.
Assess your securing arrangements. If you're currently using shackles at intermediate lengths, you need a plan to replace them before 2028.
Verify breaking strength markings on all securing hardware. The 48 kN requirement may require hardware replacement even on otherwise compliant ladders.
Check your rope diameters. Side ropes outside the 20-22mm range will require replacement.
Review your documentation systems. Inspection records, certificates, and maintenance logs need to be organized and accessible.

I am building LadderWatch partly because ship operators often don't know what pilots are seeing, and pilots often have no way to tell ship operators what they've seen on previous calls. The 2028 amendments create a regulatory framework, but enforcement happens one boarding at a time. A platform that tracks deficiency history by IMO number makes compliance visible across the fleet, not just at the moment of survey.