Revised interpretation of requirements to permanent means of access (PMA)

New IMO amendments clarify inspection requirements for PMA on tankers and bulk carriers. The changes aim to prevent safety incidents and introduce stricter inspection and documentation rules. Ship operators must update procedures and manuals, and revised records must be reviewed during future surveys. Read more about the revised interpretation in this statutory news.

Information for: Shipyards, owners/managers, and flag states.

Introduction

A revised interpretation of SOLAS Regulation II‑1/3‑6, introduced in MSC.1/Circ.1572/Rev.2 (Annex, paragraph 1.4), provides clearer expectations for the inspection and maintenance of Permanent Means of Access (PMA) on oil tankers and bulk carriers built on or after 1 January 2006.

The amendments were triggered by a reported near‑miss involving poorly maintained inspection platforms, and they reinforce the requirements for how PMA should be checked, documented and followed up on board. The revision places greater emphasis on systematic inspection routines and proper record‑keeping, and it intends to ensure that PMA remains safe and fully functional throughout the vessel’s service life.

Application

The MSC.1/Circ.1572/Rev.2 applies to inspections conducted by the crew after 1 January 2025. Applicable vessels are oil tankers (≥500 GT) and bulk carriers (≥20,000 GT) constructed on or after 1 January 2006.

Key changes for crews and owners

The following are the most important changes related to the revised PMA regulations:

1. Additional inspection requirements

• All means of access arrangements, including portable equipment and associated fittings, are to undergo annual inspection.¹
• Each inspection is to be recorded in Part 2 of the Ship Structure Access Manual (SSAM).
• Before any examination of a space that uses PMA, a condition check of the permanent access equipment must be carried out and recorded for the specific space.

^{1) Clarifications on annual inspections: Following discussions after MSC 108, it has been clarified that the wording “annually inspected” in MSC.1/Circ.1572/Rev.2 does not require cargo tanks on oil tankers to be opened every year solely for inspection of PMA. In accordance with SOLAS Regulation II-1/3-6, inspections of PMA are to be carried out when the space is accessed for surveys, meaning when internal spaces are examined and access is practicable. Major flag states have confirmed their acceptance of this interpretation.}

2. Updated inspection procedures

• Where damage or deterioration is identified, including coating breakdown or material wastage, an assessment shall be carried out to determine whether the condition affects the safe use of the access arrangement.
• If the condition is assessed as substantial damage, details shall be recorded in Part 2 of the SSAM.

3. Enhanced inspection records

• Inspection records for means of access shall include the date of inspection, name and title of the inspector, confirmation or signature of the inspector, sections of the access arrangements inspected, verification of safe condition or details of deterioration or substantial damage, and a description of any repairs carried out.
• Inspection records shall be made available to classification surveyors prior to surveys.

Amendments to the Ship Structure Access Manual (SSAM)

Ship operators shall update the SSAM in accordance with the new provisions introduced in MSC.1/Circ.1572/Rev.2. In addition to the above-mentioned MSC amendments, IACS has also introduced a revised template for the SSAM, Rec 90 SSAM. See references below and a link to the IACS recommendations.

The updated SSAM is not required to be resubmitted for approval. DNV surveyors will verify the revised manual during subsequent surveys.

Recommendations

DNV recommends that owners and operators assess the impact from the new IMO amendments on PMA.

This includes updating and maintaining the SSAM in accordance with the new provisions introduced in MSC.1/Circ.1572/Rev.2.

The updated manual is not required to be resubmitted for approval. DNV surveyors will verify the revised manual during subsequent surveys.

References

Unified Interpretation to SOLAS Regulation II‑1/3‑6: MSC.1/Circ.1572/Rev.2

IACS Rec.90, Rev.2 – Ship Structure Access Manual: Rec.90 Rev.2 Nov 2024 UL.pdf

Figure 1: The cross-deck upper platform on a 15-year-old bulk carrier – damaged platform	Figure 2: The cross-deck upper platform on a 10-year-old bulk carrier – missing platform