Maritime Legal Update
– July 2026
IMO updates
requirements for Permanent Means of Access (PMA) – new inspection obligations
for tankers and bulk carriers
Firm note – SOLAS,
ship classification and technical compliance
The Law Office actively advises shipowners,
operators, technical managers, shipyards, classification societies and offshore
stakeholders regarding: SOLAS compliance, survey and inspection requirements, ship
management, technical due diligence, port state control, classification
matters, and IMO technical regulation.
The latest IMO interpretations concerning Permanent Means of Access (PMA) introduce
new inspection requirements that may have significant operational consequences
for tanker and bulk carrier operators.
1. Introduction –
MSC.1/Circ.1572/Rev.2
The International Maritime Organization has
issued MSC.1/Circ.1572/Rev.2 containing updated unified interpretations
relating to SOLAS Regulation II-1/3-6 and technical requirements concerning
Means of Access for Inspections.
The changes primarily affect: oil tankers of
500 GT and above, bulk carriers of 20,000 GT and above constructed on or after
1 January 2006.
2. What are Permanent
Means of Access?
Permanent Means of Access (PMA) are fixed
access arrangements allowing safe inspection of ship structures.
They include: ladders, platforms, walkways, inspection
routes, and other access systems.
PMA are essential for: structural inspections, condition
assessment, class surveys, and statutory inspections.
3. New annual
inspection requirement
The most significant change is the introduction
of annual inspection requirements for both permanent and portable means of
access.
The interpretations provide that PMA should be
inspected annually by crew members or competent inspectors.
Inspection records should be maintained within
Part 2 of the Ship Structure Access Manual (SSAM).
4. Why did IMO
introduce the changes?
The amendments were driven by IMO concerns
regarding the condition of access arrangements installed in: tanks, cargo
holds, ballast tanks, and other structural spaces.
The objective is to reduce: deterioration, inspection
risks, safety hazards, and structural access failures.
5. Tanker
practicalities
Lloyd’s Register has highlighted practical
concerns regarding cargo tanks on oil tankers.
Inspection of PMA within cargo tanks requires: gas
freeing, inspection activities, re-inerting, and recommissioning of the tank.
This process is: time-consuming, operationally
disruptive, environmentally burdensome, and commercially costly.
6. Lloyd’s Register
observations
LR notes that the main causes of PMA
deterioration are Bulk carriers: mechanical damage during cargo operations.
All ships: corrosion associated with
atmospheric exposure and seawater.
By contrast, PMA within tanker cargo tanks
benefit from: inert atmospheres, limited mechanical exposure, and relatively
low deterioration rates.
LR therefore questions whether annual opening
of cargo tanks is proportionate to the actual level of risk.
7. Nature of Unified
Interpretations
It is important to note that Unified
Interpretations are not directly binding legal requirements.
They are guidance documents intended to ensure
consistent implementation of SOLAS.
Their practical application remains subject to
Flag Administration interpretation and approval.
8. Recommendations to
shipowners
Lloyd’s Register recommends that shipowners
consider applying to their Flag Administration for appropriate dispensations
where justified.
Supporting documentation may include: operational
justifications, maintenance schedules, inspection reports, photographs, and
evidence demonstrating low risk.
Approved dispensations should be retained
within the Ship Structure Access Manual.
9. Practical
implications
The new interpretations may significantly
affect: tanker operators, bulk carrier operators, ship managers, classification
societies, and technical compliance departments.
Operators should review: inspection procedures,
Ship Structure Access Manuals, maintenance systems, and flag administration
requirements.
10. Law Office
conclusions
The revised IMO interpretations demonstrate the
growing importance of technical compliance within ship safety management.
Although the objective of improving inspection
safety is clear, implementation may present significant operational challenges,
particularly for tanker operators.
Shipowners should closely monitor flag
administration approaches and ensure that their technical and operational
procedures are aligned with the evolving regulatory framework.