Emergency escape from machinery spaces of category A is a critical safety concern that has led to the detention of ships during Port State Control (PSC) inspections. Despite having arrangements approved by flag states or Recognized Organizations, PSC authorities have found these arrangements non-compliant. This situation underscores the need for clarity and guidance regarding emergency escape setups. According to SOLAS Regulations II-2/13.4.1.1.1 and 13.4.2.1.1, each machinery space of category A must have two means of escape.
One of these must be in a protected enclosure extending from the lowest working level to a safe area outside the space. The IMO Unified Interpretation (MSC.1/Circ.1511/Rev.1) specifies that these machinery spaces may encompass multiple decks, with the lowest deck defined as the lowest operational area. Despite these regulations, industry practices on many vessels have seen the protected emergency escape trunk not extending down to the lowest deck. Instead, inclined ladders are often used to connect the lowest deck to a platform, allowing access to the escape trunk.
This approach is frequently necessitated by structural design limitations that prevent direct access. PSC authorities are now particularly scrutinizing vessels constructed after February 1, 2016, emphasizing compliance with IACS UI SC 276/277. They perceive escape trunks not reaching the lowest deck as a violation of SOLAS requirements. Increased inspections are demanding drills that simulate evacuation scenarios, creating potential detention situations if drills do not satisfy PSC officers.
To navigate this complexity, vessels lacking complete escape trunk arrangements must have a technical justification available for review. This justification should detail why the design is what it is, citing factors like space constraints due to equipment installations. It is essential that this documentation is formally accepted by the flag administration and kept on board. Recent discussions at the IMO highlighted ongoing uncertainties regarding escape route terminologies.
As vessels move forward, developing comprehensive safety management systems and conducting regular evacuation drills will remain critical in maintaining compliance and improving safety on ships.