Updated unified interpretations introduce stricter inspection and documentation rules, raising practical concerns for vessel operators.
November 2026 – The International Maritime Organization (IMO) has issued revised unified interpretations for Permanent Means of Access (PMA) on oil tankers and bulk carriers, introducing mandatory annual inspections by the crew or a competent person. The updates, detailed in MSC.1/Circ.1572/Rev.2, amend SOLAS Regulation II‑1/3‑6 and apply to oil tankers of 500 gross tonnage and above, and bulk carriers of 20,000 gross tonnage and above, constructed on or after 1 January 2006.
The revisions, triggered by a reported near‑miss incident involving poorly maintained inspection platforms, place greater emphasis on systematic inspection routines, damage assessment, and proper record‑keeping.
Key Changes Under the Revised Interpretations
The updated circular introduces several significant changes, with the most impactful being the requirement for annual inspections of all means of access arrangements, including portable equipment and attachments. These inspections must be recorded in Part 2 of the Ship Structure Access Manual (SSAM).
Additional requirements include:
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Pre‑entry condition checks: Before any examination of a space that utilises PMA, a condition check of the permanent access equipment must be carried out and recorded for that specific space.
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Mandatory damage assessment: Where coating breakdown, corrosion, material wastage or structural degradation is identified, a formal assessment must determine whether the condition affects the safe use of the access arrangement. Substantial damage must be clearly documented in the SSAM.
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Enhanced record‑keeping: Inspection records must now include the date of inspection, name and title of the inspector, areas inspected, condition status, and details of any repairs carried out. These records must be made available to surveyors prior to surveys.
Operational Challenges for Oil Tanker Operators
Industry stakeholders have raised concerns about the practicality of conducting annual surveys of PMA inside cargo tanks on oil tankers. The primary challenges include:
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Inerted atmosphere requirements: Cargo tanks on oil tankers are kept closed and maintained in an inerted atmosphere. Inspecting PMA inside these tanks requires the tanks to be gas‑freed prior to inspection and fully re‑inerted afterward before returning to service.
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Operational and environmental costs: The decommissioning and recommissioning cycle of a cargo tank is significantly time‑consuming, has an environmental cost, and impacts vessel operations.
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Current inspection frequency: Generally, cargo tanks on oil tankers up to 10 years of age are gas‑freed and opened once every five years, while those over 10 years of age are opened twice every five years.
Important clarification: Following discussions after IMO MSC 108, it has been clarified that the wording “annually inspected” does not require cargo tanks on oil tankers to be opened every year solely for inspection of PMA. Inspections 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.
Degradation Factors and Industry Experience
The main factors contributing to PMA deterioration differ significantly by vessel type:
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Bulk carriers: Contact damage during loading and discharging of cargo holds.
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Ballast tanks (all ships): Corrosion accelerated by atmospheric exposure and seawater.
In contrast, cargo tanks on oil tankers are not subject to the same mechanisms of degradation. Their structure is not exposed to mechanical impacts during cargo operations, and the inerted atmosphere significantly reduces corrosive effects. Industry experience indicates that PMA in oil tanker cargo tanks does not present a significant concern.
Recommendations for Shipowners and Operators
While the unified interpretations are not mandatory in themselves, they are subject to interpretation and decision by the flag Administration. Classification societies are not authorised to issue dispensation letters—such letters may only be granted by the Administration.
It is therefore recommended that shipowners, operators, managers and masters contact their flag Administration to request dispensation, submitting supporting documentation such as:
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Justification for requesting a letter of dispensation (e.g., the time each tank would remain out of service).
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Planned Maintenance System schedule for cargo tank inspections and associated activities.
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Latest cargo tank inspection reports, including sample photographs.
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A copy of the relevant Class News or circular.
If the flag Administration agrees to grant a dispensation, the document or email should be retained in the Ship’s Structure Access Manual as documentary evidence.
Next Steps for Compliance
Ship operators should take the following actions to ensure compliance with the revised requirements:
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Update the Ship Structure Access Manual in accordance with the new provisions.
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Align inspection procedures with the enhanced record‑keeping and damage assessment requirements.
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Engage with the flag Administration early to discuss any dispensation requests, particularly for oil tankers where annual tank entry presents significant operational challenges.
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Ensure consistency between onboard procedures, actual inspection practices, and recorded evidence.