Escape Routes in Ship Engine Rooms 11.03.2025 16:22
These news outline the regulatory background, recent IMO discussions, and recommended actions for ship operators to address potential issues with engine room escape arrangements.
Ensuring effective and compliant escape arrangements from the engine room is a critical aspect of ship safety. The International Association of Classification Societies (IACS) Unified Interpretation (UI) SC277 and IMO Circular MSC.1/Circ.1511 clarify the requirements for defining the lowest part of a space in relation to escape arrangements. However, recent Port State Control (PSC) inspections in Asia have raised deficiencies where the escape trunk does not extend to the lowest level of the engine room, prompting concerns regarding compliance and crew safety.
One of the key fire safety objectives of SOLAS Chapter II-2 is to “provide adequate and readily accessible means of escape for passengers and crew.” To comply with SOLAS Regulation II-2/13, one solution for means of escape from machinery spaces is the installation of a vertical escape trunk from the “lower part of the space.”
According to IMO MSC.1/Circ.1511, “the lower part of the space should be regarded as the lowest deck level, platform, or passageway within the space.” This interpretation is essential for shipowners, technical operators, and surveyors to ensure proper escape arrangements.
Recently, PSC inspections in Asia have flagged deficiencies in ships built after the implementation of IACS UI SC277 and MSC.1/Circ.1511. Specifically, non-compliant engine room escape trunks that do not extend to the lowest level of the engine room have been noted. Some vessels have instead installed short, inclined stairs leading from the bottom level to the lowest escape trunk door, which has resulted in deficiencies being raised by PSC inspectors.
Additionally, PSC inspections have required ship crews to demonstrate the effective evacuation of an injured crew member from the lowest level of the engine room to the escape trunk, as per SOLAS Reg. III/19.3. In cases where the drill was deemed unsatisfactory, deficiencies were recorded. Procedures for conducting PSC inspections, including rescue drills, are outlined in IMO Resolution A.1185(33).
Recommended next steps
For ships subject to IACS UI SC277 and MSC.1/Circ.1511, where the engine room escape trunk does not lead to the lowest level of the engine room, the following measures are recommended:
• A technical justification should be developed [and reviewed by the flag Administration or its Recognised Organisation] which should detail why the escape arrangement did not extend to the lowest platform.
• The technical justification should provide justifiable reasons why the trunk cannot be led to the lowest level. These could include:
o Insufficient space due to any restrictions, e.g. ship's hull lines, side shell stiffening, structural design arrangements.
o Equipment or machinery in the way, e.g. shaft or stern seal equipment.
o Maintenance envelope or access required to maintain equipment or withdraw shafts.
• A technical justification should be developed [and reviewed by the flag Administration or its Recognised Organisation] which should detail why the escape arrangement did not extend to the lowest platform.
• The technical justification should provide justifiable reasons why the trunk cannot be led to the lowest level. These could include:
o Insufficient space due to any restrictions, e.g. ship's hull lines, side shell stiffening, structural design arrangements.
o Equipment or machinery in the way, e.g. shaft or stern seal equipment.
o Maintenance envelope or access required to maintain equipment or withdraw shafts.
• The technical justification should explain how the as-fitted arrangements provide for safe escape, e.g. short, inclined ladder of suitable width, sufficient access platform area at entrance door, easy access to inclined ladder.
• The technical justification should be kept onboard the ship, available to be presented to Port State Control or other parties when required. For all ships, where the engine room escape trunk does not lead to the lowest level of the engine room, the following measures are recommended:
• Operators should ensure they have adequate procedures in the ship’s Safety Management System (SMS) to cover rescue drills for evacuating injured persons from the engine room.
• In addition, the crew should familiarise themselves with the arrangement on board and practise and record rescue drills, as per the Company SMS requirements.
• The technical justification should be kept onboard the ship, available to be presented to Port State Control or other parties when required. For all ships, where the engine room escape trunk does not lead to the lowest level of the engine room, the following measures are recommended:
• Operators should ensure they have adequate procedures in the ship’s Safety Management System (SMS) to cover rescue drills for evacuating injured persons from the engine room.
• In addition, the crew should familiarise themselves with the arrangement on board and practise and record rescue drills, as per the Company SMS requirements.
