Emergency Escape Trunks Scrutinized by Port State Control
DNV has encountered instances where ships have been detained during Port State Control (PSC) inspections due to the arrangement of emergency escape trunks from machinery spaces even though the arrangements were approved by the flag state or their Recognized Organization.
As a result, DNV has issued guidance explaining that on many ships, the protected emergency escape trunk does not, for various reasons, extend all the way down to the lowest deck level of the engine room.
Common industry practice involves using an inclined ladder from the lowest deck level of the engine room to a platform above the deck, providing direct access to the escape trunk. This arrangement is often necessary due to the hull shape, structural elements and technical installations that prevent the escape trunk from extending to the lowest deck of the engine room.
PSC authorities are concentrating on vessels contracted for construction or with keels laid on or after 1 February 2016 since these must comply with IACS UI SC 276/277, as reflected in MSC.1/Circ.1511/Rev.1, by IACS societies.
“Certain port states consider arrangements where the escape trunk does not extend all the way to the lowest deck of the engine room to be non-compliant with SOLAS. They have indicated a focus on these arrangements and advised that vessels without flag administration acceptance, and where arrangements are not extended as low as possible, will be subject to detention,” says DNV.
Some PSC inspectors are also requesting the crew to conduct an evacuation/rescue drill. This drill involves evacuating an injured person on a stretcher from the lowest deck, up the ladder and into the protected trunk. “We have seen instances of vessels being detained if the drill does not meet the satisfaction of the PSC officer. Evacuation time could be considered one criteria.”
For vessels having escape trunks not extending down to the lowest deck level in the engine room, a technical justification on why the emergency escape trunk cannot be extended to the lowest deck level could be required by flag and/or port state control.
The IMO Sub-Committee on Ship Design and Construction (SDC 11), held in January 2025 agreed to invite the Sub-Committee on Implementation of IMO Instruments (III 11) meeting in July 2025 to consider the matter.
For vessels contracted for construction (or keel laid) on or after February 1, 2016, DNV recommends that a technical justification is developed detailing why the emergency escape trunk does not extend to the lowest deck level of the engine room. This justification should be reviewed and accepted by the flag administration, kept on board the vessel and be available for presenting to the PSC or other parties when required. DNV may assist.
For ships whose emergency escape trunk does not lead to the lowest deck of the engine room, DNV recommends:
Update the Safety Management System (SMS): ensure the SMS includes procedures for rescue drills to evacuate injured persons from the engine room.
Conduct regular drills: familiarize the crew with the on-board arrangements and practice rescue drills regularly. These drills shall be recorded as required by the company’s SMS.