DNV has reported that some ships have been detained during Port State Control (PSC) inspections because of issues with the layout of emergency escape trunks from machinery spaces. Even though these arrangements had been approved by the flag state or their Recognized Organization, PSC authorities have considered them to be non-compliant. This indicates a potential discrepancy between flag state/RO approvals and PSC interpretations, and DNV is providing further clarification and guidance to address this situation.
Regulatory Background
SOLAS regulations mandate two escape routes from each Category A machinery space. If steel ladders are used, one must be within a protected enclosure, extending from the lowest part of the space to a safe external area.
IMO guidance clarifies that machinery spaces can include multiple levels of platforms and passageways, with the lowest level considered the “lower part” for escape route purposes.
Furthermore, inclined ladders or stairways within machinery spaces that are part of escape routes, but not enclosed, should have an inclination of no more than 60 degrees and a minimum clear width of 600 mm.
IACS societies have adopted these interpretations, applying them to ships contracted for construction on or after February 1, 2016.
PSC Authorities
Port State Control (PSC) authorities are focusing on vessels built after February 1, 2016, to ensure compliance with IACS interpretations of SOLAS regulations regarding machinery space escape routes.
Some port states are specifically targeting vessels where the escape trunk doesn’t reach the engine room’s lowest deck, considering this a SOLAS violation. These vessels may face detention if they lack flag administration approval and if the escape trunk is not extended as low as possible.
PSC inspections are now often including evacuation/rescue drills, where crew must evacuate a simulated injured person on a stretcher from the lowest deck, through the escape ladder, and into the protected trunk. Vessels may be detained if the drill is deemed unsatisfactory by the PSC officer, with evacuation time being a potential factor.
IMO Discussions
The issue of escape routes from machinery spaces was discussed at the IMO Sub-Committee on Ship Design and Construction (SDC 11) in January 2025.
SDC 11 considered revising the existing interpretations of SOLAS regulations to clarify the “lower part” of machinery spaces for escape route purposes.
However, SDC 11 could not reach a consensus on further clarifying the interpretation. While they confirmed that “lower part” could mean either the lowest deck level or a platform/passageway, differing opinions prevented them from definitively stating it should not be interpreted as “whichever is lowest.”
Consequently, SDC 11 decided to refer the matter to the Sub-Committee on Implementation of IMO Instruments (III 11) in July 2025, due to the implications for Port State Control (PSC) activities.
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Source: DNV
