Interpretation Risk in Collision Regulation of Same Pilot Boarding Grounds


According to a near-miss report published by CHIRP Maritime, raised concerns over misunderstandings that might occur in the interpretation of the Collision Regulations by two vessels using the same pilot boarding ground.

Summary of events

The report described a situation where an outbound vessel leaving a pilot station encountered an inbound vessel. The risk of the collision was deemed to exist by the outbound vessel (which was the stand on vessel in this instance) and having observed the situation for some time noted that the inbound vessel was not taking action in accordance with the Collision Regulations. A VHF conversation determined that the give-way vessel was inbound to the pilot station and expected the outbound vessel to keep clear. Under Collision Regulations 17 (a) (ii) the outbound vessel altered course because the inbound vessel did not seem to be taking appropriate action.

The reporter correctly identified the specific Collision Regulations that were applicable and was quite correct in saying that the Collision Regulations apply in the vicinity of a pilot boarding ground just as much as they do in any area of the high seas.

Collision Regulations

This paper addresses the particular circumstances that should apply to all vessels when approaching a pilot station and embarking or disembarking a pilot. Full compliance with the Collision Regulations and proper communications are the key factors. This is particularly true when there is potentially a need to interact with other vessels in the vicinity, in order to avoid unnecessary confusion and anxiety relating to the intentions of either vessel. Although the correct application (and interpretation) of the Collision Regulations is overarching, there are other considerations that may be taken into account in order to avoid misunderstandings at or in the vicinity of a pilot board ground.

Scheduling a pilot from the sea – speed/time/distance management

  • This topic has been highlighted by CHIRP previously but is worth re-stating as it emphasizes good practices in the planning and approach leading to a reduction in any potential conflict by resolution at an earlier stage.
  • Proper planning of scheduled boarding times by port authorities and vessels should ensure that traffic flows smoothly in the vicinity of boarding grounds. Inbound and outbound shipping movements are often co-ordinated with the pilot on board the outbound vessel being assigned to take the inbound vessel.
  • Due consideration should be given to both the actions of the outbound vessel, (perhaps creating a lee or sudden increase or decrease in speed) and the available sea room. Good communications ensure that the inbound vessel keeps well clear until the outbound pilot has disembarked and also gives the inbound vessel knowledge of the intentions of the other vessel.

Boarding delays

  • Delays are inevitable and this may result in pilot boarding times being re-scheduled. Once again it is vital that communication is maintained so that all parties are fully aware of any adjustments. When replanning an arrival at the boarding ground, speed management is a vital element. Some vessels may need to make fine speed adjustments at an early stage in order to meet the new arrival time.
  • We have all seen vessels taking round turns, effecting zig-zag dog legs, and upon occasion drifting in high-density areas of traffic with two black balls being raised in abuse of the Collision Regulations. This is where speed management and control of the operation have abjectly failed, and it has the potential to cause chaos with other vessels in the vicinity.
  • It is also desirable to avoid early arrival, particularly when there is more than one inbound vessel making for the same pilot station at the same time. There is no point in having your vessel and several others sitting on the charted purple diamond jostling for position since low speed, tidal effects, and restricted sea room may inhibit maneuverability, and is a recipe for disaster.
  • It is far safer to be at a reasonable distance from such activity, still inbound at slow speed and in control of the situation, rather than becoming involved in multiple close-quarters situations. Speed, distance and time management, plus listening to the port authority or pilot’s VHF should ensure that you are aware of any potential problems long before they arise.

Dependence on AIS information

During the approach to any port, AIS information may be helpful. However, the accuracy of updated information cannot be relied upon. AIS-derived information may be helpful, but it is only one of the tools available to you and thus CHIRP advises that caution is needed unless this information is used in conjunction with other sources.

The point where you become committed to the final approach requires careful consideration. High-density traffic areas may well result in you becoming committed long before the pilot finally approaches you.

Things to be avoided during boarding

Some pilot boarding grounds offer limited sea room, and traffic congestion should be avoided. Proper pilot scheduling, concise communications, prompt timekeeping and situational awareness of other traffic all helps to ensure that all parties are fully aware of what is going on and what is expected of them.

Safe distances are maintained by keeping to the boarding schedule. If these are changed, then adjusting speed to keep a safe distance from the boarding ground and other traffic is paramount. Collision Regulations apply where the risk of collision exists and will take precedence over all other factors, but a prudent Master may be guided by the following:

  • The inbound vessel should allow room for the outbound vessel to clear the pilot boarding ground since she will generally have more room to maneuver than an outbound vessel.
  • The outbound vessel may have the same pilot who will be transferred to the inbound vessel.
  • Ship/pilot VHF communications assist greatly with situational awareness during pilot transfer as long as the discussion is limited to the pilot boarding arrangements. The danger of over-reliance on VHF communications with respect to the Collision Regulations cannot be overstated and has been the direct cause of many incidents.
  • When safe passing distances are assured by good scheduling and communications between pilots, ports authorities and masters, no Collision Regulation issues arise since the risks are being effectively managed.

The above pointers should ensure that vessels leave enough room in both space and time to safely enter the pilot boarding ground and safely execute the pilot transfer. The key to the safe conduct of vessels during this critical operation is timing – allowing each vessel to concentrate on this task and exercise good seamanship.

Safety Recommendations

  • The correct rigging of any pilot ladder or combination ladder and the seamanlike practices for boarding or disembarking a pilot are well covered in many publications. The IMPA Required Boarding Arrangements for Pilot chart is a useful simplified schematic which details the requirements. This section highlights some additional aspects of the embarkation and disembarkation operation.
  • The pilot should advise the required height of the pilot ladder above the water and the pilot transfer speed. The pilot may advise which side to create a lee but, if not, it is good practice to double-check rather than to exercise a seamanship judgment that may not match the actual intention of the pilot. At night, any unilateral action may not be obvious to an approaching pilot boat especially if they are anticipating a different maneuver.
  • The timing of creating a lee to match the precise pilot boarding time in exactly the correct position at the pilot station is a matter of professional pride. Those who have taken an Uraga Channel Pilot into Tokyo Bay will be aware of the efficient timekeeping that is required.
  • The requirement of early turn: In general terms, start the turn early in order to place the weather on the windward side approximately four points on the bow. This gives the pilot ladder on the leeward side the very best shelter. If there is a swell, this will affect the best heading to achieve the lee. Any final adjustments can be decided by conversations with the pilot launch. Try to board the pilot just before a steady course is achieved since the vessel is likely to roll less during a turn than she would on a steady course.
  • Once the pilot is safely onboard, the ship may return to the original course or the next leg. Note that small freeboard vessels may experience decks being awash due to rolling so the safety of the pilot should be fully taken into consideration when determining both the lee, the boarding operation, and when to resume course.
  • On large high freeboard vessels, it is very difficult to judge the height of the lowest pilot ladder step above the water. Dipping and heaving back up ensures the height of the ladder from the water level is always correct.
  • For situational awareness, the Master should be on the bridge wing to ensure the safety of the transfer. The Master will need to keep a close eye on the sea and weather for the lee and con the vessel remotely. Bridge team management and good communication are essential at this critical time, to ensure the vessel’s position and traffic in the vicinity are being effectively monitored.
  • Creating a lee and boarding/disembarking a pilot requires a professional skill. It is essentially a narrow window in time, position and weather. The lee should be co-ordinated with the pilot and launch. Preparation, planning and constant situational awareness are necessary so that it is safely and efficiently performed in one synchronized movement.


  • Plan well in advance: Commence the required speed, time and distance management calculations twelve hours prior to arrival at the pilot boarding ground. Any adjustments should be limited to minor changes of speed as opposed to large course alterations, particularly in areas of dense traffic.
  • Prepare the pilot boarding arrangements properly
  • Ensure that VHF communications are limited solely to the pilot scheduling and boarding operation. Any discussion relating to traffic management and application of the Collision Regulations is strongly discouraged.
  • Keep to your ETA and constantly review your progress.
  • Create a timely and efficient lee for the pilot transfer with the Master on the bridge wing. Ensure that situational awareness and effective bridge team management is maintained.
  • Give every vessel at the pilot boarding ground space and time for them to conduct their operations in a safe and seamanlike manner.
  • Let the outbound vessel disembark the pilot and clear first. They invariably have the tightest constraints.
  • The inbound vessel has a bigger challenge to make all the above happen safely and without causing confusion or anxiety to others. This requires proper planning and constant monitoring to ensure that timing is correct upon approaching a pilot boarding ground at a manageable steady speed.

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Source: ChirpMaritime


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