Subj: PILOT LADDER, EMBARKATION LADDERS, 16714
AND PILOT TRANSFER ARRANGEMENTS CG-ENG Policy Letter No. 01-21
April 7, 2021
2
c. NVIC 4-91, reference (f), provides pilot transfer guidance based on IMO Resolution
A.667(16), reference (g). Resolution A.667(16) was superseded by IMO Resolution
A.889(21), reference (h). Resolution A.889(21) was later superseded by IMO Resolution
A.1045(27), reference (i). The Coast Guard is in the process of cancelling NVIC 4-91
because the IMO guidance it is based on has been superseded. IMO Resolution
A.1045(27) is included as enclosure (1).
d. ISO 799-1:2019 and ISO 5489:2008 provide current design and testing guidance for pilot
ladders and embarkation ladders. ISO 799-1:2019 supersedes ISO 799:2004 and ISO
5489:2008 was re-affirmed in 2018.
e. Mechanical pilot hoists, while are included in U.S. regulations, are prohibited by SOLAS
Chapter V Regulation 23. There are no Coast Guard approved pilot hoists.
3. Discussion.
a. Pilot ladders tested by a Coast Guard accepted independent laboratory and found to
comply with ISO 799-1:2019 are, pursuant to 46 CFR 163.003-9(c), approved alternatives
to ladders meeting approval series 163.003. Such pilot ladders also satisfy SOLAS
Chapter V Regulation 23.
b. Embarkation ladders tested by a Coast Guard accepted independent laboratory and found
to be in compliance with ISO 5489:2008 are, pursuant to 46 CFR 160.017—9(c) and 46
CFR 199.09, approved alternatives and equivalents to approval series 160.017 and
160.117. Such embarkation ladders also satisfy SOLAS Chapter III Regulation 11.7, and
paragraph 6.1.6 of the International Life-Saving Appliance Code.
4. Action.
a. Manufacturers are strongly encouraged to produce ladders that comply with ISO 799-
1:2019 and ISO 5489:2008, as applicable. Further information on the material to be
submitted to receive Coast Guard approval is located at https://www.dco.uscg.mil/CG-
ENG-4/Ladders/.
b. Manufacturers of pilot ladders intended for use on a vessel engaged in international
voyages should ensure they provide certification of the ladder’s compliance with SOLAS
Chapter V Regulation 23.
c. Manufacturers of pilot ladders and embarkation ladders intended for use on a vessel
engaged in international voyages should ensure they are marked in accordance with ISO
799-1:2019 and ISO 5489:2008. This includes “ISO 799-1” or “ISO 5489” and “SOLAS”.
d. Operators of vessels embarking or disembarking maritime pilots away from the dock are
strongly encouraged to comply with the pilot transfer arrangements described in enclosure
(1). The Coast Guard also recommends that all vessels obtain the poster illustrated in
enclosure (2) and post it where it is accessible. It is available for download on the
International Maritime Pilots’ Association’s website at www.impahq.org.
5. Disclaimer. The guidance in this policy letter is not a substitute for applicable legal
requirements and is not a rule. It does not impose legally binding requirements on any party.
This guidance represents the USCG’s current thinking on this topic and may assist industry,
mariners, the public, and the Coast Guard, as well as other Federal and state regulators, in
applying statutory and regulatory requirements. An alternative approach for complying with