The American Bureau of Shipping (ABS) has issued guidance for cargo ships equipped with rescue boat launching appliances that rely entirely on manual operation without stored mechanical power.
The guidance follows the adoption of IMO Resolution MSC.459(101), which introduced an exemption applicable only to rescue boats installed on or after 1 January 2024. The exemption does not apply to systems installed before that date, meaning existing arrangements remain subject to previous requirements.
During a recent Port State Control (PSC) inspection at a Europe an port, a container ship (keel laid December 2008) received deficiency Code 11113 – Launching arrangements for rescue boats. The PSC officer reported that:
- The rescue boat davit could not be slewed out using stored mechanical power or gravity
- It was not possible to actuate the launch from a position within the rescue boat
- No Flag State acceptance of the alternative arrangement could be demonstrated on board
The vessel’s dedicated rescue boat weighed 610 kg, fully equipped with engine and without crew. The manual hand crank operated launching arrangement consists of a single-arm radial davit without a hydraulic accumulator.
The PSC argued that the amended LSA Code paragraph 6.1.1.3 (introduced by Resolution MSC.459(101)) applies only to rescue boats installed on or after January 1, 2024. An alternative design for the rescue boat davits may be accepted if it can be clearly demonstrated that it had been approved or accepted by the flag Administration. At the time of the inspection, such approval or acceptance could not be demonstrated.
The regulatory framework
In 2019, IMO adopted Resolution MSC.459(101), which amended the LSA Code to allow manually operated launching appliances for dedicated rescue boats weighing up to 700 kg (fully equipped but without crew), provided specific safety conditions are met, including limits on manual operating force and requirements for safe embarkation. However, the amendment only applies to rescue boats installed on or after 1 January 2024 and does not apply retrospectively to older installations.
In 2025, IMO issued MSC.1/Circ.1693 to clarify the interpretation of the amended LSA Code requirements. The circular confirmed that manual hoisting of a dedicated rescue boat from its stowed position is considered part of launching preparation rather than the launching process, and that manual operation does not need to be performed from inside the rescue boat for systems covered by the amended requirements.
However, the interpretation applies only to arrangements meeting the requirements introduced by Resolution MSC.459(101) and does not extend the exemption to rescue boat launching systems installed before 1 January 2024.
Regulatory implications for existing vessels
Where a rescue boat was installed before 1 January 2024 and its launching arrangement relies solely on manual operation without stored mechanical power, the installation may be considered non-compliant with the unamended provisions of paragraph 6.1.1.3 unless the arrangement has been formally accepted by flag Administration under SOLAS regulation I/5.
This situation creates a regulatory gap for some existing vessels:
- Many existing cargo ships have manual rescue boat launching arrangements that are safe, functional, and long-accepted
- IMO has codified these arrangements as acceptable for new installations, confirming they achieve an equivalent level of safety
- But the codification was prospective only, and the pre-existing flag Administration acceptances were not always formally documented
- As a result, PSC authorities may raise deficiencies against existing vessels that are unable to demonstrate documented flag Administration acceptance of their arrangements
Recommendations
For existing cargo ships where the rescue boat was installed before 1 January 2024 and the launching arrangement relies on manual operation, ABS recommends the following actions:
- Verify and document certain technical particulars
- Obtain formal Flag State acceptance: For existing manually operated rescue boat launching arrangements, the appropriate compliance pathway is generally through acceptance by the flag Administration under SOLAS regulation I/5 (Equivalents), rather than a direct claim of compliance with the amended provisions of paragraph 6.1.1.3 of the LSA Code. Owners and operators should contact their ABS office and request assistance in seeking formal flag Administration confirmation of acceptance. When submitting such requests, supporting technical information should be provided, together with references to Resolution MSC.459(101) and MSC.1/Circ.1693, as evidence that the arrangement achieves an equivalent level of safety.
- Maintain documentation on board: Any flag Administration acceptance, equivalency approval, or other supporting documentation should be retained on board with the vessel’s statutory certification records and be readily available for review during PSC inspections.
- Brief masters and vessel personnel: Masters and vessel personnel should be made aware of Resolution MSC.459(101) and MSC.1/Circ.1693. The primary document supporting continued acceptance is the flag Administration approval or equivalency determination. Vessel personnel should also be familiar with the operation of the launching arrangement and be prepared to demonstrate its functionality, if requested.