DRAFT, needs technical review. Not for publication. The title is our own wording, not the official Paris MoU text.
PSC deficiency code 02109: Permanent means of access in the cargo area (tankers and bulk carriers)
| Category | Structural / machinery (SOLAS II-1) — applies to oil tankers ≥500 GT and bulk carriers ≥20,000 GT (cargo area) |
| Related certificate | Cargo Ship Safety Construction |
| Main references | SOLAS II-1/3-6 and res. MSC.158(78) |
| Typical action codes | 17 (rectify before departure), 30 (detainable) if serious |
| Commonly detainable? | Can be, depending on severity (no statistics claimed) |
What PSC officers look for
- Missing or damaged gratings and handrails
- Unsafe ladders without fall protection where required
- Corroded steps in ballast or cargo access
- Obstructed access for routine inspection in the cargo area
- Enclosed-space entry procedures not aligned with IMO res. A.1050(27) where enclosed spaces are accessed from the cargo area
Typical root causes
- Corrosion not prioritised in maintenance budget
- Removed grating not replaced after job
- Assumption that portable ladders are acceptable
- Poor coordination with charterer delay pressure
Corrective action (example)
Renew corroded access structures in the cargo area; reinstall gratings; restore handrails and anti-slip; update enclosed-space procedures per res. A.1050(27) where relevant.
Preventive action (example)
Include access structures in hull inspection scope; stock spare grating sections.
Evidence to attach for close-out
- Photos of renewed access
- Class surveyor note if attended
- PMS jobs
- Risk assessment for enclosed space
Related
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Official code list: Paris MoU, List of Deficiency Codes (1 July 2026). Action codes: Paris MoU, Inspection outcome. Reviewed by: _pending_ · Review date: _pending_ This page is general guidance, not legal, flag or class advice. Always follow the PSC officer's instructions and your flag and class requirements.