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 Not for publication.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

  • Codes: 02108, 13101, 02101
  • SIRE 2.0: Chapter 8 (structure) (chapter reference only)

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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.

Next steps

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