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Emergency escape from machinery spaces category A

DNV has encountered instances where ships have been detained during Port State Control (PSC) inspections due to the arrangement of emergency escape trunks from machinery spaces. Despite these arrangements having been approved by the flag state or their Recognized Organization, the PSC authorities have deemed them non-compliant. This news provides more explanations and guidance on this situation.
Emergency escape from machinery spaces category A
Regulatory background
SOLAS Regulations II-2/13.4.1.1.1 and 13.4.2.1.1 require two means of escape to be provided from each machinery space of category A. When two sets of steel ladders are provided to comply with this regulation, one of them shall be located within a protected enclosure and extend from the lower part of the space it serves to a safe position outside the space.
IMO Unified Interpretation (UI) MSC.1/Circ.1511/Rev.1, which was first approved in 2015, states that machinery spaces may include working platforms and passageways, or intermediate decks at more than one deck level. In such cases, the lower part of the space should be regarded as the lowest deck level, platform or passageway within the space.
MSC.1/Circ.1511/Rev.1 also states that inclined ladders/stairways in machinery spaces being part of, or providing access to, escape routes but not located within a protected enclosure should not have an inclination greater than 60° and should not have a clear width of less than 600 mm.
IACS UI SC 277 is implemented by IACS societies on ships contracted for construction on or after 1 February 2016. This interpretation is identical to the UI of SOLAS Regulations II-2/13.4.1 and 13.4.2 in MSC.1/Circ.1511/Rev.1.
Emergency escape from machinery spaces category A
Industry practice
On many ships, the protected emergency escape trunk does not, for various reasons, extend all the way down to the lowest deck level of the engine room.

Common industry practice involves using an inclined ladder from the lowest deck level of the engine room to a platform above the deck, providing direct access to the escape trunk. This arrangement is often necessary due to the hull shape, structural elements and technical installations that prevent the escape trunk from extending to the lowest deck of the engine room.
PSC authorities
PSC authorities are concentrating on vessels contracted for construction or with keels laid on or after 1 February 2016 since these must comply with IACS UI SC 276/277, as reflected in MSC.1/Circ.1511/Rev.1, by IACS societies.
Certain port states consider arrangements where the escape trunk does not extend all the way to the lowest deck of the engine room to be non-compliant with SOLAS. They have indicated a focus on these arrangements and advised that vessels without flag administration acceptance, and where arrangements are not extended as low as possible, will be subject to detention.
Following the increased focus on the arrangement of the emergency escape trunk, certain PSC inspections have established a practice of requesting the crew to conduct an evacuation/rescue drill. This drill involves evacuating an injured person on a stretcher from the lowest deck, up the ladder, and into the protected trunk. We have seen instances of vessels being detained if the drill does not meet the satisfaction of the PSC officer. Evacuation time could be considered one criteria.
Flag state administrations
For vessels having escape trunks not extending down to the lowest deck level in the engine room, a technical justification on why the emergency escape trunk cannot be extended to the lowest deck level could be required by flag and/or port state control. The justification could include considerations such as lack of space due to structural design, equipment and/or machinery installations blocking the area, and the need for maintenance access and space. It is further recommended to include a description of how the present arrangement supports safe and easy access to the escape trunk.
This technical justification shall be presented to the flag administration of the vessel for review and formal acceptance.
Discussions at the IMO
This matter was discussed during the recent 11th session of the IMO Sub-Committee on Ship Design and Construction (SDC 11), held from 13 to 17 January 2025. SDC 11 considered a proposal to revise the UIs of SOLAS Regulations II-2/13.4.1 and 13.4.2 in MSC.1/Circ.1511/Rev.1, aiming to further clarify the term “lower part” in relation to escape routes from areas below the bulkhead deck.
SDC 11 could not agree on further clarifications of the UI. SDC 11 confirmed that the current UI of the “lower part of the space” should be understood as either the lowest deck level or a platform or passageway; however, due to some opposing views, SDC 11 could not conclude that the text should not be understood as “whichever is lowest”.
SDC 11 agreed to invite the Sub-Committee on Implementation of IMO Instruments (III 11) meeting in July 2025 to also consider this matter, as appropriate, since the discussion raised questions related to PSC activities.
Recommendations
For vessels contracted for construction (or keel laid) on or after 1 February 2016, it is recommended that a technical justification is developed detailing why the emergency escape trunk does not extend to the lowest deck level of the engine room. This justification should be reviewed and accepted by the flag administration, kept on board the vessel and be available for presenting to the PSC or other parties when required. DNV may assist in the above.
For ships whose emergency escape trunk does not lead to the lowest deck of the engine room, the following measures are recommended:
Update the Safety Management System (SMS): ensure the SMS includes procedures for rescue drills to evacuate injured persons from the engine room.
Conduct regular drills: familiarize the crew with the on-board arrangements and practice rescue drills regularly. These drills shall be recorded as required by the company’s SMS.

DNV