PSC Inspection Target: Vessels whose keel was laid on or after 1 February 2016.

PSC Inspection Method (2-step process): Step 1: Check if the engine room escape trunk extends to the lowest level. If it does not extend to the lowest level (Verify that the lower entrance of the Escape Trunk in the engine room is installed as low as possible to the engine room floor deck), the vessel will be deemed non-compliant, and Step 2 verification shall be conducted.

Step 2: Order the crew to conduct a casualty rescue drill in the engine room. Specifically, assume a crew member is injured at the engine room’s lowest level; PSC will time how long it takes to evacuate the injured crew through the escape trunk with assistance. The vessel will be deemed non-compliant if the evacuation exceeds 3 minutes.

Deficiency Rectification Measures After PSC Detention: To secure release after detention, the vessel must meet three requirements: ① the engine room rescue drill complies with standards; ② a flag state declaration confirming drill compliance is provided; ③ a statement is included in the PSC re-inspection report acknowledging the escape trunk non-conformity specified in the Safety Construction Certificate, with a commitment to rectification during the next dry docking. (The emergency escape trunk of the engine room, which is elevated above the engine room’s lowest deck level, to be dealt with as per applicable approved drawing by the next scheduled dry docking.）

The engine room escape trunk of the vessel does not extend to the lowest level. Vessel berthed at Shanghai Port. Detention prevention measures for this item are as follows:

Step 1: Contact the flag state and classification society to submit a statement certifying that the escape trunk cannot be installed at the lowest level due to objective constraints such as vessel structure.

Step 2: Intensify training on engine room casualty rescue drills before the vessel berths at the port. Although there is no statutory time requirement for this drill in the conventions, the vessel will generally be deemed compliant by PSC if firefighters can successfully rescue the casualty within 3 minutes while wearing firefighting equipment. （It is recommended to complete the process of identifying an injured person in the engine room while wearing fireman's outfit, transferring the injured person into the escape trunk, and preparing them for hoisting within 3 minutes.）

PSC Inspection Convention Basis: The inspection basis combines SOLAS II-2/Reg.13.4.2.1 and the interpretation of the lower part of the space specified in MSC.1/Circ.1511/Rev.1, details are as follows:

SOLAS II-2/Reg.13.4.2.1：two sets of steel ladders as widely separated as possible leading to doors in the upper part of the space similarly separated and from which access is provided to the open deck. One of these ladders shall be located within a protected enclosure that satisfies regulation 9.2.3.3, category (4), from the lower part of the space it serves to a safe position outside the space……(Two steel ladders spaced as far apart as possible from each other, leading to doors at the upper part of the space which are also spaced far apart from each other, with access provided from these doors to the open deck. One of the steel ladders shall be located within a protected enclosure that meets the requirements of Category (4) in Regulation 9.2.3.3, extending from the lower part of the space it serves to a safe location outside that space.)

MSC.1/Circ.1511/Rev.1(Revised and Implemented on 26 June 2024)：Machinery spaces of category A may include working platforms and passageways, or intermediate decks at more than one deck level. In such case, the lower part of the space should be regarded as the lowest deck level, platform or passageway within the space.  At deck levels, other than the lowest one, where only one means of escape other than the protected enclosure is provided, self-closing fire doors should be fitted in the protected enclosure at that deck level. Smaller working platforms in-between deck levels, or only for access to equipment or components, need not be provided with two means of escape (regulation II-2/13.4.2.1). 

Demonstration Diagram:

No dispute over the escape trunk reaching the lowest level as shown above.

Yet two scenarios apply if it can’t reach the lowest level (per latest feedback):

Scenario 1: Escape trunk not reaching lowest level due to vessel design can be deemed compliant. Examples:

In the figure above, the escape trunk fails to reach the lowest level due to vessel structure, yet PSC approves it as compliant.

In the figure above, the escape trunk does not extend to the lowest level as there are pipelines beneath it, yet it is deemed compliant by PSC.

Scenario 2: Escape trunks deemed non-compliant. Examples are as follows:

Above: Available space exists under the escape trunk; it can reach the lowest level but does not, so PSC deems it non-compliant.

--------------------------------------------Reprinted from PSCReady