Operational Guide · Registers & Logbooks

# Means of Escape and Emergency Escape Routes

Every Category A machinery space requires two independent means of escape, but the exact meaning of 'lower part of the space' remains subject to differing interpretations among Administrations: an issue reopened by the IMO SDC sub-committee in 2026.

means of escape means of escape SOLAS II-2/13 machinery space

## Operational Explanation

Means of escape must ensure that personnel on board can safely and quickly reach the embarkation deck for lifeboats and liferafts in an emergency. For Category A machinery spaces, SOLAS requires two independent means of escape: one of the two must be located within an enclosed protected route and extend from the lower part of the space to a safe position outside.

Inclined ladders forming part of the means of escape in the engine room, but not located within a protected enclosure, must not have an inclination exceeding 60° nor a clear width less than 600 mm. The Maritime Safety Committee has noted differing interpretations among Administrations of the meaning of "lower part" of the space in Regulations II-2/13.4.1 and 13.4.2, with a review scheduled on the agenda of SDC sub-committee 12 (January 2026).

## Regulatory Reference

SOLAS Chapter II-2, Regulation 13 (Means of escape), in particular Regulations 13.4.1.1.1 and 13.4.2.1.1 for Category A machinery spaces: two independent means of escape required, one within a protected enclosure. Differing interpretations of the term "lower part of the space" under review by the SDC sub-committee since January 2026.

## Scope of Application

Every ship subject to SOLAS Chapter II-2, with particular attention to Category A machinery spaces where the risk of rapid fire spread makes the availability of two independent, functional means of escape critical.

## Procedure / How to Complete It

1. Verify that every Category A machinery space has two independent means of escape, as required by SOLAS II-2/13.4.
2. Confirm that at least one of the two means of escape is located within a protected enclosure, extending from the lower part of the space to a safe position outside.
3. Verify that inclined ladders forming part of unprotected means of escape comply with the inclination (max 60°) and width (min 600 mm) limits.
4. If an escape trunk cannot be extended to the lowest level of the space due to construction constraints, prepare a detailed technical statement justifying the configuration, formally accepted by the flag Administration.
5. Keep the complete documentation of the means of escape (approved plans with calculations, installation certificates for fire doors/dampers, training and drill records) always available on board.

## Practical Example

Example: at the design stage of a new unit, a construction constraint prevents the escape trunk from being extended to the lowest level of the engine room; the shipyard prepares a detailed technical statement justifying the alternative configuration adopted, submitted to and formally accepted by the flag Administration before the plan is approved.

## Real Cases

The interpretive divergence over the meaning of "lower part of the space" among different flag Administrations led the Maritime Safety Committee to include a review of Regulations II-2/13.4.1 and 13.4.2 on the provisional agenda of SDC sub-committee 12 (January 2026): an example of how an apparently technical regulatory ambiguity can create real practical uncertainty for shipyards and Companies during design and approval.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Means of escape from Category A machinery spaces verified only for their formal existence, without verifying the actual independence of the two routes | Both means of escape potentially compromised by the same event (e.g. a fire blocking a single common route) | Verify the actual physical independence of the two means of escape, not just their formal presence on the plan
Inclined ladders in the means of escape not verified against the required inclination and width limits | Means of escape formally present but not compliant with dimensional safety requirements | Always verify the inclination (max 60°) and width (min 600 mm) of unprotected inclined ladders
Alternative escape trunk configuration adopted without a technical statement formally accepted by the flag Administration | Non-compliant configuration, potentially challenged during subsequent inspections | Always obtain formal acceptance from the flag Administration for any alternative escape trunk configuration

## PSC Observations

PSCOs verify the presence and actual functionality of the means of escape from Category A machinery spaces, including the technical documentation justifying any alternative configurations accepted by the flag Administration.

## Operational Tips

- Don't just verify the formal presence of two means of escape: verify that they are actually independent of each other.
- Keep track of developments in the 2026 SDC review on the interpretation of 'lower part of the space', as it could change the applicable requirements.
- Always keep the complete technical documentation of the means of escape on board, including any agreements with the flag Administration on alternative configurations.

## Checklist

- Two independent means of escape verified for every Category A machinery space
- At least one means of escape confirmed within a protected enclosure down to the lower part of the space
- Unprotected inclined ladders compliant with inclination and width limits
- Technical statement for alternative configurations accepted by the flag Administration, if applicable
- Complete means-of-escape documentation available on board

## FAQ

How many means of escape does a Category A machinery space require?
Two independent means of escape, as required by SOLAS II-2/13.4.1.1.1 and 13.4.2.1.1; at least one must be located within a protected enclosure.
What limits apply to inclined ladders forming part of unprotected means of escape?
An inclination not exceeding 60° and a clear width not less than 600 mm, per the established interpretations of SOLAS II-2/13.
Why is a review of the means of escape rules under way in 2026?
Because the Maritime Safety Committee has noted differing interpretations among Administrations of the meaning of the term 'lower part of the space', with a review of Regulations II-2/13.4.1 and 13.4.2 scheduled at SDC sub-committee 12 in January 2026.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Fire Drill and Fire Safety Damage Control and Blackout Management (IT)

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