Passenger Accounting: The Accuracy of the Roll-Call after Costa Concordia
SOLAS III/27 governs counts and information before departure; during an emergency, the accountability method comes from the ship's approved procedure and SMS.
Operational Explanation
Separate the pre-departure passenger information system from emergency accountability. SOLAS III/27 requires the count, information on persons needing assistance and prescribed data before departure; it does not mandate a universal name-by-name roll-call at assembly stations.
Regulatory Reference
SOLAS III/27 addresses counting and rescue information; III/8 and III/37 address instructions and muster lists. For CVSSA-reportable incidents, 46 USC 3507(g)(3) distinguishes prompt telephone reporting to the FBI and written reporting to the website maintained by the Secretary of Transportation. The specified disappearance category is a missing United States national, subject to jurisdictional conditions; this is not a universal CVSSA reporting rule for every disappearance worldwide. Applicable alerting and rescue duties remain for every person. 46 USC 3507.
The duty to count, however, is not in III/8. It is in SOLAS Regulation III/27, Information on passengers, worth reading in full because it is short and is invariably quoted from memory. Paragraph 1: “All persons on board all passenger ships shall be counted prior to departure”. Paragraph 2: details of persons who have declared a need for special care or assistance in emergency situations are recorded and communicated to the master prior to departure. Paragraph 3: “In addition, not later than 1 January 1999, the names and gender of all persons on board, distinguishing between adults, children and infants shall be recorded for search and rescue purposes”. Paragraph 4: that information “shall be kept ashore and made readily available to search and rescue services when needed”. Paragraph 5: Administrations may exempt ships from paragraph 3 where their scheduled voyages make keeping such records impracticable.
Three observations that head off three errors. The date “Not later than 1 January 1999” in paragraph 3 is not a leftover from an old edition: it is in the text in force, a spent transitional date never tidied out. Readers sometimes conclude they are holding a superseded version of the Convention, and need reassuring.
SOLAS III/27 specifies name, gender and adult/child/infant distinction. Nationality is additionally recommended by MSC.1/Circ.1446/Rev.2, §14; this is distinct from a III/27 obligation. Under the relevant EU regime for legs exceeding 20 nautical miles to the next port, Article 5 of Directive 98/41/EC also requires nationality and date of birth, subject to applicable derogations. MSC.1/Circ.1446/Rev.2.
Third: III/27 binds passenger ships on international voyages; 98/41/EC applies to ships operating to or from ports of Member States, including the domestic voyages SOLAS does not reach. For a ship trading in Europe the two regimes stack, and the more demanding one is the European.
Directive 98/41/EC distinguishes counts from personal data. Article 4: count and inform the master before departure, then report through the single window or to the designated authority via AIS under the applicable arrangements. Article 5: collect personal data before departure and report through the single window on departure, no later than 15 minutes afterwards; AIS does not replace the named list. Check exclusions, derogations and national implementation. Directive 2017/2109.
Article 8 addresses the passenger registrar and pre-departure notification to the master of declared assistance needs. Company data collected for this Directive must not be retained longer than necessary: after safe completion and reporting, erase them automatically without undue delay, without prejudice to other specific legal obligations consistent with data protection. Distinguish company records from authority records.
The transitional option of reporting only to the registrar/shore system ended on 20 December 2023; this does not remove the AIS alternative for person counts. Regulation 2019/1239 on EMSWe applies from 15 August 2025: check the operational national channel and submission receipts. European Commission: EMSWe.
Current 46 USC 3507(k) cumulatively requires authorization for at least 250 passengers, overnight accommodation for at least 250, and a voyage embarking or disembarking passengers in the US; check federal/state-vessel exclusions. Do not use the old coastwise-voyage exclusion.
The muster list assigns emergency duties to crew and is not the named passenger list. The accountability procedure should assign responsibility for collecting and reconciling attendance, missing persons and search results, with a fallback if electronic scanning fails.
Section 3507(g)(1)(B) grants requested logbook access to FBI, USCG and competent investigators. CVSSA reports are distinct from separate marine-casualty reporting duties applicable to the vessel; do not wait for internal findings before the prompt FBI call.
Scope of Application
Before departure apply SOLAS III/27 and, where relevant, EU and National Single Window requirements. In an emergency apply the approved procedure/SMS method, which may combine roll-call, electronic scanning and search teams.
Procedure / How to Complete It
- Complete count and passenger information before departure.
- Record and transmit special-assistance information under the applicable regime.
- In an emergency use the accountability method set by the approved procedure/SMS.
- Reconcile results and searches without attributing the method directly to III/27.
Practical Example
Example: during an abandon-ship drill, the person in charge of an assembly station carries out the name-by-name roll-call against the assigned list, immediately reports to the bridge two names found absent, and waits for confirmation before declaring the station complete, following the Company's documented procedure.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Counting of those present at assembly stations left to individual initiative, without a written and assigned procedure | As in the Costa Concordia case, inability to establish with certainty who is actually present or missing | Define and exercise a written, assigned counting procedure for every assembly station |
| Discrepancies between attendance recorded and the muster list not reported immediately to the bridge | Delay in searching for people actually missing during the emergency | Report every discrepancy found immediately, without waiting for the count of the entire ship to be completed |
| Disappearance reporting procedures to the Coast Guard/FBI not kept up to date for ships subject to CVSSA | Regulatory non-compliance and delayed notification to the competent authorities | Always keep the reporting procedures required by CVSSA up to date for ships meeting all cumulative conditions in § 3507(k)(1) |
What the PSCO Checks
Operational Tips
- Do not leave the counting method implicit: write it explicitly into the emergency procedure and exercise it regularly.
- Report every discrepancy found immediately to the bridge, however minor: the Costa Concordia case teaches that delays accumulate.
- For ships subject to CVSSA, always keep the procedures for reporting disappearances to the competent US authorities up to date.
Preparation checklist
- Pre-departure count complete
- Data and special-assistance information available
- EU/NSW requirements checked
- Emergency-accountability method defined in SMS
FAQ
Related Topics
Last substantive revision of this page: 16 September 2026 · page fingerprint 24860a40e259