External Access to Means of Escape
One important issue for Companies in the development of their Ship Security Plans – SSP – is how to deal with restricted areas making part of means of escape.
The UK Maritime and Coastguard Agency – MCA – has issued an important guidance on this subject: the MARINE GUIDANCE NOTE MGN 426 (M), which extract can be found below for easy reference:
- Introduction: The conflict between international safety and security requirements with regard to locking the doors on escape routes while providing a means of escape is frequently reported by ship operators and designers.
- Background: Many parts of the ISPS Code require doors to be secured against unauthorised access. This includes doors on escape routes. For safety reasons such locks must not impede emergency escape. Over the years many ways for overcoming this conflict have been adopted. Unfortunately some unacceptable methods do not allow access from outside the space in an emergency.
- Passenger ships and cargo ships: different specificities were considered for passenger ships (SOLAS II-2/13.3.2.6.1 requires “Cabin and stateroom doors shall not require keys to unlock them from inside the room. Neither shall be any doors along the escape route which require keys to unlock them when moving in the direction of escape”) and for cargo ships (although SOLAS II-2/13.4.2.1.2 does not explicitly require every door leading to the open deck to be capable of being opened from both sides, MSC/Circ.1120 outlines the philosophy that “means of escape” referenced in SOLAS II-2/13.3.3 must be accessible from both sides).
- Methods of Securing Doors: it is recognised that security requires that access to “restricted areas” is controlled. Both the safety and security requirements have to be met and various methods of achieving this have been employed.
Examples of unacceptable methods:
“dead bolt latches‟ on the inside
Planks of wood across the door handles internally
Internally lashed doors with emergency knife
Door locks with no external keyhole
Examples of acceptable methods:
Key-pad door locks which in their failure mode open the lock
Swipe-card locks which in their failure mode open the lock
A padlock key control system and an internal quick release device
Door locks with internal release device and an external lock with key control system
Latch dogs with a removable handle that require a special shaped head for opening them externally, with the handle readily available for emergency use.
Use of customs tags to show restricted area has not been breached coupled with a patrol system to verify integrity of tag
Door alarm coupled with a response system to investigate when alarm sounds
The acceptable methods described above also require appropriate operational procedures to be in place to ensure that the means of access is readily accessible in an emergency. Examples of this are: procedures for access to and use of keys and codes; or searches of restricted areas to verify their integrity after a suspected breach.
Examples of door securing devices with internal release, including diagram and pictures of acceptable arrangements were presented.
The full document can be downloaded from the MCA website and may also be found here.
Source: UK MCA