Ro-Ro Locker Compliance Changes: What Surveyors Are Now Looking At in PSSC Surveys

Ro-Ro vessels reaching 20+ years in service are increasingly being subject to more detailed inspection during certification and survey processes. As these vessels continue through extended lifecycles, expectations around onboard safety equipment, and just as importantly the documentation associated with it, appear to be evolving.

In particular, Passenger Ship Safety Certificate (PSSC) surveys are increasingly highlighting greater attention on the traceability, certification, and individual identification of equipment stored within Ro-Ro safety lockers.

From our experience supporting ship operators and shipyards, this is gradually influencing how lockers are specified, documented, and maintained over time.

Historically, Ro-Ro safety lockers were often supplied and assessed as complete, pre-approved units. In many cases, once the system approval was in place, the assumption was that the contents were covered under the wider certification, provided the locker remained unchanged.

More recently, we are seeing a shift in approach during surveys, where greater attention is being placed on individual components within the locker rather than only the system as a whole.

This does not necessarily indicate a formal change in all regulatory frameworks, but it does suggest a trend toward more detailed verification of the items contained within safety systems.

As a result, compliance discussions are increasingly focused not only on the locker itself, but also on the equipment inside it and how clearly each item can be identified and traced.

One of the most notable trends observed in recent PSSC survey activity is the increased interest in item-level traceability.

In a number of cases, surveyors appear to be requesting supporting information such as:

• Serial numbers for individual components
  
• Date of manufacture, often referred to informally as “birthdate”
  
• Defined service life or expected lifecycle guidance
  
• Certification relevant to specific lifting-related items
  
• Evidence of Safe Working Load (SWL) ratings
  

This reflects a broader industry move toward understanding equipment at a more granular level, rather than relying solely on system-wide approval.

In practice, this means lockers are often viewed less as a single certified assembly and more as a collection of individually verifiable components.

A particular area where this trend appears more consistently is lifting equipment and recovery arrangements within Ro-Ro lockers.

These systems are often used in casualty recovery or man-overboard scenarios, where controlled lifting capability is an important factor.

In recent surveys, we have observed increasing attention being given to:

• SWL identification across lifting components
  
• Certification for lifting tripods and associated systems
  
• Clarity around assembled lifting arrangements as well as individual parts
  
• Alignment with onboard lifting safety practices, including where LOLER principles may be applied
  

In some cases, equipment that was previously accepted as part of a broader certified system is now being reviewed more closely at component level, particularly where load-bearing performance is involved.

This reflects a gradual shift in how lifting safety arrangements are interpreted during inspections rather than a universal change in requirement.

Another area that appears to be gaining attention is the lifecycle management of certain locker contents.

Some items commonly included in Ro-Ro lockers, such as lifting strops or recovery components, may have defined manufacturer guidance relating to service life. These lifespans can vary depending on product type, usage environment, and how the equipment is used onboard.

As part of survey preparation, we are increasingly seeing interest in:

• Manufacturing dates for individual items
• Records of time in service
• Awareness of manufacturer-recommended lifecycle limits
• Replacement planning for time-expired equipment

This introduces a more structured approach to equipment oversight, where age and traceability are considered alongside physical condition.

In day-to-day discussions with operators and shipyards, one of the more common challenges is a mismatch between what is specified and what is actually required under regulations.

A clear example of this is the wooden rope ladder configuration within Ro-Ro lockers.

While some specifications request longer or non-standard ladders, the general regulatory baseline for Ro-Ro applications is commonly understood to be:

• A rope ladder of no less than 10 metres in length

In some cases, overspecification can lead to unnecessary complexity or confusion during survey discussions, particularly where expectations differ between procurement and inspection perspectives.

This highlights the value of aligning specifications with clearly understood baseline requirements where possible.

Across a number of recent projects, documentation appears to be playing an increasingly important role in survey preparation.

Rather than focusing solely on physical presence of equipment, attention is often given to whether supporting information is available and clearly structured.

This typically includes:

• Records of locker contents
  
• Individual certification for lifting-related equipment
  
• SWL documentation for load-bearing components, like lifting strops
  
• Serial number and manufacturing date traceability
  
• Supporting evidence of relevant safety standards
  

In some cases, gaps in documentation can lead to additional clarification requests during inspection, even where equipment itself is in good condition.

For operators managing Ro-Ro vessels in longer service life cycles, these trends may be contributing to a more detailed approach to equipment management over time.

Common considerations we are seeing include:

• Greater emphasis on traceable inventory records
  
• More structured documentation packs per locker
  
• Periodic review of equipment lifecycle status
  
• A shift toward actively managed safety equipment rather than static locker sets
  

For shipyards and procurement teams, this also highlights the importance of considering not only how the equipment functions, but also how easily it can be documented, tracked, and presented during survey activity.

Overall, the direction of travel appears to be toward greater traceability and clearer documentation across Ro-Ro safety systems.

This aligns with wider maritime safety themes focusing on accountability, lifecycle visibility, and verifiable equipment history.

From an operational perspective, this does not necessarily mean immediate change is required. However, it may indicate that expectations around documentation and traceability are gradually becoming more central to survey discussions.

As these trends continue to develop, many operators are beginning to review how Ro-Ro lockers are structured, documented, and maintained.

To support this, we have also put together a practical Ro-Ro Locker Compliance Checklist.

This provides a simple reference point for equipment and documentation commonly referenced during PSSC survey preparation, based on current industry observations.