Lifeboat rules: SOLAS III, LSA Code and MSC.402(96)

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In 2001 the UK Marine Accident Investigation Branch (MAIB) looked back over ten years of its data and found something uncomfortable: lifeboats and their launching systems had killed 12 professional seafarers, 16% of all lives lost on UK merchant ships, and injured 87. None of those people died in a real abandonment. Every accident happened during a drill or a test, with experienced, qualified seafarers doing or supervising the work.

Almost every rule in this course was written in response to accidents like those. Knowing where each rule sits, and who it puts in charge of each job, is the first skill of anyone who inspects, services or commands a lifeboat. Get it wrong and you either do work you are not allowed to do, or you accept a certificate that is worth nothing.

Try it

Who is allowed to do this job?

In plain words

Three layers of rules apply to a lifeboat on a ship that trades internationally.

The first layer is the law: the International Convention for the Safety of Life at Sea (SOLAS), Chapter III. It says what the ship must carry, how often the crew must drill, and what must be checked every week, month, year and five years.

The second layer is the design standard: the International Life-Saving Appliance (LSA) Code. It says how strong a davit must be, how fast a boat may be lowered, and how a release hook must behave. SOLAS makes the LSA Code mandatory.

The third layer is the service standard: IMO resolution MSC.402(96). Since 1 January 2020 it has been mandatory too. It says who may do which job, what each examination must cover, and what paperwork must come out of it.

Around these sit IMO guidelines, the flag’s circulars, the class society’s survey practice and the manufacturer’s manuals. For how to do a task on your equipment, follow the manual; for what must be done, SOLAS sets the minimum.

The simple rule for “who may do what”:

Weekly and monthly checks, and routine maintenance from the manual: the ship’s crew, directed by a senior officer.
Annual thorough examination, five-yearly overhaul, overload tests and any repair: certified technicians of the manufacturer or of a service provider that the flag has authorised.
Authorising the service provider and checking that it was all done: the flag Administration and the class society acting for it.

In detail

SOLAS Chapter III: the regulations you will use most

Regulation	What it covers	Lesson
III/1.5	Replacement of non-compliant on-load release hooks (the “hook rule”)	6
III/3.25	Defines “the Requirements” as resolution MSC.402(96)	1
III/19	Drills and onboard training, including launching intervals	8
III/20	Operational readiness, maintenance, weekly, monthly, annual and five-yearly work	3 to 5
III/36	Instructions for onboard maintenance: checklists, schedules, lubrication diagrams, spares, logs	3

Regulation III/20.11 is the backbone of the servicing regime. As rewritten by resolution MSC.404(96) from 1 January 2020, it requires launching appliances to have a thorough examination at the annual survey followed by a dynamic winch brake test, release gear to have a thorough examination and operational test every year and an overhaul with a 1.1 load test at least every five years, and lifeboats and rescue boats themselves to have an annual thorough examination. Paragraph 11.5 then says all of this must follow MSC.402(96) and the regulation III/36 maintenance instructions.

The LSA Code: the design rules

Adopted by resolution MSC.48(66) and amended many times, the LSA Code chapters you will meet are IV (survival craft, including 4.4.7.6 on release mechanisms and 4.7 on free-fall lifeboats), V (rescue boats and fast rescue boats) and VI (launching appliances, including 6.1.2 on falls and winches).

MSC.402(96): the service standard

MSC.402(96) is short, and every inspector and technician should read it in full. Its structure:

Section 2 sets the scope: lifeboats including free-fall lifeboats, rescue boats and fast rescue boats, and the launching appliances and release gear for those boats and for davit-launched liferafts. It also defines “repair” (anything needing disassembly or beyond the onboard maintenance instructions) and “overhaul”.
Section 4 sets the three qualification levels shown in the exercise above.
Section 5 sets the records: every report and checklist signed by the person who did the work and countersigned by the master or company representative, kept on board for the service life of the equipment, and a statement that the arrangements “remain fit for purpose” issued after every thorough examination, test, overhaul or repair, with copies of the technician’s certificate and the provider’s authorisation attached.
Section 6 gives the actual procedures: the annual examination (6.2) and the five-year examination, overhaul and overload tests (6.3).
Section 7 says what a service provider must show to be authorised: certified staff, tools including the manufacturer’s special tools, access to parts, the manufacturer’s instructions for repairs, and a documented and certified quality system.
Section 8 sets technician training and certification: per make and type, with a certificate that expires three years after issue and is renewed only after a new competency assessment.

The guidelines and what replaced what

Instrument	Status on 2026-10-20
MSC.1/Circ.1206/Rev.1, Measures to prevent accidents with lifeboats (2009)	Main text still useful guidance. Annex 1 (servicing) was revoked by MSC.402(96); annex 2 (drills) was superseded by MSC.1/Circ.1578
MSC.1/Circ.1277, interim conditions for authorising service providers (2008)	Replaced by MSC.402(96) sections 7 and 8
MSC.1/Circ.1578, safety during abandon ship drills (2017)	Superseded by MSC.1/Circ.1578/Rev.1 of 6 July 2026
MSC.1/Circ.1392 and MSC.1/Circ.1584, evaluation and replacement of release hooks	Guidance for applying SOLAS III/1.5

What changed recently and what is coming

Change	Instrument	Applies
Ventilation system added to the annual thorough examination	MSC.559(108)	In force 1 January 2026, “where fitted”
Hook must not hold load unless completely reset; new minimum and maximum lowering speeds	MSC.554(108)	Equipment installed on or after 1 January 2026
Ventilation of at least 5 m³/h per person for 24 h in totally enclosed lifeboats	MSC.535(107)	Lifeboats installed on or after 1 January 2029
Arrangement to test free-fall release under load without launching, and matching MSC.402(96) changes	MSC.589(111) and MSC.402(96) amendments adopted at MSC 111 (May 2026)	Enter into force 1 January 2028, for free-fall lifeboats installed on or after 1 January 2031

What the rules say

SOLAS regulation III/3.25 defines “Requirements for maintenance, thorough examination, operational testing, overhaul and repair” as resolution MSC.402(96), as amended under the SOLAS amendment procedure, which makes it mandatory.¹
SOLAS regulation III/20.11.5 requires the thorough examination, operational testing, overhaul, maintenance and repair of lifeboats, rescue boats, launching appliances and release gear to follow MSC.402(96) and the regulation III/36 maintenance instructions; this took effect on 1 January 2020.¹
SOLAS regulation III/36 requires onboard maintenance instructions that include a checklist for the monthly inspections, maintenance and repair instructions, a schedule of periodic maintenance, a lubrication diagram, lists of replaceable parts and spare part sources, and a log of inspections and maintenance.²
MSC.402(96) paragraph 4.1 lets weekly and monthly inspections and routine maintenance be done by shipboard personnel “under the direction of a senior ship’s officer” following the maintenance manuals.³
MSC.402(96) paragraph 4.2 requires the annual thorough examination and operational tests to be done by certified personnel of the manufacturer or of an authorised service provider; the ship operator may act as the provider only if it is authorised itself.³
MSC.402(96) paragraph 4.3 reserves the five-year thorough examination, any overhaul, overload operational tests and repair for certified personnel of the manufacturer or an authorised service provider.³
MSC.402(96) paragraphs 5.1 to 5.3 require every report and checklist to be signed by the person who did the work and countersigned by the company’s representative or the master, kept on board for the equipment’s service life, and followed by a statement that the arrangements remain fit for purpose.³
MSC.402(96) paragraph 8.3.1 requires a technician’s certificate to state the makes, types and activities covered and to expire three years after issue.³
MSC.402(96) paragraph 7.2 requires each Administration to make information on its authorised service providers available, and paragraph 7.4.3 lets it accept providers authorised by other Administrations or their recognised organisations.³
Resolution MSC.559(108) adds “ventilation system, where fitted” to the items examined at the annual thorough examination, in force from 1 January 2026.⁴
Resolution MSC.535(107) requires totally enclosed lifeboats installed on or after 1 January 2029 to have ventilation of at least 5 m³/h per person for not less than 24 hours, operable from inside.⁵
MSC.1/Circ.1578 (2017) superseded annex 2 (the drill guidelines) of MSC.1/Circ.1206/Rev.1.¹³ MSC.1/Circ.1578/Rev.1 (6 July 2026) records that MSC.402(96) revoked annex 1 of MSC.1/Circ.1206/Rev.1, and it supersedes MSC.1/Circ.1578.⁶

Flag and class notes

Flags implement MSC.402(96) through their own authorisation schemes, and the details differ:

Panama (Merchant Marine Circular MMC-258, version 04 of May 2026) publishes its list of authorised service providers in the circular itself, issues each provider a certificate valid for three years, and requires renewal applications within three months before expiry. It also says MSC.1/Circ.1277 is no longer used.⁸
Liberia (Marine Notice SAF-005, revision 07/26) lets original equipment manufacturers work on their own makes without a separate Liberian authorisation, but requires every other provider to hold a Liberian authorisation document, and says authorisations given to third parties under the old MSC.1/Circ.1206/Rev.1 annex 1 are no longer accepted.⁹
Denmark (DMA RO Circular no. 28) accepts providers authorised by any SOLAS Administration or by an EU-recognised organisation, provided the authorisation states compliance with MSC.402(96), and reads “make” as the manufacturer and “type” as a category of equipment such as lifeboat, liferaft or davit.¹⁰

Class: when the class society surveys the ship for the Safety Equipment Certificate on behalf of the flag, it checks the records, not just the hardware. The IMO survey guidelines under the Harmonized System of Survey and Certification (HSSC, 2025 edition) tell the surveyor to check that the thorough examination, winch brake test and release gear servicing were done to MSC.402(96).⁷ Always confirm with your flag’s latest circular which providers it accepts before booking a service.

Key numbers

What	Value
MSC.402(96) mandatory from	1 January 2020¹
Validity of a technician’s certificate under MSC.402(96)	3 years from issue³
Panama authorisation certificate for a service provider	Valid 3 years⁸
Ventilation added to the annual examination	From 1 January 2026⁴
Ventilation rate for new totally enclosed lifeboats	At least 5 m³/h per person for 24 h, installed on or after 1 January 2029⁵
Lives lost in UK lifeboat accidents, 10 years to 2001	12, or 16% of all lives lost on UK merchant ships¹¹

What inspectors find

The wrong people did the annual work. A statement of fitness signed by a technician whose certificate does not cover that make and type, or has expired, or by a provider the flag has not authorised, does not meet MSC.402(96) section 4. Check the attached certificates.³
Missing or unsigned records. Checklists that are not countersigned by the master, or records that do not go back over the equipment’s life, are a common finding at both survey and ISM audit.³
Manuals not on board or out of date. MSC.402(96) paragraph 6.1.2 requires a full set of manufacturer’s manuals on board, kept up to date by the company.³
Lifeboats remain a top detention item. In 2025, Tokyo MOU port State control officers recorded 152 detainable lifeboat deficiencies, the third most frequent detainable item in the region.¹²

Questions people ask

Is MSC.402(96) a guideline or a requirement?

A requirement. It was adopted as a resolution, but SOLAS regulation III/3.25 and III/20.11.5 make it mandatory, and amendments to it follow the SOLAS amendment procedure. That is why its 2024 amendment, MSC.559(108), entered into force on a fixed date like a SOLAS amendment.

Can our own company do the annual examination?

Only if the company is itself an authorised service provider under MSC.402(96) sections 3 and 7, and the people doing the work hold certificates for that make and type under section 8. Otherwise the crew does the weekly and monthly work and an authorised provider does the annual work.

Does MSC.402(96) apply to liferafts?

Partly. It covers the launching appliances and automatic release hooks of davit-launched liferafts, not the liferafts themselves. Inflatable liferafts are serviced at approved servicing stations under SOLAS III/20.8.

Sources

1 IMO Resolution MSC.404(96), Amendments to SOLAS 1974 (adopted 19 May 2016, in force 1 January 2020), Annex: regulation III/3.25 and regulation III/20.11. https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MSCResolutions/MSC.404(96).pdf
2 IMO Resolution MSC.47(66), Amendments to SOLAS 1974 (adopted 4 June 1996, revised chapter III in force 1 July 1998), regulation III/36. https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MSCResolutions/MSC.47(66).pdf
3 IMO Resolution MSC.402(96), Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (adopted 19 May 2016, in force 1 January 2020), Annex, sections 2, 4, 5, 6.1, 7 and 8. https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MSCResolutions/MSC.402(96).pdf
4 IMO Resolution MSC.559(108), Amendments to the Requirements (resolution MSC.402(96)) (adopted 23 May 2024, in force 1 January 2026), Annex, paragraph 6.2.3.10. https://wwwcdn.imo.org/localresources/en/MediaCentre/Documents/Resolution%20MSC.559(108).pdf
5 IMO Resolution MSC.535(107), Amendments to the LSA Code (in force 1 January 2026, applied to totally enclosed lifeboats installed on or after 1 January 2029), operative paragraph 4 and LSA Code paragraphs 4.6.6 and 4.6.7. https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MSCResolutions/MSC.535(107).pdf
6 IMO MSC.1/Circ.1578/Rev.1, Revised guidelines on safety during abandon ship drills using lifeboats (6 July 2026), paragraphs 4, 5 and 7 (copy published by the Marshall Islands registry). https://wpsso.register-iri.com/wp-content/uploads/MSC.1-Circ.1578-Rev.1-1.pdf
7 IMO Resolution A.1207(34), Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2025 (adopted 3 December 2025), Annex, paragraph (EA) 1.2.2.24. https://wwwcdn.imo.org/localresources/en/OurWork/IIIS/Documents/A%2034-Res.1207%20-%20SURVEY%20GUIDELINES%20UNDER%20THE%20HARMONIZED%20SYSTEMOF%20SURVEY%20AND%20CERTIFICATION%20(HSSC),%202025%20(Secretariat).pdf
8 Panama Maritime Authority, Merchant Marine Circular MMC-258 V.04 (May 2026), Authorized service providers for lifeboats, rescue boats, launching appliances and release gear, paragraphs 1.7, 2.2, 5.5, 5.6 and 6. https://www.panamashipregistry.com/wp-content/uploads/2026/03/MMC-258-V04-MAY-2026.pdf
9 Liberia Maritime Authority, Marine Notice SAF-005 (Rev. 07/26), Survival craft, rescue boat and launching appliances: testing, servicing and maintenance, paragraphs 4.1 and 4.2. https://www.liscr.com/sites/default/files/online_library/SAF-005.pdf
10 Danish Maritime Authority, DMA RO Circular no. 28 (issued 19 January 2022, revision 02), Resolution MSC.402(96). https://www.dma.dk/Media/638587867299226754/DMA%20RO%20Circular%20no.%2028.pdf
11 UK Marine Accident Investigation Branch, Safety Study 1/2001, Review of lifeboat and launching systems’ accidents, introduction and section 1.4. https://assets.publishing.service.gov.uk/media/5a7d8042ed915d2d2ac0954a/Lifeboat_Study.pdf
12 Tokyo MOU, Annual Report on Port State Control in the Asia-Pacific Region 2025, figure 8 and table 15 (most frequent detainable deficiencies). https://www.tokyo-mou.org/wp/wp-content/uploads/ANN25.pdf
13 IMO MSC.1/Circ.1578, Guidelines on safety during abandon ship drills using lifeboats (19 June 2017), paragraph 6. https://wwwcdn.imo.org/localresources/en/OurWork/Safety/Documents/MSC.1-CIRC.1578.pdf

Free awareness training. Al Safwan Marine is not an approved training provider, so no certificate is given, and these courses are not a qualification. They don't replace STCW training, manufacturer training or the certification technicians need for this work. The manufacturer's manual and your flag's rules always come first.

This lesson is also published by our sister site vslsafety.com.

The rulebook: SOLAS III, the LSA Code and who may service what