619
1 INTRODUCTION
Passenger embarkation and debarkation at a fixed
berth normally take place between a vessel and a
comparatively stable shore structure. At anchorage,
however, passengers move between two floating
platforms that heave, roll and yaw independently. The
changing gap between a ship and a small boat creates
a short but safety-critical exposure in which a loss of
balance, a failure of the access arrangement, or a
delayed recovery response can rapidly produce serious
injury or fatality. Research on pilot and personnel
transfer has repeatedly identified relative motion,
unsuitable access, communication failure, human
factors and environmental conditions as dominant
contributors to accidents [3, 6, 17, 23, 28, 31, 32].
The problem is particularly important for
Indonesian pioneer shipping services. These services
provide essential mobility and logistics to
underdeveloped, frontier and outermost areas that are
not commercially attractive to regular operators.
Vessel design and service patterns are adapted to
remote routes, but port infrastructure and local feeder
arrangements remain uneven [4, 11, 16]. At Sofyanin,
Pioneer Service Vessel R-72 must remain at anchorage
Formal Safety Assessment of Passenger Embarkation
and Debarkation at Anchorage: A Case Study
of an Indonesian Pioneer Service Vessel
F. Muhammad
1
, D. Widarbowo
1
, M. Idris
1
, M. Kendek
2
, F. Filemon
1
, D. Haryanto
1
& S. Suganjar
1
1
Politeknik Pelayaran Sorong, Sorong, Southwest Papua, Indonesia
2
Politeknik Pelayaran Barombong, Makassar, South Sulawesi, Indonesia
ABSTRACT: Passenger transfer between an anchored pioneer service vessel and local connecting boats combines
relative motion, limited infrastructure and fragmented operational authority. This study develops risk-control
options and an International Safety Management Code-based operating procedure for such transfers. A
qualitative single-case design with an adapted semi-quantitative Formal Safety Assessment was applied to
Pioneer Service Vessel R-72 at Sofyanin anchorage, Indonesia. Evidence comprised case observations, Safety
Management System documents and role-based expert judgement from a master, a harbour master and a certified
ISM Code auditor. Fifteen hazards were identified, while five common scenarios were scored on a 5 × 5 likelihood-
severity matrix and summarised by median and range. The initial risks of falling overboard and boat capsizing
were Extreme, each with a median score of 20. Collision between boats, passenger crushing or impact, and loss
of boat position were High, each with a median score of 12. A layered control package reduced four scenarios to
Medium, but capsizing remained High with a residual median of 10 because catastrophic severity and uncertainty
in overload control persisted. Eight control groups were formulated and mapped to ISM Code clauses 5-12. The
resulting Layered Passenger Transfer Safety System integrates no-go criteria, boat acceptance, fit-for-purpose
access, transfer-zone control, personal flotation devices and rescue readiness, competence and vulnerable-
passenger arrangements, organisational learning, and formal local coordination. A written procedure alone
cannot establish tolerable risk unless capacity, equipment, emergency readiness and stop-work authority are
objectively verified. Controlled field trials remain necessary before operational adoption.
http://www.transnav.eu
the International Journal
on Marine Navigation
and Safety of Sea Transportation
Volume 20
Number 3
September 2026
DOI: 10.12716/1001.20.03.10
620
because no permanent berth is available. Passengers
are carried between shore and ship by locally operated
boats and then transferred through a ship-side access
arrangement. The service is socially necessary, but the
operational interface is exposed to overloading, limited
freeboard, inadequate personal flotation devices,
unstable boat positioning, unsuitable access and weak
supervision.
A previous study of the same service context
documented structural, policy, operational and
cultural gaps in safety-standard implementation [25].
That diagnostic work established the need for stronger
supervision, equipment and safety awareness, but it
did not complete an integrated Formal Safety
Assessment, compare initial and residual risks across
role-based experts, or translate the controls into an
auditable Safety Management System procedure. The
present study therefore addresses a distinct research
question and uses an additional expert-judgement
dataset to develop a risk-control architecture and an
ISM Code-mapped operating procedure.
Formal Safety Assessment (FSA) offers a structured
sequence for hazard identification, risk analysis, risk-
control options, cost-benefit or feasibility assessment,
and recommendations for decision-making [14, 30].
FSA is especially useful where accident statistics are
sparse, provided that the basis, uncertainty and
limitations of expert judgement are made explicit [5,
14]. The ISM Code complements this risk-based logic
by requiring documented responsibilities, resources,
shipboard procedures, emergency preparedness,
reporting, maintenance, document control, verification
and management review [2, 8, 9, 10, 13, 19, 33]. Under
SOLAS Chapter IX, safety is not demonstrated by the
existence of a procedure alone. It must be shown
through implementation and objective evidence [13,
18].
This study asks two questions. First, which Risk
Control Options can practically reduce passenger-
transfer risk at anchorage in a remote operating
environment? Second, how can these controls be
converted into an ISM Code-based procedure that
preserves the master’s overriding authority and
clarifies the roles of the vessel, boat operator, company,
local parties and harbour master? The article
contributes an adapted FSA application for public
passenger transfer, a transparent synthesis of three
institutional perspectives, and a Layered Passenger
Transfer Safety System designed for locations where
permanent infrastructure is not yet available.
2 THEORETICAL BASIS
2.1 Passenger transfer as a socio-technical operation
Personnel-transfer research has often focused on
maritime pilots, offshore personnel or ship-to-ship
operations. These studies show that accidents are
rarely explained by a single unsafe act. They emerge
from the interaction of vessel motion, access geometry,
equipment condition, communication, workload,
training, organisational pressure and emergency
capability [1, 6, 17, 21, 23, 28, 31, 32]. A system
perspective is therefore more appropriate than an
approach that attributes failure solely to passenger
behaviour or boat-operator error [34, 35].
2.2 Technical access and operational boundaries
Pilot-transfer arrangements provide useful technical
lessons on rigging, handholds, supervision,
communication and rescue readiness, but they cannot
be copied uncritically for general passengers. A pilot
ladder is intended for a trained and medically fit
professional and is not automatically suitable for all
members of the travelling public [3, 17, 23]. For this
study, vulnerability is treated functionally: a passenger
is considered vulnerable when the available transfer
arrangement cannot be used safely without additional
assistance or an alternative arrangement. This
definition is used for operational screening only
because the study did not collect subgroup-specific
exposure or accident data. The selected access
arrangement must therefore be fit for purpose,
properly secured, illuminated, inspected and
maintained. Operational limits must also be explicit.
Without no-go criteria, a decision can be distorted by
schedule pressure, social expectations or normalisation
of deviance.
2.3 FSA, risk matrices and layered control
The IMO FSA framework is a decision-support process
rather than a single risk-analysis technique [14]. In this
study, a 5 × 5 matrix was used as the semi-quantitative
technique within FSA Step 2. Risk matrices are suitable
for prioritisation when exposure data are limited, but
their categories are study-specific and must not be
presented as universal IMO thresholds [7, 30]. Controls
were developed as layered defences. Avoiding
exposure and engineering controls were prioritised
before administrative controls and personal protective
equipment. This ordering is important because a
checklist or lifejacket does not correct an overloaded
boat, a defective access point or an uncontrolled gap.
2.4 ISM Code integration
The ISM Code connects operational controls with
organisational accountability. The master must have
clear authority to make safety decisions, while the
company must provide resources and support.
Shipboard operations must be planned, emergency
scenarios must be tested, equipment must be
maintained, and non-conformities and near misses
must generate corrective and preventive action [2, 8-10,
13, 19, 24, 26, 33]. For the present case, the relevant
interface extends beyond the ship. Boat operators,
agents and local officials may support passenger
registration, queuing and communication, but they do
not replace the legal functions of the harbour master
under Indonesian shipping law and sailing-approval
procedures [15, 22].
3 MATERIALS AND METHODS
3.1 Study design and case boundary
The research used a qualitative descriptive single-case
design with a semi-quantitative risk component. The
case boundary covered the complete passenger-
transfer chain for Pioneer Service Vessel R-72 at
Sofyanin anchorage: passenger preparation ashore,
selection and loading of the connecting boat, transit,
621
approach, ship-side transfer, head count,
documentation and post-operation learning. This
broad boundary was selected because hazards can be
created before the passenger reaches the access point,
for example through an inaccurate manifest, poor
baggage distribution or the acceptance of an unfit boat.
3.2 Evidence sources and expert panel
Three evidence streams were triangulated. First, the
study used field conditions and risk observations
documented in the earlier diagnostic case study [25].
Second, applicable Safety Management System
materials, operating records and regulatory
requirements were reviewed. Third, semi-structured
role-based expert judgement was obtained from a
master, a harbour-master representative and a certified
ISM Code auditor. The interview guide followed
established principles for developing semi-structured
qualitative instruments and for interviewing maritime
experts [20, 29]. The panel was purposive rather than
statistically representative. Each expert represented a
function that controls a different part of the system:
real-time shipboard decision-making, statutory
oversight and SMS verification.
The master held an Indonesian Nautical Expert
Certificate Level I (ANT-I), had four years of
experience on 3T routes and two years of experience
with transfer at anchorage. The harbour-master expert
was a marine inspector with six years of relevant
maritime-safety supervision and vessel-inspection
experience. The ISM expert was a certified auditor with
experience evaluating objective evidence, non-
conformities and corrective action. All three experts
provided informed consent. Summaries, scores and
control interpretations were returned for member
checking and confirmed before synthesis. Personal
identifiers were coded NK-01, SY-01 and AU-01 in the
analytical dataset.
3.3 Adapted FSA procedure
The study followed five linked stages. Step 1 identified
hazards through process mapping, document analysis
and expert elicitation. Step 2 numerically scored only
H1-H5 because these were the five hazards for which
all three expert instruments contained comparable
initial and residual ratings. H6-H15 remained in the
hazard register and informed the SOP, but they were
not assigned consolidated scores because doing so
would have required imputing ratings that were not
present in the source data. Step 3 grouped the
proposed measures into Risk Control Options with an
assigned control owner and required evidence. Step 4
used a qualitative feasibility screen because reliable
monetary loss, exposure and accident-cost data were
not available. The screen considered safety benefit,
initial and recurring cost, personnel demand,
implementation time, dependency on external parties,
feasibility in Indonesia's 3T (underdeveloped, frontier
and outermost) setting and effect on service continuity.
Priority was assigned qualitatively rather than through
a weighted numerical index: measures that directly
addressed an Extreme or High hazard, could be
implemented with low or moderate burden, and did
not depend on major external infrastructure were
placed earlier in the implementation sequence.
Measures requiring technical design, capital approval
or major infrastructure were placed in the medium- or
long-term horizon. Step 5 converted the preferred
controls into an ISM Code-based SOP structure and
decision rules. Figure 1 summarises the design.
3.4 Risk scoring and synthesis
Likelihood and severity were each scored from 1 to 5.
Severity ranged from negligible to catastrophic.
Likelihood ranged from very rare to very frequent and
was interpreted with reference to exposure, relevant
near misses and expert experience. The risk score was
calculated as:
R L S=
(1)
where R is the risk score, L is likelihood and S is
severity. The 5 × 5 matrix is not the FSA framework
itself; it is the study-specific semi-quantitative scoring
tool used within FSA Step 2. Study-specific categories
were Low (1-4), Medium (5-9), High (10-16) and
Extreme (17-25). High and Extreme scores required
additional control or suspension before the operation
could continue. These category boundaries are
decision aids for the R-72 case and should be
recalibrated if the method is applied to another vessel,
location, season or operating profile. Because the scores
were ordinal and the panel contained three
purposively selected experts, the synthesis used the
median as the central value and the minimum-
maximum range to retain disagreement. No inferential
statistics were applied.
3.5 Qualitative coding and trustworthiness
Interview and document material was coded against
FSA stages, direct causes, human factors,
organisational factors and ISM Code clauses. The
analysis deliberately retained dissent. For example, a
lower residual score from one expert was not treated as
consensus when the other two experts considered
control performance uncertain. Trustworthiness was
strengthened through source triangulation, role
triangulation, an audit trail of scoring decisions and
member checking. The principal limitation is that the
RCO package and SOP had not yet undergone a
controlled field trial at the time of analysis.
Table 1. Expert panel and analytical roles
Role
Qualification and
experience
Analytical contribution
Master
ANT-I; 4 years on 3T
routes; 2 years of
anchorage transfer
Real-time go/no-go
decision, boat and vessel
condition, duties and
emergency response
Harbour
master /
marine
inspector
6 years in maritime-
safety supervision
and vessel inspection
Statutory oversight,
capacity verification, local
coordination and limits of
delegated tasks
Certified ISM
Code auditor
Relevant audit and
SMS-verification
experience
Objective evidence, ISM
clause mapping, non-
conformity, CAPA and
management review
622
Figure 1. Research design and adapted FSA workflow
4 RESULTS
4.1 Existing operation and hazard identification
The operational process comprises five stages:
preparation ashore, boat transit, approach, passenger
transfer and completion. The most critical interface
occurs when the connecting boat is alongside the ship
because the two platforms move differently and the
available gap changes rapidly. Nevertheless, the
analysis showed that the risk chain starts earlier, when
the boat is selected, capacity is interpreted, baggage is
distributed and vulnerable passengers are identified. It
also continues after transfer if near misses and
equipment defects are not reported.
The first five hazards were common to all three
scoring instruments and were therefore used for cross-
expert comparison. This decision followed the
comparability rule defined in Section 3.3: a
consolidated numerical result was reported only when
all three experts had assessed the same hazard using
comparable rating fields. Hazards H6-H15 were
retained in the register and in the SOP design, but they
were not assigned a consolidated numerical score
because comparable ratings from all three experts were
not available. This distinction avoids presenting
incomplete scoring as consensus.
Table 2. Hazard register for passenger transfer at anchorage
ID
Hazard
scenario
Main causes
Credible
consequences
H1
Passenger falls
overboard
Relative motion; slippery
footing; unsuitable access;
hands occupied; unclear
command
Serious injury,
drowning or death
H2
Boat capsizes or
loses stability
Overloading; poor load
distribution; low
freeboard; weather; boat
condition
Multiple casualties,
boat loss and
suspension of
service
H3
Collision
between boats
No queue; simultaneous
approach; communication
failure
Injury, damage and
person overboard
H4
Passenger is
crushed or
struck
Changing gap; inadequate
fenders; poor timing;
unstable boat
Limb injury or fall
overboard
H5
Boat loses
position
Engine, steering or line
failure; operator error;
current and waves
Impact, fall or
separation from
access
H6
Access
arrangement
fails
Incorrect rigging; weak
securing point; corrosion;
inadequate inspection
Fall or multiple
serious injuries
H7
PFD absent,
unsuitable or
not worn
Insufficient number;
wrong size; damage; non-
compliance
Drowning after fall
or capsizing
H8
Baggage and
passenger move
together
Occupied hands;
restricted space;
distraction
Loss of balance,
crushing or falling
objects
H9
Vulnerable
passenger
cannot use
access
Physical limitation;
unsuitable PFD;
improvised assistance
Fall, severe injury or
delayed evacuation
H10
Lighting or
visibility is
inadequate
Night operation; glare;
shadow; failed lighting
Misstep and failed
visual
communication
H11
Communication
fails or
crowding
develops
No radio; language
difference; non-standard
command
Unsynchronised
movement, panic or
collision
H12
Anchor drags
or ship
movement
changes
Holding-ground failure;
wind/current change; poor
monitoring
Unsafe transfer
point or boat
displacement
H13
Fatigue or
insufficient
personnel
Long operation; work-rest
issue; conflicting watch
duties
Human error and
delayed response
H14
MOB or
recovery
response is
delayed
No lookout; lifebuoy not
ready; inadequate
recovery method
Escalation from
survivable event to
fatality
H15
Manifest or
reporting is
inaccurate
Weak head count; hidden
near miss; poor document
control
Delayed missing-
person detection
and repeated hazard
4.2 Initial risk
Table 3 shows that none of the five jointly scored
hazards was initially rated Low or Medium. Falling
overboard and capsizing were Extreme, while the
remaining scenarios were High. The ranges are
analytically important because they show different
assumptions about exposure and credible consequence
rather than measurement error.
Table 3. Initial risk scores from the three expert perspectives
ID
Hazard
SY-
01
NK-
01
AU-
01
Median
(range)
Category
H1
Falling overboard
16
20
20
20 (16-20)
Extreme
H2
Boat capsizing
25
15
20
20 (15-25)
Extreme
H3
Collision between
boats
12
12
16
12 (12-16)
High
H4
Crushing or impact
9
12
16
12 (9-16)
High
H5
Loss of boat position
12
12
15
12 (12-15)
High























623
Falling overboard received a median of 20 because
a short exposure can escalate to drowning or impact
with the hull when recovery is delayed. Capsizing also
received a median of 20 and the widest range, 15-25.
The difference reflected the master’s emphasis on
experienced boat handling and the harbour-master
expert’s concern that overloading, low freeboard and
undocumented capacity can create a catastrophic event
affecting several people at once.
4.3 Residual risk after the RCO package
Residual scores were conditional on the entire control
package being implemented and verified. They are not
predictions of safety under partial compliance. Four
scenarios fell to Medium. Capsizing remained High
because severity remained catastrophic and the
reliability of overload controls had not been
demonstrated through an operational trial.
Table 4. Residual risk scores after the proposed layered
controls
ID
Hazard
SY-
01
NK-
01
AU-
01
Median
(range)
Category
H1
Falling overboard
6
8
8
8 (6-8)
Medium
H2
Boat capsizing
10
10
5
10 (5-10)
High
H3
Collision between
boats
4
6
6
6 (4-6)
Medium
H4
Crushing or impact
2
6
6
6 (2-6)
Medium
H5
Loss of boat position
4
8
5
5 (4-8)
Medium
For H1, a residual median of 8 required fit-for-
purpose access, one passenger at a time, hands free,
correctly fitted PFDs, a dedicated lookout and a
workable recovery arrangement. For H3 and H4, most
risk reduction came from lower likelihood through
one-boat-at-a-time control, a holding area, fendering
and a single command chain. For H5, the score
depended on verified engine and steering readiness, a
competent operator, suitable securing and an abort
procedure. Documentation supported learning and
audit, but it did not substitute for physical reliability.
4.4 Risk Control Options
The eight RCO groups in Table 5 form a multi-layer
defence. Each control has a designated owner and a
form of objective evidence. A control was not treated
as implemented merely because it appeared in a draft
procedure.
Table 5. Risk Control Options, ownership and objective
evidence
ID
RCO group
Core controls
Control
owner
Objective
evidence
RCO-
1
Operating
limits and
stop-work
No-go weather and
motion limits; anchor
movement; crowding;
access defect;
communication loss
Master /
transfer
PIC
Go/no-go
checklist
and decision
log
RCO-
2
Boat capacity
and fitness
Documented
capacity; freeboard;
hull; engine; steering;
fenders; lines; PFDs;
competent operator
Boat
operator,
agent and
vessel
Boat-
acceptance
checklist
and
manifest
RCO-
3
Fit-for-purpose
access
Suitable arrangement;
securing; handholds;
lighting; fendering;
inspection and
maintenance
Company
and
master
Design
basis,
inspection
and
maintenance
record
RCO-
4
Transfer zone
and
communication
Holding area; one
boat at a time; call-in;
clear-to-approach;
read-back; exclusion
zone
Vessel PIC
and boat
operator
Communi-
cation and
queue
record
RCO-
5
PFDs and
rescue
readiness
Correct sizes;
lookout; lifebuoy and
line; recovery
method; first aid;
drills
Master
and
emergency
team
Equipment
check and
drill record
RCO-
6
Competence
and vulnerable
passengers
Role-based staffing;
operator competence;
understandable
briefing; screening;
safe alternative or
delay
Company,
master
and shore
party
Training
record,
RACI and
passenger
assessment
RCO-
7
Reporting,
audit and
learning
Near miss; defect;
NCR; CAPA; internal
audit; management
review
DPA and
company
Deck log,
NCR/CAPA
and audit
trail
RCO-
8
Formal local
coordination
Written support for
registration, queuing,
education and
communication
without transferring
statutory authority
Harbour
master
and
authorised
local
parties
Local rule,
assignment
letter and
inspection
report
4.5 Operational feasibility and implementation sequence
A monetised GCAF or NCAF calculation was not
possible because exposure, accident-frequency and
consequence-cost data were incomplete. The
qualitative screen therefore focused on relative safety
benefit and implementation burden. The priority labels
in Table 6 were assigned by comparing each option
against the criteria specified in Section 3.3, without
converting those criteria into a composite numerical
score. An intervention was placed in an earlier horizon
when it directly reduced an Extreme or High risk,
could be implemented with low or moderate resource
burden, and was feasible without major third-party or
infrastructure dependency. Options requiring
technical design, capital approval, specialised assets or
shore infrastructure were placed later. This sequence
prevents a common failure in remote operations:
postponing low-cost high-value controls while waiting
for permanent infrastructure. It also prevents the
opposite failure, in which administrative measures are
used indefinitely to avoid necessary engineering
investment.
624
Table 6. Phased feasibility and implementation priorities
Horizon
Intervention
Safety
benefit
Cost burden
3T
feasibility
Implementa
tion decision
Immediate
No-go and stop-
work; core boat
checks; one-boat
transfer zone;
briefing; manifest;
reporting
Very
high
Low
High
Before the
next
operation
Short term
PFDs in multiple
sizes;
radio/megaphone;
fenders; lighting;
lifebuoy; first aid;
drills
High
Medium
High
Within one
operating
cycle
Medium
term
Purpose-built
access; dedicated
tender; platform
improvement;
digital reporting
Very
high
Medium
-high
Medium
Following
technical
design and
budget
approval
Long term
Pontoon, landing
facility or
permanent berth
Very
high
High
Location-
dependent
Infrastructure
investment
programme
4.6 ISM Code-based SOP architecture
The SOP was designed as a controlled SMS document
rather than an isolated checklist. It covers pre-transfer
assessment, boat acceptance, go/no-go, approach,
passenger movement, functional screening of
passengers who may require assistance or an
alternative arrangement, baggage, emergency
response, completion, reporting and review. The
company and Designated Person Ashore provide
resources and verification, while the master retains the
final decision to begin, postpone or stop the operation.
Figure 3 summarises the implementation sequence and
shows that a failed acceptance criterion returns the
operation to a stop-and-reassess state rather than
allowing the transfer to continue.
Table 7. Mapping of the proposed controls to ISM Code
clauses 5-12
Clause
Management
focus
Application to the transfer
SOP
Required
objective
evidence
5
Master’s
responsibility
and authority
Overriding authority;
go/no-go and protected
stop-work
Decision record
and standing
orders
6
Resources and
personnel
Role-based staffing,
competence, briefing and
fatigue control
Manning plan,
training and rest
records
7
Shipboard
operations
Ship-specific, location-
aware transfer SOP
Controlled SOP,
checklist and
RACI
8
Emergency
preparedness
MOB, capsizing, injury,
engine/steering failure and
communication-loss
response
Drill records,
response time
and equipment
checks
9
Reports and
analysis
Near-miss, defect, root-
cause analysis and CAPA
NCR, CAPA and
trend report
10
Maintenance
Access, fenders, lighting,
radio, PFDs and recovery
equipment
Planned-
maintenance and
defect records
11
Documentation
Version control, manifest,
communication log and
record retention
Revision register
and controlled
forms
12
Company
verification
and review
Field trial, internal audit
and management review
Audit report,
minutes and
action closure
Figure 3. Implementation flow for passenger-transfer control
4.7 Layered Passenger Transfer Safety System
The synthesis produced the five-layer model in Figure
2. The first layer prevents exposure when operating
limits are not met. The second ensures technical
integrity. The third controls traffic, communication and
passenger flow. The fourth limits consequences and
supports recovery. The fifth creates accountability and
organisational learning. The model is intentionally
redundant: failure of one layer should not immediately
produce a casualty because the remaining layers
continue to function.
Figure 2. Layered Passenger Transfer Safety System derived
from the FSA and expert synthesis





















625
5 DISCUSSION
5.1 From individual caution to system control
The findings do not support the view that passenger-
transfer accidents are primarily the result of
carelessness. The same passenger action can be safe or
unsafe depending on relative motion, access geometry,
fendering, instructions, staffing and recovery
readiness. This aligns with systemic maritime-safety
research, which treats safety as an emergent property
of interacting technical and organisational controls [34,
35]. The practical implication is that briefing
passengers to “be careful” cannot compensate for an
overloaded boat or an access arrangement that is
unsuitable for the user population.
5.2 Why capsizing remains the controlling scenario
Capsizing remained High after controls because its
credible consequence is multiple fatalities and because
the reliability of overload prevention was not yet
demonstrated. The auditor’s lower residual score
assumed complete verification of capacity, manifest,
loading and boat fitness. The master and harbour-
master experts were more conservative because locally
operated boats may lack documented capacity,
baggage can be added informally and an alternative
boat may not be immediately available. The
conservative median is therefore appropriate until a
field trial demonstrates consistent compliance. This is
also an example of why residual risk should be
conditional on safeguards rather than reported as an
unconditional property of a written procedure.
5.3 The relationship between FSA and the ISM Code
FSA identifies what must be controlled and why, while
the ISM Code determines how the organisation must
make the control repeatable and auditable. The RCOs
become operationally meaningful only when they are
assigned to an owner, supported by resources and
linked to objective evidence. This finding is consistent
with accident and implementation studies showing
that the major weakness of an SMS is often the gap
between documented procedures and work as actually
performed [2, 8-10, 24, 33]. The proposed SOP therefore
includes go/no-go records, boat-acceptance checks,
communication logs, inspection records, drills, near-
miss reporting and CAPA rather than a sequence of
passenger instructions alone.
5.4 Contextual safety for remote services
Remote service continuity and safety should not be
framed as competing absolutes. The absence of a
permanent berth does not justify uncontrolled transfer,
but an immediate infrastructure solution may also be
financially and logistically unrealistic. The phased
control strategy offers a defensible bridge. Low-cost
controls with high safety benefit, including stop-work
criteria, capacity verification, queuing, communication
and reporting, can be applied immediately. Equipment
upgrades can follow in the short term, while purpose-
built access, a dedicated tender, pontoon or berth
require technical design and investment planning. The
ALARP logic remains relevant, but administrative
feasibility cannot be used to avoid an engineering
measure when the remaining risk is intolerable.
5.5 Contribution and limitations
The main conceptual contribution is the Layered
Passenger Transfer Safety System shown in Figure 2. It
combines five mutually supporting layers: operating
limits, technical integrity, controlled transfer-zone
operations, emergency resilience, and governance with
organisational learning. The model is transferable as an
analytical structure, but its numerical scores are not
automatically transferable to another vessel, route or
season. Likewise, the Low-Medium-High-Extreme
bands used in this case should not be treated as
universal IMO acceptance thresholds. A new
application should reassess the local hazards, exposure
pattern, operating limits and consequence assumptions
before adopting numerical categories. The study is
limited by a single case, three role-based experts,
incomplete historical exposure data and the absence of
a field trial. The additional hazards H6-H15 were
identified but not scored by all three experts, so they
should be included in the next validation cycle. A
controlled before-after field trial should record at least
checklist completion, boat-capacity or loading
violations, near misses, stop-work decisions,
equipment defects and closure time, and man-
overboard recovery time. These indicators would
allow the proposed controls to be evaluated against
observed operational performance rather than
procedural compliance alone.
6 CONCLUSIONS
1. Passenger transfer at anchorage is a high-risk socio-
technical operation, not a simple passenger-
movement task. In the R-72 case, falling overboard
and capsizing had Extreme initial median scores of
20, while collision, crushing or impact, and loss of
position had High initial median scores of 12.
2. A layered RCO package reduced four scenarios to
Medium. Boat capsizing remained High with a
residual median of 10, showing that the operation
cannot be declared controlled until documented
capacity, loading discipline, boat fitness and
alternative arrangements are demonstrated in
practice.
3. Eight RCO groups were formulated: operating
limits and stop-work, boat capacity and fitness, fit-
for-purpose access, transfer-zone control and
communication, PFDs and rescue readiness,
competence and vulnerable-passenger
arrangements, reporting and audit, and formal local
coordination. These controls were mapped to ISM
Code clauses 5-12 and converted into a controlled
SOP structure.
4. The master retains final go/no-go authority and
must be protected from schedule or commercial
pressure. The harbour master retains statutory
oversight, while local parties may support
registration, queuing and communication only
through clearly defined arrangements.
5. Before adoption as operational policy or local rules,
the SOP should undergo a tabletop exercise, a
controlled field trial, audit and revision. The field
626
trial should use observable performance indicators
such as checklist completion, capacity or loading
violations, near misses, stop-work decisions, defect
closure and man-overboard recovery time. Future
research should replicate the method across vessels,
seasons and anchorage environments and should
develop quantitative cost-benefit estimates when
reliable exposure and consequence data become
available.
APPENDIX A. MANDATORY STOP-WORK
CRITERIA
The following conditions require immediate
suspension or non-commencement of passenger
transfer. Restart is permitted only after the condition
has been corrected, the risk has been reassessed and the
master has authorised continuation.
1. Weather, waves, current or visibility exceed
validated vessel- and location-specific operating
limits.
2. Boat capacity, freeboard, stability or condition
cannot be verified, or overloading is observed.
3. PFDs are insufficient, incorrectly sized, defective or
not worn correctly.
4. The access arrangement, securing point, fenders,
lighting, communication or recovery equipment
fails the checklist.
5. The anchor drags, ship movement changes
unexpectedly, traffic becomes unsafe or the boat
cannot maintain position.
6. A vulnerable passenger cannot be transferred safely
using the available arrangement.
7. More than one boat enters the transfer point,
crowding develops or an operator does not follow
the PIC’s instruction.
8. Passenger transfer conflicts with cargo or baggage
handling at the same access point.
9. Personnel are insufficient, fatigued, unclear about
their roles or required watchkeeping would be
compromised.
10. A serious near miss, injury, equipment failure or
loss of communication occurs. The operation
remains stopped until reassessment is completed.
REFERENCES
[1] Arici, S.S., Akyuz, E., Arslan, O. (2020). Application of
fuzzy bow-tie risk analysis to maritime transportation:
The case of ship collision during the STS operation. Ocean
Engineering, 217, 107960.
https://doi.org/10.1016/j.oceaneng.2020.107960
[2] Batalden, B.-M., Sydnes, A.K. (2014). Maritime safety and
the ISM Code: A study of investigated casualties and
incidents. WMU Journal of Maritime Affairs, 13(1), 3-25.
https://doi.org/10.1007/s13437-013-0051-8
[3] Behforouzi, M. (2021). Implementation of smart pilotage
to safeguard pilots from pilot ladder accidents. Pomorski
Zbornik, 60(1), 65-84. https://doi.org/10.18048/2021.60.04
[4] Berlianto, W.R., Augustriandi, A., Suparno, S., Mukhtar,
S. (2025). Integrasi pelayaran perintis (pioneer shipping)
dan Tol Laut untuk mengoptimalkan return cargo di
Indonesia. OPTIMAL Jurnal Ekonomi dan Manajemen,
5(2), 634-647. https://doi.org/10.55606/optimal.v5i2.6465
[5] Browne, T., Veitch, B., Taylor, R., Smith, J., Smith, D.,
Khan, F. (2021). A knowledge elicitation study to inform
the development of a consequence model for Arctic ship
evacuations: Qualitative and quantitative data. Data in
Brief, 39, 107612. https://doi.org/10.1016/j.dib.2021.107612
[6] Camliyurt, G., Park, Y., Kim, D., Kang, W.S., Park, S.
(2023). Machine learning with multi-source data to
predict and explain marine pilot occupational accidents.
Journal of Marine Science and Technology, 31(4).
https://doi.org/10.51400/2709-6998.2709
[7] Chaal, M., Bahootoroody, A., Basnet, S., Valdez Banda,
O.A., Goerlandt, F. (2022). Towards system-theoretic risk
assessment for future ships: A framework for selecting
Risk Control Options. Ocean Engineering, 259, 111797.
https://doi.org/10.1016/j.oceaneng.2022.111797
[8] Demirci, S.M.E., Cicek, K. (2023). Innovative strategy
development approach for enhancing the effective
implementation of the International Safety Management
(ISM) Code. Transportation Research Record, 2677(1), 25-
48. https://doi.org/10.1177/03611981221098394
[9] Ghosh, S., Abeysiriwardhane, A. (2021). The influence of
information technology on the implementation of the
International Safety Management (ISM) Code: A shift
from paper-based to paperless ships. Maritime
Technology and Research, 3(3), 299-311.
https://doi.org/10.33175/mtr.2021.249024
[10] Ghosh, S., Daszuta, W. (2019). Failure of risk assessment
on ships: Factors affecting seafarer practices. Australian
Journal of Maritime & Ocean Affairs, 11(3), 185-198.
https://doi.org/10.1080/18366503.2019.1658277
[11] Hadi, E.S., Manik, P., Iqbal, M. (2018). Influence of hull
entrance angle “Perintis 750 DWT” toward ship
resistance. MATEC Web of Conferences, 159, 01057.
https://doi.org/10.1051/matecconf/201815901057
[12] Hamilton, A.B., Finley, E.P. (2020). Qualitative methods
in implementation research: An introduction. Psychiatry
Research, 283, 112629.
https://doi.org/10.1016/j.psychres.2019.112629
[13] International Maritime Organization (2017). Revised
guidelines on the implementation of the International
Safety Management (ISM) Code by Administrations,
Resolution A.1118(30). London: IMO.
https://wwwcdn.imo.org/localresources/en/KnowledgeC
entre/IndexofIMOResolutions/AssemblyDocuments/A.1
118(30).pdf
[14] International Maritime Organization (2018). Revised
guidelines for Formal Safety Assessment (FSA) for use in
the IMO rule-making process, MSC-
MEPC.2/Circ.12/Rev.2. London: IMO.
https://wwwcdn.imo.org/localresources/en/OurWork/Sa
fety/Documents/MSC-MEPC%202-Circ%2012-
Rev%202.pdf
[15] Indonesia (2008, as amended in 2024). Law of the
Republic of Indonesia No. 17 of 2008 on Shipping.
https://peraturan.bpk.go.id/Details/39060
[16] Indonesia (2021). Presidential Regulation No. 27 of 2021
on Public Service Obligations for the Transport of Goods
to and from Underdeveloped, Remote, Outermost and
Border Areas.
https://peraturan.bpk.go.id/Details/165696/perpres-no-
27-tahun-2021
[17] Jiang, Z., Xiao, Z., Feng, Y., Cao, Y. (2024). Analysis of
risk influential factors of marine pilots during
embarkation and debarkation. Journal of Marine
Engineering & Technology, 24(1), 1-14.
https://doi.org/10.1080/20464177.2024.2397847
[18] Joseph, A., Dalaklis, D. (2021). The International
Convention for the Safety of Life at Sea: Highlighting
interrelations of measures towards effective risk
mitigation. Journal of International Maritime Safety,
Environmental Affairs, and Shipping, 5(1), 1-11.
https://doi.org/10.1080/25725084.2021.1880766
[19] Junaidi, A., Yudo, H., Ab-Samat, H.A. (2024). Identifying
trends in maritime safety management system studies: A
review. TransNav, the International Journal on Marine
Navigation and Safety of Sea Transportation, 18(4), 775-
784. https://doi.org/10.12716/1001.18.04.03
627
[20] Kallio, H., Pietilä, A., Johnson, M., Kangasniemi, M.
(2016). Systematic methodological review: Developing a
framework for a qualitative semi-structured interview
guide. Journal of Advanced Nursing, 72(12), 2954-2965.
https://doi.org/10.1111/jan.13031
[21] Kaptan, M. (2021). Risk assessment of ship anchorage
handling operations using the fuzzy bow-tie method.
Ocean Engineering, 236, 109500.
https://doi.org/10.1016/j.oceaneng.2021.109500
[22] Kementerian Perhubungan Republik Indonesia (2022).
Regulation of the Minister of Transportation No. PM 28
of 2022 on the issuance of sailing approvals and approvals
for ship activities in ports. https://jdih.kemenhub.go.id/
[23] Lee, J.-W., Kim, E.-W., Lee, C.-H. (2017). A basic study on
accident-prevention measures for maritime pilots during
embarkation and debarkation. Journal of Fisheries and
Marine Sciences Education, 29(1), 137-147.
https://doi.org/10.13000/JFMSE.2017.29.1.137
[24] Mbong, T.S.-S., Bygvraa, D.A. (2021). Analysis of the
implementation of the International Safety Management
Code using motivation theory: The seafarer’s views.
International Maritime Health, 72(3), 172-178.
https://doi.org/10.5603/IMH.2021.0033
[25] Muhammad, F., Idris, M., Satria, I.D., Filemon, F.,
Siregar, M.S., Rakka, S.G.A. (2025). Evaluation of the
implementation of safety standards in the debarkation
and embarkation process of Sea Toll Vessel R-72 at
anchorage. Dinasti International Journal of Education
Management and Social Science, 7(1), 1179-1188.
https://doi.org/10.38035/dijemss.v7i1.5606
[26] Ndori, A., Sutajaya, F., Widiatmaja, A. (2023).
Implementation of the International Safety Management
Code for the safety of crew and passengers on KM
Sinabung. RSF Conference Series: Engineering and
Technology, 3(1), 88-96.
https://doi.org/10.31098/cset.v3i1.738
[27] Radwanski, K., Rutkowski, G. (2022). An analysis of the
risks during personnel transfers between units operating
on the water. Water, 14(20), 3303.
https://doi.org/10.3390/w14203303
[28] Sakar, C., Sokukcu, M. (2023). Dynamic analysis of pilot
transfer accidents. Ocean Engineering, 287, 115823.
https://doi.org/10.1016/j.oceaneng.2023.115823
[29] Sharma, D.R. (2023). Expert as interviewer:
Methodological challenges in the use of qualitative
interviews in maritime research. TransNav, the
International Journal on Marine Navigation and Safety of
Sea Transportation, 17(3), 637-642.
https://doi.org/10.12716/1001.17.03.15
[30] Trbojevic, V.M., Carr, B.J. (2000). Risk-based
methodology for safety improvements in ports. Journal of
Hazardous Materials, 71(1-3), 467-480.
https://doi.org/10.1016/S0304-3894(99)00094-1
[31] Tunçel, A.L., Akyuz, E., Arslan, O. (2023). Quantitative
risk analysis for operational transfer processes of
maritime pilots. Maritime Policy & Management, 50(3),
375-389. https://doi.org/10.1080/03088839.2021.2009133
[32] Turna, İ. (2024). A safety risk assessment for ship
boarding parties from a fuzzy Bayesian networks
perspective. Maritime Policy & Management, 51(1), 1-14.
https://doi.org/10.1080/03088839.2022.2112780
[33] Uflaz, E., Akyuz, E., Arslan, O., Çelik, E. (2022). A
quantitative effectiveness analysis to improve Safety
Management System implementation on board ship.
Safety Science, 156, 105913.
https://doi.org/10.1016/j.ssci.2022.105913
[34] Valdez Banda, O.A., Goerlandt, F. (2018). A STAMP-
based approach for designing maritime safety
management systems. Safety Science, 109, 109-129.
https://doi.org/10.1016/j.ssci.2018.05.003
[35] Xu, M., Ma, X., Zhao, Y., Qiao, W. (2023). A systematic
literature review of maritime transportation safety
management. Journal of Marine Science and Engineering,
11(12), 2311. https://doi.org/10.3390/jmse11122311