Cargo gear is inspected on three separate cadences, by three different categories of person, with three different record obligations — and the one that actually prevents accidents is the one with almost no record behind it. Under ILO Convention No. 152, lifting appliances forming part of a ship's equipment must be re-tested at least every five years, all lifting appliances and loose gear must be thoroughly examined and certified by a competent person at least once every twelve months, and loose equipment must be inspected before use by a responsible person, as frequently as is reasonably practicable for pre-slung cargoes. The five-year test produces a certificate. The annual examination produces a certificate. The before-use inspection, which happens hundreds of times more often and is the check most likely to catch a sling about to fail, is explicitly permitted to go unrecorded in the register. That is a defensible regulatory design and a poor management position, and it became a more pressing one on 1 January 2026 when SOLAS Regulation II-1/3-13 entered force with guidelines in MSC.1/Circ.1663, requiring every item of loose gear to carry a unique permanent identification so that item and certificate are traceable to one another. Start a free trial of Marine Inspection and put the third cadence on the record.
Every 5 years
Re-test of lifting appliances forming part of the ship's equipment
Conducted by a competent person — someone with the knowledge and experience necessary for thorough examinations and tests, and acceptable to the competent authority. Produces a certificate stating safe working load, inspector identity, test date and results.
Recorded
Every 12 months
Thorough examination and certification of all appliances and loose gear
Also by a competent person, covering everything not caught by the five-yearly cycle. Every item of loose gear must additionally be tested and thoroughly examined before first use, and again after any substantial alteration or repair to a part liable to affect its safety.
Recorded
Before every use
Visual inspection of loose gear by a responsible person
A responsible person is appointed by the master or the equipment owner, and the inspection decides whether the sling or item of loose gear is whole, undamaged and safe for continued use. Hundreds of times more frequent than either cadence above, and the check most likely to catch the item that was about to fail.
Largely unrecorded
The convention is explicit that all loose gear should be inspected before use while entries need only be made in defined circumstances. That is sensible regulation — nobody wants a register entry for every shackle picked up in a shift. It also means the highest-frequency safety check in cargo operations generates no data, which leaves a port captain managing the one thing they can see least.
What Changed on 1 January 2026
The new SOLAS requirements did not replace the ILO regime — they sit alongside it and tighten the identification and evidence side considerably. Book a Marine Inspection demo and see gear held at item level rather than as a category.
Why it happened
The decision was driven by increasing accidents involving lifting appliances and winches. The work began with an analysis of maritime accident data and a review of existing regulation, including ILO Convention No. 152, to identify root causes and regulatory gaps — so the amendment is a direct response to where the previous framework was not working.
What it covers
Application, design, construction, operation, inspection, testing and maintenance. The stated aim is preventing accidents causing harm to personnel, damage to ships, cargo, subsea and shore-based structures, and harm to the marine environment — a scope notably wider than crew safety alone.
The register
A Register of Ship's Lifting Appliances and Cargo Handling Gear must be maintained on board. The Certificate of Test and Thorough Examination must be in the format provided in Appendix 1 of the guidelines, which standardises what every certificate has to contain.
The marking requirement
All loose gear must be clearly and permanently marked with its unique identification, its safe working load, and any additional marks required for safe use. Each item carries a serial number or tag specifically to ensure traceability between the item and its certification. A bucket of shackles is no longer a workable data model.
All applicable lifting appliances certified in accordance with an acceptable standard
All lifting appliances properly marked with safe working load and other information essential to safe operation, such as maximum or minimum slewing radius or boom angle
All loose gear clearly and permanently marked with its unique identification, safe working load and any additional marks required for safe use
All lifting appliances and associated loose gear load tested and thoroughly examined by a competent person
All lifting appliances provided with an operation and maintenance manual
The verification happens at the first Cargo Ship Safety Construction Renewal Survey, on a five-year cycle, or the first Passenger Ship Safety Survey, annually, conducted after 1 January 2026. Which means there is no single fleet deadline — every vessel has its own, and some of them are close.
Item
Unique ID
SWL
Certificate and date
Every shackle, sling and chain as its own record
Unique identification, safe working load, certificate reference, test and examination dates, discard criteria and inspection history — held per item rather than per category, so traceability between the gear and its certificate exists as data rather than as an assumption. Plus the before-use inspection captured in seconds by the responsible person doing it, which the register never asked for and your operation needs.
Two Routes for Gear That Predates the Regulation
Most cargo gear in service was installed before 2026, and the treatment depends entirely on what paperwork already exists for it. This is the most immediately actionable section on the page. Sign up for Marine Inspection and establish which route each appliance is on before a surveyor does.
Route one: valid certificates exist
Existing lifting appliances installed before 1 January 2026 are regarded as compliant where valid certificates of test and thorough examination were issued beforehand under another international instrument acceptable to the Administration
Instruments acceptable to the Administration are understood to include conventions of international level, ILO Convention No. 152 among them
The practical task is locating those certificates, confirming their validity and getting them into a register that a surveyor can work through without assistance
Effort: administrative. The evidence exists and has to be assembled.
Route two: certificates are missing
Compliance may be demonstrated by a factual statement, also called a statement of fact, issued by a competent person approved by the Administration or by the recognised organisation
Where certificates are absent — engine-room cranes are the example most often cited — the owner must determine the appropriate safe working load for test load verification in accordance with the guidelines, and provide evidence of that SWL
Which means an appliance nobody has thought about for years may need an SWL determination, a load test and a marking exercise before the next renewal survey
Effort: substantial, and it needs scheduling rather than discovering.
The item most likely to fall into route two is not the deck crane. It is the smaller appliance nobody classified as cargo gear — an engine-room crane, a stores crane, a provisions davit — which has been lifting things safely for twenty years without anyone asking to see its certificate. Establishing which of your appliances have documentation and which do not is a one-afternoon exercise that determines whether your next survey is routine or expensive.
The Register, and What It Has to Carry
The register requirement is not new — Article 25 of the convention has required one for decades — but the standard of item-level identification has risen, and retention obligations bite. Schedule a walkthrough and load one vessel's gear register during the evaluation.
Table 1: The Cargo Gear Register, Item by Item
| Element | What is required | Cadence | Where it usually fails |
|---|---|---|---|
| The register itself | A register of lifting appliances and items of loose gear, kept in a form prescribed by the competent authority taking account of the international model | Maintained continuously | Kept as a paper book that only one person can navigate |
| Unique identification | Each item clearly and permanently marked with a serial number or tag ensuring traceability between item and certificate | On first entry to service | Loose gear grouped by type, so no item traces to a certificate |
| Safe working load | Marked on the item, and on appliances alongside information essential to safe operation such as slewing radius or boom angle | Permanent | Marking worn illegible, which is a finding in its own right |
| Initial test | Every item of loose gear tested and thoroughly examined before first use | Once, before service | Gear entering service through a purchase nobody logged |
| After alteration or repair | Re-tested and thoroughly examined after any substantial alteration or repair to a part liable to affect safety | Event-driven | A repair carried out and the re-test overlooked |
| Thorough examination | By a competent person, at least once every twelve months, with certification | Annual | Certificate issued and filed separately from the item record |
| Re-test | Lifting appliances forming part of the ship's equipment re-tested at least every five years | Five-yearly | Falls between survey cycles because nobody owns the date |
| Before-use inspection | Loose equipment inspected regularly before use by a responsible person, deciding whether it is whole, undamaged and safe for continued use | Every use | Performed properly, recorded almost never |
| Certificate content | Safe working load, inspector identity, test date and results, in the prescribed format | Per test or examination | Held by the testing company rather than by the vessel |
| Retention | Register and certificates available for inspection by authorised persons and retained for at least five years | Five years minimum | Retention satisfied in a filing cabinet nobody can search |
Retained five years
Available for inspection by authorised persons — which is a different standard from being kept somewhere.
Competent Person, Responsible Person, and Why the Distinction Matters
The convention defines two roles precisely, and confusing them is one of the more common ways a gear programme becomes non-compliant without anyone noticing. Start a free trial and record which category performed each check.
Competent person
A person with the knowledge and experience necessary for thorough examinations and tests of lifting appliances and loose gear, and who is acceptable to the competent authority. In practice usually certified inspectors and expert controllers.
Performs: five-yearly re-tests, twelve-monthly thorough examinations, initial tests, post-repair examinations. Issues certificates.
Responsible person
A person appointed by the master of the ship or by the equipment owner to be responsible for performing inspections. Appointed rather than certified, and the appointment itself is the qualification the convention recognises.
Performs: the before-use visual inspection deciding whether an item is whole, undamaged and safe for continued use.
Where it goes wrong
A thorough examination recorded as having been done by someone who is a responsible person but not a competent person, or an appointment that exists in someone's memory rather than in writing. Both are visible to an auditor and neither is difficult to fix in advance.
Fix: record who performed each check and in which capacity, and keep the appointments documented.
The Port Captain's Actual Problem
The regulatory picture above is only half the job. The other half is that a port captain oversees gear moving between vessels, terminals, contractors and shifts, with different people responsible at each handover. Book a walkthrough and see the gear record follow the item rather than the location.
01
Gear moves and records do not
A sling used on one vessel this week may be on another next week, or ashore, or in a contractor's van. Its certificate lives wherever it was filed. Unique identification is what makes the item findable regardless of where it currently is, which is exactly why the 2026 marking requirement matters operationally rather than only for compliance.
02
Nobody owns the before-use check
It is performed by whoever is rigging, on a shift, under time pressure, and the convention does not require it to be written down. So the check that matters most has no owner in any system, and a decision to reject an item produces no trace that would help anyone else.
03
Terminal equipment sits outside the ship's register
Shore cranes, forklifts, spreaders and terminal loose gear carry their own regimes, their own owners and their own records. A port captain sees the operation as one thing; the paperwork sees it as two, and incidents happen at the interface between them more often than within either.
04
Findings die at the end of a call
A worn sling noticed during a night shift gets set aside, mentioned to the next person and then forgotten when the vessel sails. Without an item-level record it cannot follow the gear, so the same item is rediscovered by somebody else at another berth weeks later.
All four of these are the same underlying problem in different clothing: the record is organised around the event or the location rather than around the item. Once the item carries a unique identification — which the regulation now requires anyway — the record can follow it, and all four resolve at once.
Evaluating a Platform for Cargo Gear and Terminal Operations
Generic maintenance software models fixed assets on a vessel. Cargo gear is portable, numerous, individually certificated and shared between operations. These questions expose whether a platform can carry that. Start a free trial and load a real gear inventory rather than a sample.
Table 2: Buyer Questions for Port Captains and Terminal Operations
| Area | The Question | A Real Answer | What Should Worry You |
|---|---|---|---|
| Item granularity | Can every shackle and sling exist as an individually identified record? | Your own inventory imported at item level with unique IDs and SWL | Loose gear as a category with a quantity against it |
| Certificate linkage | Is the certificate attached to the item, or filed separately? | Certificate held against the item with its dates and issuing person | A document library that has to be cross-referenced by hand |
| Three cadences | Can five-yearly, twelve-monthly and before-use checks all be tracked? | Three independent cycles, with the before-use check capturable in seconds | Annual and five-yearly only, which leaves the frequent one invisible |
| Capacity recorded | Is the person's capacity — competent or responsible — recorded per check? | Capacity as a property of the record, with appointments documented | A name field with no distinction between the two roles |
| Portability | Does the record follow the item between vessels, terminals and contractors? | Item-keyed records independent of current location | Gear modelled as belonging permanently to one vessel |
| Discard criteria | Can a rejection threshold be set that alerts before the item is used again? | Thresholds as data with escalation, not a note in a procedure | Discard criteria held only in the operations manual |
| Marking status | Can I find every item whose marking has become illegible? | Marking condition as a recorded attribute, reportable across the inventory | Nowhere to record it, so it surfaces at survey |
| Retention and retrieval | Can I produce five years of certificates for one item in under a minute? | Retrieved live from your own data during the demonstration | Retention satisfied by storage rather than by retrievability |
| Offline capture | Does it work on a quay, in a hold and on a night shift with no signal? | Full offline capture with photographs and a clean sync afterwards | An assumption of connectivity at the point the check happens |
2026 CARGO GEAR REALITY
Two regimes apply together and neither replaces the other. The SOLAS lifting appliance requirements entered force on 1 January 2026 with guidelines in MSC.1/Circ.1663, and they sit alongside ILO Convention No. 152 rather than superseding it — existing certificates issued under the ILO convention where acceptable to the Administration remain valid for demonstrating compliance. Survey windows are not uniform. For appliances subject to the ILO convention no survey windows are foreseen by the convention itself, and each flag administration may issue its own instructions on how windows are applied. Confirm your own flag's position rather than assuming a common standard. Verification timing differs by ship type. Surveyors verify at the first Cargo Ship Safety Construction Renewal Survey, on a five-year cycle, or the first Passenger Ship Safety Survey, annually, after 1 January 2026 — so there is no single fleet-wide deadline. Terminal and shore equipment sits under separate regimes. National occupational safety law, port authority requirements and equipment owner obligations govern shore cranes and terminal gear, and this page addresses the ship's register rather than those.
Frequently Asked Questions
How often must cargo gear be tested and examined?
On three separate cadences. Lifting appliances forming part of a ship's equipment must be re-tested at least every five years. All lifting appliances and loose equipment must be thoroughly examined and certified by a competent person at least once every twelve months. And loose equipment must be inspected before use by a responsible person, with pre-slung cargoes inspected as frequently as is reasonably practicable. Separately, every item of loose gear must be tested and thoroughly examined before being put into use for the first time, and again after any substantial alteration or repair to a part liable to affect its safety.
What is the difference between a competent person and a responsible person?
A competent person has the knowledge and experience necessary for thorough examinations and tests of lifting appliances and loose gear, and is acceptable to the competent authority — usually a certified inspector or expert controller. They perform the tests and thorough examinations and issue the certificates. A responsible person is appointed by the master of the ship or by the equipment owner to be responsible for performing inspections, and carries out the before-use visual inspection deciding whether an item is whole, undamaged and safe for continued use. The distinction matters because a thorough examination recorded against someone who is only a responsible person is not compliant, and appointments should exist in writing rather than in memory.
What changed under SOLAS on 1 January 2026?
SOLAS Regulation II-1/3-13 entered force with guidelines in MSC.1/Circ.1663, covering application, design, construction, operation, inspection, testing and maintenance of lifting appliances. The decision followed increasing accidents involving lifting appliances and winches, and began with analysis of maritime accident data alongside a review of existing regulation including ILO Convention No. 152. A Register of Ship's Lifting Appliances and Cargo Handling Gear must be maintained on board, the Certificate of Test and Thorough Examination must follow the format in Appendix 1 of the guidelines, and all loose gear must be clearly and permanently marked with unique identification, safe working load and any additional marks required for safe use.
What happens to appliances that predate the new regulation?
Existing lifting appliances installed before 1 January 2026 are regarded as compliant where valid certificates of test and thorough examination were issued beforehand under another international instrument acceptable to the Administration — instruments understood to include international-level conventions such as ILO Convention No. 152. Where no such certificates exist, compliance may be demonstrated by a factual statement, also known as a statement of fact, issued by a competent person approved by the Administration or by the recognised organisation. Where certificates are missing entirely, engine-room cranes being a commonly cited example, the owner must determine the appropriate safe working load in accordance with the guidelines and provide evidence of it.
When exactly will this be checked?
At the first Cargo Ship Safety Construction Renewal Survey, which runs on a five-year cycle, or the first Passenger Ship Safety Survey, which is annual, conducted after 1 January 2026. Surveyors will verify that all applicable appliances are certified to an acceptable standard, that appliances are properly marked with safe working load and other information essential to safe operation such as slewing radius or boom angle, that all loose gear is clearly and permanently marked with unique identification and SWL, that everything has been load tested and thoroughly examined by a competent person, and that operation and maintenance manuals are provided. Because the trigger is your own survey date, there is no common fleet deadline.
Why record the before-use inspection when the convention does not require it?
Because it is the check most likely to catch an item about to fail, and because the absence of a record means nothing learned from it survives the shift. The convention sensibly does not require a register entry for every item picked up in a working day — that would be unworkable and would degrade the register. But a rejection decision that leaves no trace means the same worn sling gets rediscovered by another person at another berth, and a port captain has no way of seeing that a particular item, batch or supplier is generating repeated rejections. Capturing it takes seconds if the item already carries a unique identification, which it now must.
5 years
12 months
Before every use
Track All Three, Not Just the Two That Produce Certificates
Every appliance and every item of loose gear as its own record, with unique identification, safe working load, certificate reference and dates. The capacity of whoever performed each check recorded alongside it. Discard criteria as thresholds that alert rather than as lines in a manual. Records that follow the item between vessels, terminals and contractors. And the before-use inspection captured in seconds on a quay at night, which no regulation asks of you and which is the only one that happens before something goes wrong.
