SOLAS II-1/3-13: which survey sets the deadline for existing cranes

For stores and engine room cranes installed on a cargo ship before 1 January 2026, the load test, thorough examination, safe working load (SWL) marking and SWL evidence are due no later than the first Cargo Ship Safety Construction (SC) certificate renewal survey on or after 1 January 2026. Some Class societies and flags want parts of this earlier, so the SC renewal date is your outer limit, not your plan.

Key points

• SOLAS regulation II-1/3-13.2.4 sets the deadline as "the first renewal survey on or after 1 January 2026". Unless the flag says otherwise, IACS reads this as the SC renewal survey (cargo ships) or Passenger Ship Safety survey (passenger ships).
• The test load for appliances used in port or sheltered waters comes from Table 1 of MSC.1/Circ.1663: 1.25 x SWL up to 20 t.
• Valid ILO 152 certificates, or others under an instrument acceptable to the flag, issued before 2026 count if shown to come from the flag or a competent person (which can be an RO). Uncertified ones can use a "factual statement" under MSC.1/Circ.1696.
• After that, every appliance needs a yearly thorough examination and a load test at least every five years. Some flags, such as Liberia, allow windows or alignment with HSSC survey dates.
• Where ClassNK issues the SC certificate, it checks loose gear, the appliance list, SWL evidence and marking at the first SC periodical survey on or after 1 January 2026, whichever survey type that is.
• Whether appliances under 1,000 kg SWL are exempt depends on your flag.

What the regulation requires for existing appliances

Regulation 3-13, added by resolution MSC.532(107), entered into force on 1 January 2026. Its definition of "lifting appliance" (regulation II-1/2.30) names engine-room and stores cranes. Like the rest of SOLAS, it covers ships on international voyages: cargo ships of 500 gross tonnage and above, and passenger ships (more than 12 passengers) of any size (SOLAS chapter I, regulations 2 and 3).

"Installed before 1 January 2026" has a defined meaning (regulation II-1/2.33). On a ship whose keel was laid (or at a similar stage of construction) before that date, an appliance is existing unless its contractual delivery date (or, failing that, actual delivery to the ship) is on or after 1 January 2026.

For existing appliances, paragraph 2.4 requires by the deadline a load test and thorough examination based on MSC.1/Circ.1663, permanent SWL marking (paragraph 2.3) and documentary evidence of the SWL.

A thorough examination is a detailed check by a "competent person" acceptable to the flag, usually the Class society or a flag-approved firm, as Britannia P&I notes. Paragraph 3 (operational testing, examination, inspection, operation and maintenance) applies to every appliance whatever its age, from 1 January 2026.

Which renewal survey: the Safety Construction certificate

The regulation says "first renewal survey" but not which certificate. IACS Recommendation No. 198 (April 2026) reads it as a survey that leads to a new certificate: the five-yearly Safety Construction renewal survey for cargo ships, and the yearly Passenger Ship Safety survey for passenger ships. It cites the IMO Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), resolution A.1186(33) "or latest revision". A.1186(33) was replaced by A.1207(34) in December 2025, which Rec. 198 cites elsewhere; the renewal survey wording is unchanged.

Under the HSSC, the SC renewal survey can be completed up to three months before expiry without losing validity. It may also start at the fourth annual survey and progress through the following year, but fourth annual survey items cannot be credited to the renewal survey (A.1207(34), paragraph 4.5.1.2).

So a ship whose SC renewal survey was completed in late 2025 has until its next SC renewal, around 2030 or 2031 depending on the expiry date, though ClassNK's earlier checks still apply. For passenger ships, the deadline was their first Passenger Ship Safety survey of 2026.

Where Class and flag practice differ

The under-1,000 kg exemption depends on your flag

Regulation 3-13.1.3 lets each Administration decide how far paragraphs 2.1 and 2.4 (not paragraph 3) do not apply to appliances with an SWL below 1,000 kg. IACS reads it this way: if the flag has issued nothing, they apply in full. It also warns that a change of flag can change the answer.

Flag answers are rarely a simple yes or no. Liberia's Marine Notice SAF-020 (Rev. 12/25) requires new appliances under 1,000 kg to be load tested and certified after installation. For all appliances under 1,000 kg, owners should assess usage and risk and put inspection and maintenance procedures into the Safety Management System (SMS).

ClassNK's lifting appliances page summarises other flags' positions and links their circulars. It lists Antigua and Barbuda, for example, as applying the rule but letting existing appliances under 1,000 kg stay in service if maintained and documented in the planned maintenance system (PMS). We have not checked these summaries against the circulars, so read your own flag's.

Choosing an SWL without maker's papers

Without a valid certificate, IACS Rec. 198 (paragraph 6.3) says the company should nominate the SWL, to the satisfaction of the flag, from manuals or drawings, or failing that, a company declaration. Circ.1663 paragraph 3.2.1.6 covers the narrower case where the SWL is undocumented and design information is not available, such as when the maker no longer exists: the test load is calculated from the nominated SWL, which then becomes the marked SWL (paragraph 3.4.3).

A competent person or RO witnesses the test and examination and issues a factual statement under MSC.1/Circ.1696, a unified interpretation that IMO Member States are invited to apply, not a mandatory rule. The statement confirms paragraph 2.4 only, says the SWL was nominated by the company and not confirmed, uses a different form from the Circ.1663 sample certificate, and may be attached to the Register of Lifting Appliances.

Table 1 of MSC.1/Circ.1663 sets the minimum test loads for appliances used in port or sheltered waters:

For appliances used at sea, the flag or Class sets the test load, allowing for dynamic loads. The corrigendum MSC.1/Circ.1663/Corr.1 changes only the Table 2 factor for multi-sheave blocks and hook blocks over 25 t up to 160 t SWL, from 0.993 to 0.933 (Liberia's SAF-020 reproduces the corrected table). No figure in this article is affected.

After the deadline: the five-yearly retest and loose gear

Each appliance then needs a load test at least every five years (Circ.1663 paragraph 3.2.1.4) and a thorough examination after every load test and every year (3.2.2.1). IACS treats the last load test date as the anniversary date and allows no extension of the five-year test unless the flag authorises one.

Loose gear (hooks, blocks, shackles and similar items attaching the load) needs documentary evidence of a proof test, a yearly thorough examination, and marking with a serial number and SWL. Table 2 of the Guidelines sets proof loads; hooks and shackles up to 25 t SWL, for example, are tested at 2 x SWL.

If there is no evidence that an item was ever proof tested, IACS recommends replacing it. ClassNK's TEC-1361 corrected an earlier note: proof test certificates are needed for loose gear used with any appliance subject to regulation 3-13, including small appliances a flag has exempted from paragraph 2.4.

Worked example: SC certificate expiring 15 March 2027

A 2012-built Liberian-flag bulk carrier has an SC certificate expiring on 15 March 2027. It has four 30 t deck cranes with ILO 152 certificates (last load tested June 2023), an uncertified 2 t provision crane and 5 t engine room overhead crane, and a permanently installed 0.5 t monorail hoist in the workshop, all installed before 1 January 2026.

The ILO certificates count, though IACS recommends a fresh load test on entry. The hoist is in scope because it is permanently installed (a removable chain block would not be). Being under 1,000 kg, it falls under SAF-020's risk assessment and SMS procedures, but paragraph 3 and loose gear rules still apply.

If the renewal survey starts at the fourth annual survey, ask your RO which attendance it treats as the deadline, and finish the tests before the renewal survey begins.