Every ship holds drills. Far fewer can produce a record that proves who took part, which boat was used, and that no month was missed. That gap is where the deficiencies come from, and incomplete drill records are among the most common detainable findings.
The Requirement Is About Individuals, Not Events
SOLAS Chapter III, Regulation 19 is precise in a way that catches people out. It does not require a ship to hold a fire drill every month. It requires that every crew member participates in at least one abandon ship drill and one fire drill every month. The obligation attaches to each person, not to the calendar.
That distinction changes what a compliant record looks like. A log showing twelve fire drills in twelve months proves nothing about the second engineer who was on leave for two of them and on watch for two more. The record has to demonstrate participation per person, which is why inspectors ask for names rather than headcounts, and why a record that says “crew participated” satisfies nobody.
The rule is not one drill a month. It is one drill a month for each person aboard, which is a much harder thing to prove and a much easier thing to fail.
The Triggers Beyond the Monthly Cycle
Three additional triggers sit alongside the monthly requirement, and each exists because crew composition changes faster than the calendar.
Monthly: Every crew member participates in at least one abandon ship drill and one fire drill each month. On passenger ships, both are held weekly.
The 25% rule: Drills must take place within 24 hours of the ship leaving port if more than 25% of the crew have not participated in abandon ship and fire drills on board that particular ship in the previous month.
Before sailing: When a ship enters service for the first time, after a modification of a major character, or when a new crew is engaged, the drills are held before sailing rather than afterwards.
Familiarisation training: On-board training in the use of the ship’s life-saving appliances, including survival craft equipment, and in the use of fire-extinguishing appliances, given as soon as possible and not later than two weeks after a crew member joins.
Coverage cycle: All of the ship’s life-saving and fire-extinguishing appliances must be covered within any period of two months.
The 25% rule deserves attention because it is easy to breach without noticing. It refers to participation on that particular ship, so an experienced officer who has drilled a hundred times on other vessels still counts as not having participated. On a ship with a heavy crew change in port, the threshold can be crossed by a routine rotation, and the 24-hour clock starts at departure whether or not anyone has done the arithmetic.
The Equipment Intervals Inside the Drills
Layered onto the drill frequency is a set of equipment-specific requirements that determine what a drill must actually include. These are where the record gets detailed, and where rotation matters.
The rotation requirement is the one most often missed. Lowering the same convenient lifeboat every month for two years satisfies the count and defeats the purpose, since the boat nobody has touched is the one most likely to fail. An inspector reading a record that names the same boat repeatedly has found something without needing to look at the equipment at all.
What the Record Must Contain
Because a drill leaves no physical trace, the record is the entire evidence base. Port State inspectors examining drill documentation typically look for the date and time, the type of drill, a description of the scenario including the location and conditions simulated, the equipment actually used, participation by name rather than by number, response times where measured, the debrief findings and any corrective actions, and the Master’s signature confirming the drill took place.
A drill leaves nothing behind but paper. That makes the record not an administrative afterthought but the only evidence the drill ever happened.
Read across a year, the record also has to show three patterns: unbroken monthly frequency with no gaps, rotation through different lifeboats at successive drills, and variety in scenarios rather than the same engine room fire every month. Missing or incomplete drill records are among the most frequently cited deficiencies, and they can support detention, because a ship that cannot demonstrate crew preparedness has not demonstrated compliance with a core safety requirement.
Conducted As If It Were Real
SOLAS requires that drills are conducted, as far as practicable, as if there were an actual emergency. That phrase is doing real work, and it is the difference between a drill and a muster.
In practice it means summoning by the general alarm followed by the public address system, exactly as in a real event; crew mustering at their stations properly dressed with lifejackets correctly donned; a headcount verified against the muster list; and equipment actually operated rather than pointed at. Where an element is genuinely difficult, the guidance is to pause and explain rather than to skip, and to document the lessons for the next session.
This is also where the muster list earns its place. It is not a poster. It assigns each person a duty and a station, and a drill is the mechanism that confirms every individual knows theirs. A muster list that no longer matches the crew list, which happens quietly after a few rotations, undermines every drill held under it and is trivially checked by comparing the two documents side by side.
Making the Records Hold Up
None of this requires more drills. It requires the drills already being held to be recorded in a way that survives scrutiny. Track participation per person rather than per event, so the monthly obligation can be demonstrated for each crew member including new joiners. Watch crew turnover against the 25% threshold at every port. Rotate the lifeboat used and vary the scenario deliberately, and record which was which. Give new joiners their familiarisation training inside two weeks and log it. And write the debrief, including what went wrong, because a record showing a problem found and corrected is far more credible than one showing twelve flawless drills.
The underlying point is the same one that runs through inspection generally. The crew that drills properly is safer, and the ship that records it properly is the one that can prove it. Both are needed, and only one of them is visible to an inspector standing on the deck.
Frequently Asked Questions
How often must fire and abandon ship drills be held?
Under SOLAS Chapter III, Regulation 19, every crew member must participate in at least one abandon ship drill and one fire drill every month, and on passenger ships both are held weekly. The obligation attaches to each individual rather than to the ship, so a log of monthly drills does not by itself demonstrate compliance for a crew member who missed them.
What is the 25% rule?
Drills must be held within 24 hours of the ship leaving port if more than 25% of the crew have not participated in abandon ship and fire drills on board that particular ship in the previous month. Participation elsewhere does not count, so experienced officers new to the vessel still fall within the threshold, and a routine crew change in port can trigger it without anyone noticing.
How often must lifeboats actually be launched?
At least one lifeboat must be lowered monthly, using different boats at successive drills, and each lifeboat must be launched with its assigned operating crew aboard and manoeuvred in the water at least once every three months. Free-fall lifeboats are launched by free fall every six months, or simulated launching may be accepted at that interval where the Administration permits a twelve-month extension.
What do inspectors look for in drill records?
Date and time, type of drill, the scenario simulated, equipment used, participation by name rather than headcount, response times where measured, debrief findings with corrective actions, and the Master’s signature. Read across the year, the records should also show unbroken monthly frequency, rotation through different lifeboats, and varied scenarios. Missing or incomplete records are among the most commonly cited deficiencies and can support detention.
Sources: IMO SOLAS Chapter III, Regulation 19, Emergency training and drills (monthly drill participation, the 25% rule, drills before sailing, lifeboat lowering and launching intervals, free-fall launching, and on-board training within two weeks of joining) · IMO SOLAS Chapter III, Regulation 8, Muster list and emergency instructions · IMO SOLAS Chapter III, Regulation 30, Drills on passenger ships · IMO SOLAS Chapter III, Regulation 20, Operational readiness, maintenance and inspections · IMO Resolution A.1155(32), Procedures for Port State Control
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