Outside the Polar Code, Not Outside the Cold: The Survival Gap on Naval and Government Vessels
The same water, a different rulebook
A sailor on a naval patrol vessel in the Barents Sea faces the same water as the crew of a merchant ship a few miles away. The temperature is the same, and so is the time it may take for rescue to arrive. What differs is the rulebook.
The IMO Polar Code was written to protect the people aboard commercial ships operating in polar waters. Chapter 8 requires that survival equipment keep people alive for the maximum expected time of rescue, which may never be taken as less than five days. Warships and government vessels on non-commercial service, however, sit outside its mandatory scope.
This post sets out why that distinction matters, and why the absence of a regulatory requirement does not remove the obligation to protect a crew.
Government vessels often operate furthest from help. Photo: U.S. Coast Guard.
What the exemption actually means
SOLAS does not apply to ships of war and troopships, and the Polar Code's mandatory provisions do not apply to ships owned or operated by a government and used only on non-commercial service. Naval combatants, auxiliaries, coast guard cutters, and many research and survey vessels therefore fall outside the Code's reach.
The exemption is not an oversight. Navies set their own technical standards, and sovereign vessels are not subject to flag-state or port-state inspection in the way commercial ships are.
The practical result, however, is that no international instrument asks a naval or government operator to demonstrate that its crew could survive five days in polar water. Some nations close part of this gap through national rules. The United Kingdom, for example, requires its defence vessels to comply with merchant shipping legislation, including the Polar Code, through the Defence Maritime Regulations. Many others have no equivalent mechanism, and the question is left to each service's own equipment policy.
Why the gap matters
Most immersion suits in service today, on commercial and government vessels alike, are standard LSA suits certified to MSC.81(70). That standard tests a suit for six hours in water at 0–2°C. Standard LSA suits were never designed nor tested in polar conditions, and they do not meet the goal-based requirements of Polar Code Chapter 8.
The evidence that this matters is growing:
Lloyd's Register (Case #00845510, February 2026) acknowledged that standard suits may not consistently ensure five-day survivability under realistic polar conditions.
IMO guidance (MSC.1/Circ.1614/Rev.1) recognises that survival depends on the combination of equipment, training and leadership, and that equipment must be matched to the expected time of rescue.
The US Coast Guard Research and Development Center (2023) studied Arctic search and rescue specifically to verify the Polar Code survival-time requirement.
Chile's DIRECTEMAR committed in February 2026 to verify Chapter 8 survival equipment during port state control at Punta Arenas, the first administration to act on the gap.
Naval and government vessels are often the ones operating furthest from help. They patrol, survey and resupply in remote waters, frequently alone. If a merchant crew needs more than a standard suit to survive a polar abandonment, a naval crew in the same water needs it no less.
Duty of care does not depend on a certificate
An exemption from a regulation is not an exemption from responsibility. Every service accepts a duty of care toward the people it sends to sea, and that duty is measured against the conditions they will actually face, not against the instruments that happen to apply.
The Polar Code is, in effect, the international community's best statement of what survival in polar water requires. A naval or government operator that is not bound by it can still use it as a benchmark. Where rescue may take days, the relevant question is the same for every vessel: can this equipment keep this crew alive until help arrives?
That question also extends beyond the polar regions. Any vessel operating in cold water, hours or days from search and rescue, faces the same arithmetic of rescue time against survival time.
Survival equipment must be matched to the conditions a crew will actually face.
Closing the gap
Closing the gap does not require new regulation. It requires naval and government operators to ask of their own equipment the question the Polar Code asks of commercial ships. In practice, that means four steps:
Estimate the realistic time to rescue for each area of operation, using the METR methodology in MSC.1/Circ.1614/Rev.1.
Verify that issued immersion suits are designed and tested for that time and those conditions, not only certified to MSC.81(70).
Where they are not, specify suits that meet Chapter 8's functional requirements as a voluntary standard.
Train crews to don and use that equipment in realistic conditions, including donning after entering the water.
White Glacier designs the Arctic 10+ for exactly this situation: an abandon-ship survival suit built for extended time in cold water, which can be donned even when the wearer is already wet. We welcome conversations with naval architects, equipment managers and medical officers who want to evaluate their fleet's exposure.
#PolarCode · #MaritimeSafety · #DutyOfCare · #NavalOperations · #ColdWaterSurvival · #ImmersionSuits
To discuss your fleet, or to request a technical briefing, contact Diego Jacobson at djacobson@whiteglacier.com.
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