1 It has been found that counterfeit and substandard
life-saving appliances (LSA) are available on the market. Those goods
cost less than the real and quality product and are always inferior
and, therefore, less durable, unsafe or downright dangerous because
they have not undergone the rigorous testing that should be applied
to make sure that they are safe.
2 It is of utmost importance that awareness is
raised of the problem of counterfeit and substandard life-saving products
and the wide range of problems they might cause for the maritime industry.
3 All interested parties, including Administrations,
recognized organizations (ROs), shipyards, shipowners, etc., should
take responsibility in applying rigorously the applicable requirements
when LSA products are manufactured and thoroughly check the accompanying
approvals and documents of approved LSA products, particularly those
with a certified service life, when they are purchased and installed
on board ships. Counterfeit and substandard LSA products may include,
for example, hydrostatic release units, pyrotechnic man-overboard
lights, smoke signal products, lifejacket lights, lifebuoy lights
and emergency water rations for use in survival craft.
4 In addition to the above, in some cases used
LSA products, from scrapped ships or discarded from operational ships
after expiry, are refurbished and sold, whereby the original manufacturer's
label is removed, the sealed product is only cleaned externally and
a replacement label is then applied, which is identical to the original,
except that the dates of manufacture and expiry are falsified to extend
the period of acceptability. For these products, extra vigilance by
all related parties, particularly shipowners and Administrations/ROs,
is recommended, and all associated documents should be thoroughly
checked.