Safety Radio

Survey for Cargo Ship Safety Radio Certificate

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Guidelines for the installation of equipment of radio installations on board SOLAS ships are displayed in COMSAR/Circ 32/Rev.3 see attached files. These guidelines were developed and amended in order to provide an unambiguous interpretation of the radio installation requirements in SOLAS chapter IV, as amended, and adopted IMO resolutions.

The core elements of this document give Guidelines on GMDSS installations on board ships. However, additional useful information is included from other bodies which are involved when maritime radio equipment is installed.

Radio Specialist

1. The Surveyor relies upon an approved Radio Specialist to perform the inspection of the ship's radio communication equipment. The Surveyor is nevertheless responsible for the intervention : he endorses the survey report and issues the relevant certificate. He therefore attends the survey.

2. The Radio Specialist is an approved sub-contractor. The conditions of approval and use are specified in NR 533 and the related survey procedure. He shall be advised in writing of the survey to be conducted and he shall not disclose any information relating to the survey to a third party. A list of Radio Specialists capable of being appointed to perform surveys is kept updated in the Survey Centre.

3. The duties and responsibilities involved in the Radio Specialist's task are clearly defined through the content of the survey report which is handed to him and which he has to complete. The report clearly shows these duties and responsibilities :

   • apply compulsory regulations (stated as heading of the report),

   • state the survey findings,

   • give an advice regarding the issuance of a certificate.

   His commitments are finalised by the signature of the report.

Survey and certification

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1. The Surveyor draws the attention of the Radio Specialist to the fact that he must fill in the survey report correctly and clearly specify the points which are not in conformity with the Regulations and which are the subject of recommendations. He must keep in mind that there should only be minor recommendations and that all important recommendations such as transmitter or receiver out-of- order, represent as great a danger to the ship as any other equipment which is perhaps more obvious, such as damaged lifeboats.

2. The 1988 Protocol to SOLAS 1974 provides for the issuance of a Cargo Ship Safety Radio Certificate with a 5-year validity. Periodical Surveys are nevertheless conducted every year, within a window of plus or minus three months from the anniversary date. The scope of these surveys are the same, except that the Renewal Survey provides for the issuance of a new Cargo Ship Safety Radio Certificate.

3. The Surveyor endorses the date and place of the survey onto the Cargo Ship Safety Radio Certificate in the same way as he endorses annual surveys (Safety Construction, Safety Equipment, Load Lines, MARPOL).

Modernization of GMDSS – reissuance of SOLAS Certificates on or after 1 January 2024

The format of SOLAS Certificates (i.e., CSSC, SafEq, SafRad, PSSC) have been amended, through resolution MSC.496(105) and resolution MSC.496(105), to accommodate the modernization of GMDSS. The revised formats are available on ASMS Certificate from 1 January 2024.Bearing in mind that amendments to SOLAS chapter IV, do not bring substantive changes to the radio installations on existing ships, as they are introduced mostly to accommodate any new future technologies or the existing arrangements by generalizing, modifying and/or relocating the expressions therein, therefore and unless ships are subject to modifications (e.g. such as VHF-EPIRB, NBDP in sea area A3), IMO confirmed (ref. MSC 105/20 para. 3.12) that in accordance with the provisions in paragraph 3.1 of the Guidance provided in MSC-MEPC.5/Circ.6, re-issuance of the relevant certificates and their supplements, if any, after entry into force of the amendments, would not be necessary until their expiry (unless otherwise instructed by the ship’s Flag State, refer to flag procedures).

Global Maritime Distress System (GMDSS) - SOLAS 1974, Ch. IV

The GMDSS applies to all ships since 1 February 1999

It should be underlined that, within the scope of GMDSS, the manning of the ship regarding Radio communications is left to the Flag Administration. The Surveyor therefore refers to the Manning Documents held by the ship to ensure that the ship is correctly manned.

In general, based on the position taken by several Administrations, a ship equipped in compliance with GMDSS would not require a dedicated Radio Officer provided that two (or more) Deck Officers hold valid Radio Telephone Operator Certificates.

A table showing the status of the equipment to be provided on board a ship under GMDSS as per IMO Resolutions is shown in section 2 "GMDSS equipment and governing IMO Resolutions".

Modernization of GMDSS – entry into force on 1 january 2024 of amended SOLAS chapter IV

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IMO MSC 105 adopted amendments SOLAS chapter II-1, III, IV and V, the appendix (Certificates) and the 1988 SOLAS Protocol (Certificates); through resolution MSC.496(105) and resolution MSC.497(105). The amendments enter into force on 1 January 2024.The revision of the Global Maritime Distress and Safety System (GMDSS) aims to allow the use of modern communication systems, while removing the requirements for carrying obsolete systems.The amendments to SOLAS Chapter IV include the use of generalized terms for GMDSS technologies, consolidation of provisions for VHF radio telephone apparatus and SART (Search and Rescue Transponder), changes in sea area coverage, and the removal of the NBDP (Narrow Band Direct Printing) function for MF/HF radio installations.

In relation to the Modernization of GMDSS which enters into force on 1 January 2024, below are the notable changes for existing shipboard equipment:

• MF/HF radio installation cannot be using as primary equipment for sea area A3 but remains only primary equipment for sea area A4.

• If different types of RMSS SES are installed on board as the primary and duplicated system, the RMSS SES with lesser coverage should be designed as primary system.

• VHF-EPIRB is no longer be accepted in lieu of satellite EPIRB for sea area A1. Ships operating exclusively in sea area A1 should replace VHF-EPIRB with satellite-EPIRB

Clarification on duplicated MF/HF radio installation requirements in sea area A3

MSC 109 confirmed that a single MF/HF radio installation may be accepted both as a primary MF radio installation and a duplicated MF/HF radio installation for sea area A3.

Consequently, the Committee approved COMSAR.1/Circ.32/Rev.3, amending footnote no. 6 of the table beneath paragraph 2.3 , superseding COMSAR.1/Circ.32/Rev.2.

GMDSS. Functional requirements (SOLAS, Reg.IV/4)

The aim of the GMDSS is to alert shore-based search and rescue authorities, in addition to ships sailing in the vicinity, so that coordinated assistance in search and rescue operation be met.

Every ship to which SOLAS, Chapter IV applies, shall be capable of :

1. performing the GMDSS functions, which are as follows :

1. transmitting ship to shore distress alerts by, at least, two separates and independent means each using a different radiocommunication service,

2. receiving shore to ships distress alerts relays,

3. transmitting and receiving ship-to-ship distress alerts,

4. transmitting and receiving search and rescue coordinating communications,

5. transmitting and receiving on-scene communications,

6. transmitting and receiving signals for locating,

7. receiving MSI,

8. transmitting and receiving urgency and safety communications,

9. transmitting and receiving bridge-to-bridge communications.

2. transmitting and receiving general radiocommunications

GMDSS Communications

Land communications

VHF is used in radio-telephony (R/T). Communications are established through Digital Selective Call (DSC). Channel 70 is a frequency dedicated to distress communication,

MF/HF are used in radio-telephony and telex also with DSC. Frequencies are dedicated to distress, safety, navigation angd general communications,

DSC (Digital Selective Call) is a specific message assigned to the distress indicating the position of the ship and the kind of distress,

Maritime Safety Information (MSI), such as NAVTEX, EGC or HF-MSI are used to broadcast Notices to Mariners and Weather Reports and Meteorological Warnings.

Satellite Communications

Satellite communications are Recognized Mobile Satellite Service (INMARSAT, IRRIDIUM, etc.) which are officially acknowledged and regulated by relevant authorities. Mobile satellite services involve the provision of communication services, including voice and data, through satellite networks for mobile users, such as those on ships, and remote locations.The RMSS SES (Ship Earth Station) installed on board should be able to receive EGC(Enhanced Group Calling) broadcasting in the sea area where the ship is intended to operate. If different types of RMSS SES are installed on board as the primary and duplicated system, the RMSS SES with lesser coverage should be designed as primary system.

INMARSAT: This is a Geostationary Satellite System. It provides for radio-telephony communications, telex, fax data transmission. INMARSAT also supports the EGC System (Enhanced Group Call) which operates the FLEET NET (a trading service) and the SAFETY NET. SAFETY NET is transmitting safety information in open seas, therefore completing NAVTEX.

INMARSAT Maritime Services are operated through several standards, the most often used being Standard A (telephony, telex, fax and data) and Standard C (telex, data transmission, SAFETY NET, FLEET NET).

COSPAS-SARSAT: This is a Polar Orbiting Satellite System used for distress alert through EPIRB (Emergency Position Indicating Radio Beacon) working on main frequency 406 KHz.

IRRIDIUM: Iridium Communications operates a constellation of low Earth orbit (LEO) satellites to provide global mobile satellite services. Their network is used for voice and data communication, particularly in remote areas.

GMDSS. Relationship Functions/Communications

GMDSS. Sea Areas (SOLAS, Reg.IV/2)

Oceans and coastal waters are divided into four Sea Areas. The areas are defined according to the kind of radio-communication facilities that are provided on their coast. The basic definition of the sea areas is the following :

• Sea Area A1. Within the range of shore-based VHF coast stations (20-30 miles),

• Sea Area A2. Within the range of shore-based MF coast stations, excluding A1 area (100 miles),

• Sea Area A3. Within the coverage area of a recognized mobile satellite service supported by the ship earth station carried on board,

• Sea Area A4. An area outside of sea areas A1, A2 and A3.

Radio communication equipment on ships engaged on voyages in sea areas A2 and A3 – IACS REC 195

With the comprehensive revision of SOLAS Chapter IV, as adopted by MSC.496(105), and the subsequent approval of COMSAR.1/Circ.32/Rev.2 (which has been further revised as Rev.3), questions arise regarding how MF/HF installations should be recorded in the Record of Equipment for the SOLAS ship’s safety certificates. In this context, IACS developed REC 195 providing the correct method for recording MF/HF installations in the Passenger Ship Safety Certificate, Cargo Ship Radio Safety Certificate, Cargo Ship Safety Certificate for the following two cases:- A single MF/HF serving both as a primary MF and a duplicated MF/HF (Recommendation 2.1)- MF/HF installed to meet the requirement of MF, in other words, an MF/HF substitutes an MF (Recommendation 2.2)Unless otherwise instructed by the flag, the provisions of IACS REC 195 apply (see attached REC195). Refer to the examples described in Appendix Radio communication equipment on ships engaged on voyages in sea areas A2 and A3 for the application of REC 195 and the harmonization of provisions to be indicated in the record of radio equipment FORM R / FORMC / FORM P in ASMS Certificate, as appropriate and at the first opportunity but not later than the renewal of the SOLAS certificates.

GMDSS - Equipment to be provided on board ships (SOLAS, Reg. IV/7 to 11)

The table displayed in GMDSS. Radio-communication equipment to be fitted on board ships (COMSAR.1/Circ.32/Rev.3) shows the radio-communication equipment to be fitted on board ships according to the sea area where they are operated and certified (circular COMSAR.1/Circ.32/Rev.3 - Harmonization of GMDSS requirements for radio installations on board SOLAS ships).

GMDSS - Maintenance requirements (SOLAS, Reg. IV/15)

Equipment shall be constructed and installed so as to be easily accessible for inspection and maintenance. Main equipment units shall be easily replaceable. Information regarding operation and maintenance shall be made available on board.

The availability of the GMDSS functions at sea shall be ensured through the following method :

• duplication of equipment,

• shore-based maintenance,

• at sea electronic maintenance capability.

In sea areas A1 and A2, one of these three methods shall be used. In sea areas A3 and A4, a combination of at least two of the three methods shall be used.

It should be noted that evidence of the use of the second method (shore-based maintenance) should be produced through a copy of a contract showing that a radio company is in charge of the maintenance. The use of the third method (at sea electronic maintenance capability) involves the ship to be manned by a dedicated officer.

The Society's current experience shows that a combination of duplication of equipment and shore-based maintenance is most often used on board ships operating sea areas A3 and A4.

GMDSS - Two-way radio-communication equipment. Position updating (SOLAS, Reg. IV/18)

As from 1st July 2002, any two-way radio-communication equipment which is capable of automatically including the ship's position is the distress alert is subjected to requirements for updating the ship's position. The equipment shall be automatically provided with the ship's position either from an internal or external navigation receiver.

If no receiver is installed, the ship's position (and time at which the position was determined) shall be manually updated at intervals not exceeding four hours.

Validity of radiocommunications equipment installed and used on ships.

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IMO Maritime Safety Committee, at its ninety-second session recognized that incompatibility may exist between radiocommunication equipment installed on ships, and the revised frequencies and channelling arrangements for the maritime HF and VHF bands as contained in appendices 17 and 18 to the Radio Regulations (RR) - Edition 2012. MSC 92 approved the circular MSC.1/Circ.1460 - Guidance on the validity of radiocommunications equipment installed and used on ships.

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However, MSC 97 approved a revision of the circular as MSC.1/Circ.1460/rev.1 and agreed to amend the date in paragraph 6 of the circular to 1 January 2024 (to align the date with the upcoming revision of SOLAS Chapter IV)Revised paragraph of Circular MSC.1/Circ.1460 reads:"To ensure GMDSS communication capability, HF radiocommunication equipment capable of operating narrow-band direct printing (NBDP) should be updated so that following the first radio survey after 1 January 2017 1 January 2024 it meets the channelling arrangements reflected in sections II and III of part B in appendix 17 of the RR."

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Furthermore, MSC 98 approved a revision of the circular as MSC.1/Circ.1460/Rev.2 and agreed to amend the paragraph related to MF and VHF with the intention to treat MF radiocommunication equipment capable of operating NBDP as well as VHF equipment in the same way as HF NBDP radiocommunication equipment. Revised paragraph reads :“To ensure GMDSS communication capability and the availability of appropriate GMDSS radiocommunication equipment, MF radiocommunication equipment capable of operating NBDP as well as VHF equipment, without prejudice to the arrangements contained in appendix 18 of the RR, should be updated so that following the first radio survey after 1 January 2024, at the earliest, it meets the arrangements which will be in force by then.”Refer to Circular MSC.1/Circ.14060/Rev.2 -Guidance on the validity of radiocommunications equipment installed and used on ships (See the attached file “MSC.1-Circ.1460-Rev.2”)

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In addition, the Maritime Safety Committee, at its 107th session (31 May to 9 June 2023), approved the guidance set out in the following paragraphs, taking into account concerns over the availability of VHF radiocommunication equipment compatible with the frequencies and channelling arrangements set out in Appendix 18 of the ITU Radio Regulations (RR) – Edition 2020. This guidance recognizes that incompatibility may exist between VHF radiocommunication equipment installed on ships and on shore, and the revised frequencies and channelling arrangements in Appendix 18 of the RR.

Revised paragraph reads :“To ensure GMDSS communication capability and the availability of appropriate GMDSS radiocommunication equipment, and without prejudice to the arrangements contained in Appendix 18 of the RR, VHF radiocommunication equipment should be updated following the first radio survey after 1 January 2028, at the earliest, so that it meets the arrangements that will be in force by then.”Refer to Circular MSC.1/Circ.14060/Rev.4 -Guidance on the validity of radiocommunications equipment installed and used on ships (See the attached file “MSC.1-Circ.1460-Rev.4”)

Performance Standard (SOLAS, Reg. IV/15)

Refer to the Table in GMDSS equipment and governing IMO Resolutions "GMDSS equipment and governing IMO Resolutions".

In relation to the Modernization of GMDSS which enters into force on 1January 2024, IMO also adopted a substantial number of amendments or revisions to existing related resolutions and guidelines, including performance standards for relevant equipment. But delays in developing relevant IEC standards have been reported to the IMO highlighting the risk that there may not be GMDSS equipment complying with the revised Performance standards for implementation on 1 January 2024.Consequently, IMO approved circular MSC.1/Circ.1676 permitting until 1 January 2028 the continued installation new shipborne VHF radio installations, shipborne MF and MF/HF radio installations or Inmarsat-C ship earth stations conforming to former performance standards.Refer to the attached MSC.1/Circ.1676

Shipborne navigational equipment (SOLAS, Revised Reg.V/19)

Global Navigation Satelite System, Revised SOLAS Reg. V/19

Under the "old" regulation, all ships of 1,600 grt and upwards were fitted with radio direction finding apparatus. This apparatus is however no more required as from the first survey after 1st July 2002. At this time, it shall be replaced either by a Global Navigation Satellite System (GNSS) or by a terrestrial position finding system.

The Specialist is checking the system and makes sure that it is in woking condition.

Radars, Electronic Plotting Aid (EPA), Automatic Tracking Aid (ATA) and Automatic Radar Plotting Aids (ARPA), SOLAS, Reg. V/12(g) to (j) and revised Reg. V/19

See Section 2.6, Point 8.

The Specialist is checking the radar(s), EPA, ATA and ARPA in service and examine the maintenance manual and records.

Automatic Identification System (AIS), Revised SOLAS Reg. V/19

The Specialist is checking the system and makes sure that it is in woking condition. On completion of satisfactory survey, he issues the AIS Test report. Cf Safety Equipment

Radio life-saving appliances and onboard communications and alarms systems

The radio equipment required by SOLAS, Reg. III/6.2 (two-way VHF radio-telephone apparatuses and radar transponders) and Reg. III/6.4 (onboard communication and alarm systems) shall be checked at the periodical/renewal surveys.

The checking of this equipment shall be clearly recorded on the survey report.

EPIRBs - Two-way (VHF) radiotelephone apparatus.

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Emergency Position Indicating Radio beacon (EPIRB) - GMDSS (SOLAS, Reg. IV/ 7.1.5)

This equipment must have been fitted onboard ships built on/after 1 February 1992 fully equipped as per GMDSS and, in any case, onboard every ship since 1 August 1993. It is a manually-activated EPIRB, capable of floating free and of being automatically activated when afloat.

Annual testing

As from 1 July 2002, the EPIRB is subjected to an annual test which may be conducted either on board the ship or at an approved testing/servicing station (SOLAS Reg.IV/15.9). The regulation does not clearly set the survey window for EPIRB equipment. However, unless otherwise instructed by the Administration, MSC.1/Circ.1576 / IACS UI SC279 applies :

“The annual test of the EPIRBs shall be carried out within the "time window" of the prescribed survey, but not later than the date of completion of the survey for endorsement / renewal of the relevant Certificate.”

A copy of the testing report shall be left on board the ship in order to avoid any subsequent misunderstanding with PSC and a copy of the same is attached to the survey report.

Refer to Circular MSC.1/Circ.1040/Rev.2 the Revised Guidelines on annual testing of emergency position-indicating radio beacons (EPIRBs) (See the attached file “MSC.1-Circ.1040-Rev.2”) which has been issued to include requirements for the new GNSS/AIS enabled EPIRBs in accordance with the revised performance standards for float-free Emergency Position-Indicating Radio Beacons (EPIRBs) operating on 406 MHz (Resolution MSC.471(101))

Shore-based maintenance

In addition to the annual test on boards, shore-based maintenance of satellites EPIRBs is required on and after 1 July 2006.

Shore-based maintenance shall be performed by an approved shore-based maintenance (SBM) provider at intervals not exceeding five years.

EPIRBs in compliance with resolution MSC.471(101) shall comply with revised Guidelines for shore-based maintenance of emergency position-indicating radio beacons (EPIRBs), MSC.1/Circ.1039/Rev.1. However, EPIRBs in compliance with resolution A.810(19), as amended by resolutions MSC.56(66) and MSC.120(74), shall comply with the Guidelines for shore-based maintenance of satellite EPIRBs, MSC/Circ.1039.

Shore-based maintenance providers

Shore-based maintenance shall be performed either by approved radio companies which meet the condition for a shore-based maintenance (SBM) provider or by satellite EPIRBs manufacturers or manufacturers’ representative

On completion of the survey, the shore-based maintenance provider shall issue a “Shore based Maintenance report” to be made available to the surveyor

Refer to Circular MSC.1/Circ.1039 Guidelines for shore-based maintenance of satellite EPIRBs (See the attached file “MSC.1-Circ.1039”) ”) and Circular MSC.1/Circ.1039/Rev.1 revised Guidelines for shore-based maintenance of emergency position-indicating radio beacons (EPIRBs) (See the attached file “MSC.1-Circ.1039-Rev.1”) as appropriate

Marking of EPIRBs

The EPIRB shall be provided with a label or labels containing the following information at least in English:

• Type designation, serial number, type of battery specified.

• The expiry date of the battery.

• Adequate instruction to enable manual activation, deactivation and self test.

• A warning to the effect that the satellite EPIRB shall not be operated except in an emergency.

• Ship name / Call sign / MMSI N°.

• Class of the EPIRB.

• Transmitted identification code.

• The compass-safe distance.

• The date when the next shore-based maintenance is due.

In addition for EU vessels :

• Conformity mark (Wheel mark) and number of the Notified Body undertaking surveillance module .

• Last two digits of year mark affixed.

VHF Emergency Positions Indicating Radio Beacon (VHF EPIRB) - GMDSS (Old SOLAS, Reg.IV/ 8.3)

In relation to the Modernization of GMDSS which enters into force on 1January 2024, VHF-EPIRB is no longer accepted in lieu of satellite EPIRB for sea area A1. Ships operating exclusively in sea area A1 should replace VHF-EPIRB with satellite-EPIRB.

Two-way VHF radio-telephone apparatus (GMDSS -SOLAS 1974, Reg.IV/7)

At least, 3 apparatuses (2 on every cargo ship of 300 grt and upwards but less than 500) must have been fitted on ships built on/after 1 February 1992 and must be fitted on every ship from 1 February 1995 (with possible exception)

In relation to the Modernization of GMDSS which enters into force on 1January 2024, the provisions in SOLAS regulation III/6 related to two-way VHF radiotelephone apparatus and search and rescue locating devices (SART) have been relocated under SOLAS IV

Two-way VHF radio-telephone apparatuses are annually surveyed at the periodical radio survey.

Radar SARTs and AIS-SARTs (SOLAS regulation IV/7.5)

At least, one radar transponder shall be carried on each side of every cargo ship of 500 grt and over. At least, one radar transponder shall be carried on every cargo ship of 300 grt and over, but less than 500.

In relation to the Modernization of GMDSS which enters into force on 1January 2024, the provisions in SOLAS regulation III/6 related to two-way VHF radiotelephone apparatus and search and rescue locating devices (SART) have been relocated under SOLAS IV.

The search and rescue transponders or transmitters (radar SARTs or AIS-SARTs) should be placed in brackets on both sides of the ship and preferably visible from the navigation bridge. It should be easy to bring the radar SART or AIS-SART to the lifeboats or life-rafts. A visible location inside the navigation bridge, close to the outer doors, is recommended.Alternatively, one radar SART or AIS-SART should be placed in bracket in each survival craft (normally covered lifeboats) if such location permits rapidly replacing of the radar SART or AIS-SART into any survival crafts which may be used in emergency situations.

MSI and SAR related information receiver(s) (SOLAS Reg.IV/7.1.4)

The printer or display for an MSI and SAR related information receiver should be located on the navigation bridge. As mandatory equipment in the GMDSS, these receivers should also, as a general rule and in the same way as required for other permanent installed equipment, have their own permanent installed power supplies with fuse circuits/fuses. The mandatory requirement for an MSI and SAR related information receiver may be combined with RMSS equipment. It is recommended that a dedicated MSI and SAR related information receiver is used, enabling continuous reception of MSI messages independent of whether the RMSS equipment is being used or not.Refer to the attached circular MSC.1/Circ.1645

GMDSS equipment and governing IMO Resolutions

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GMDSS. Radio-communication equipment to be fitted on board ships (COMSAR.1/Circ.32/Rev.3)

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Appendix — Radio communication equipment on ships engaged on voyages in sea areas A2 and A3

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Refer to the attached file ”Application of IACS REC 195”