The regulation around navigating the seas

Malcolm Latarche
Malcolm Latarche

12 July 2017


Navigation has been part of shipping and trading for millennia and although the technology available today allows position fixing and passage planning to be done with an ease that would leave past generations gasping, the older skills are still very relevant.

Regulation as to the abilities of navigators and the equipment needed on board have evolved by flag states over centuries. Today most of the regulations concerned with navigation on board vessels are found almost entirely within the texts of STCW and SOLAS but there are both flag and port state elements that will also need to be investigated.

There are very few chapters of SOLAS that do not mention the bridge in one way or another even if it is just to require that an alarm or status indicator for a piece of equipment is to be provided. For the majority of systems and equipment as well as for standards for bridge layout, it is Chapters IV and V that are the main source of regulation. Chapter IV of SOLAS covers radio communications and equipment and it is here that the requirements for GMDSS equipment are to be found.

Navigation as a subject is not covered by SOLAS until Chapter V and then most of the regulations are concerned with matters such as weather information, ice patrols, bridge layout, navigation warnings, hydrographic services, life-saving signals and ancillary equipment.

Bridge Layout Regulation

The command and control centre of a ship has shifted position over time as ship design and equipment has evolved. There is currently an element of regulation connected with bridge design mostly in regard to visibility requirements but there is every chance that some future regulation may be on the cards in this area. Chapter V, Regulation 15 of SOLAS is titled Principles relating to bridge design, design and arrangement of navigational systems and equipment and bridge procedures and requires bridge designers to make decisions with certain aims in mind.

Although there are guidelines published by the IMO and classification societies, there are few prescriptions to be observed. Regulation 15 says:

`All decisions which are made for the purpose of applying the requirements of regulations 19(LRIT), 22(Visibility), 24(Heading & Track control systems), 25(steering gear), 27(Charts & Publications) and 28(Logs) and which affect bridge design, the design and arrangement of navigational systems and equipment on the bridge and bridge procedures§ shall be taken with the aim of:`

  1. facilitating the tasks to be performed by the bridge team and the pilot in making full appraisal of the situation and in navigating the ship safely under all operational conditions;
  2. promoting effective and safe bridge resource management;
  3. enabling the bridge team and the pilot to have convenient and continuous access to essential information which is presented in a clear and unambiguous manner, using standardized symbols and coding systems for controls and displays;
  4. indicating the operational status of automated functions and integrated components, systems and/ or sub-systems;
  5. allowing for expeditious, continuous and effective information processing and decision-making by the bridge team and the pilot;
  6. preventing or minimizing excessive or unnecessary work and any conditions or distractions on the bridge which may cause fatigue or interfere with the vigilance of the bridge team and the pilot; and
  7. minimizing the risk of human error and detecting such error, if it occurs, through monitoring and alarm systems, in time for the bridge team and the pilot to take appropriate action.
 *`§ Refer to Guidelines on ergonomic criteria for bridge equipment and layout (MSC/Circ.982) and Guidelines for bridge equipment and systems, their arrangement and integration (BES) (SN.1/Circ.288) and, for INS, to Recommendation on performance standards for an integrated navigational system (resolution MSC.86(70), annex 3, as amended).`

The question of ergonomics is explored further in a later chapter but the circular MSC/Circ.982 referred to in the footnote to Regulation 15 is a 33-page guideline document that covers a very wide ranging number of topics from basic layout through to controls and display requirements.

Within the guidelines, a large section is devoted to the subject of visibility but while the guidance here is voluntary, Regulation 22 of Chapter V of SOLAS also contains a number of mandatory conditions that must be met with regard to the windows and visibility from the bridge for vessels built since 1998.

Equipment

In the past most regulation of bridge equipment was prescriptive laying down performance standards but recently goal based standards have become more common. The exact requirements for individual ships will vary depending upon ship type, size and age. In the case of the communications equipment that must be carried under the Global Maritime Distress & Safety System (GMDSS), the area in which the ship operates is also a deciding factor.

In addition to the international requirements, flag states are always at liberty to impose additional requirements for vessels on their registry. Such rules should be communicated to ships by the appropriate government department usually by way of Merchant Shipping Notices. Ships joining a flag will normally be subjected to some form of inspection and any deficiencies should be picked up by the surveyor and advised to the operator for immediate rectification.

The Merchant Shipping Notices of most flag states are relatively easy to locate but while some countries issue very few, others seem to legislate and advise on a vast number of topics. In the latter case where rules change and notices are superseded regularly, keeping up to date requires careful attention to detail. SOLAS changes are more easily followed but care needs to be taken to ensure that alternatives allowed in SOLAS are also accepted by flag states.

The carriage requirements for the key navigation systems such as radar, compasses and tracking systems do not appear until regulation 19 where they are laid out in a way that deals firstly with all ships and then the additional requirements that come with increased ship size as measured in gross tonnage. The divisions of ship type and size according to Chapter V Regulation 19 paragraph 2 are:

  • 2.1 All ships, irrespective of size
  • 2.2 All ships of 150 gross tonnage and upwards and passenger ships irrespective of size
  • 2.3 All ships of 300 gross tonnage and upwards and passenger ships irrespective of size
  • 2.4 All ships of 300 gross tonnage and upwards engaged on international voyages and cargo ships of 500 gross tonnage and upwards not engaged on international voyages and passenger ships irrespective of size. This section only covers AIS
  • 2.5 All ships of 500 gross tonnage and upwards (2.6 details some duplication requirements)
  • 2.7 All ships of 3,000 gross tonnage and upwards
  • 2.8 All ships of 10,000 gross tonnage and upwards
  • 2.9 All ships of 50,000 gross tonnage and upwards.

In some instance alternative ‘other means’ are permitted for certain requirements. When ‘other means’ are permitted under this regulation, they must be approved by the Administration (Flag state) in accordance with regulation 18. The navigational equipment and systems referred to in regulation 19 shall be so installed, tested and maintained as to minimise malfunction.

Regulation 19 2.10 covers the Electronic Chart Display & Information Systems (ECDIS) carriage requirements and details the various dates of the rollout programme. The regulations around ECDIS are covered in depth later as they represent a step change in navigation practices.

Under the SOLAS regulations, navigational equipment and systems offering alternative modes of operation shall indicate the actual mode of use. Integrated bridge systems shall be so arranged that failure of one subsystem is brought to the immediate attention of the officer in charge of the navigational watch by audible and visual alarms and does not cause failure to any other sub-system. In case of failure in one part of an integrated navigational system, it shall be possible to operate each other individual item of equipment or part of the system separately.

Performance standards for the various systems are laid out in numerous IMO documents are subject to changes from time to time. When the performance standards do change, it is not normally necessary to replace equipment fitted prior to the change of date but in some cases, ECDIS is a good example, a change in the performance standards may necessitate an adaption to the equipment fitted. When a new system or piece of equipment is added to the mandatory carriage requirements because of new IMO regulations, there is often a rollout programme which will see different ship types and sizes affected over a period of time.

E-navigation is a new concept that has been permitted by modern technology. Although details are still being worked, it could be said that it may result in something akin to an air traffic control network. In the IMO’s own words its work is *‘to develop a strategic vision for e-navigation, to integrate existing and new navigational tools, in particular electronic tools, in an all-embracing system that will contribute to enhanced navigational safety (with all the positive repercussions this will have on maritime safety overall and environmental protection) while simultaneously reducing the burden on the navigator’*

The IMO says that as the basic technology for such an innovative step is already available, the challenge lies in ensuring the availability of all the other components of the system, including electronic navigational charts (Now in progress with the mandatory carriage of ECDIS), and in using it effectively in order to simplify, to the benefit of the mariner, the display of the occasional local navigational environment.

E-navigation would thus incorporate new technologies in a structured way and ensure that their use is compliant with the various navigational communication technologies and services that are already available, providing an overarching, accurate, secure and cost-effective system with the potential to provide global coverage for ships of all sizes.

What the IMO and other proponents of e-navigation appear to have overlooked is that the ECDIS regulations apply only to passenger ships over 500gt and cargo vessels above 3,000gt. Most ports and navigable waters will have vessels below those sizes operating along with ECDIS equipped ships.

When GMDSS replaced the traditional communication arrangements on ships in the late 1990s and into the opening years of the 21st Century, it was controversial because it brought about the demise of the position of Radio Officer. It also heralded the era of universal satellite communications on ships and the long held monopoly of Inmarsat – then an international not for profit organisation – in safety communications.

Today there are rival satellite service providers but these currently complement rather than replace the need to carry an Inmarsat terminal on board. This is a situation that is destined to change as competition is introduced under plans to open up the GMDSS. There is a strong likelihood of Iridium being the first satellite operator being accepted as an alternative GMDSS service provider.

As things stand the regulations already allow for some flexibility in the equipment required on board providing there is on-board capability to repair equipment or a contract is in place with a competent service provider. Some of the equipment required under GMDSS can be seen in other articles.

After the arrival of GMDSS, the next items of equipment to be made mandatory under SOLAS were a voyage data recorder (VDR) and automatic identification system (AIS). The VDR is the maritime equivalent of an aircraft black box even though it is usually red or orange in colour.

VDRs were made mandatory in 2002 for new vessels above 3,000gt and by 2010 for vessels above 3,000gt existing prior to 2002. For some of the older vessels, an option to install a simplified VDR or S-VDR was given because of the incompatibility of the systems needing to be connected to it.

The initial performance standards for VDRs date back to 1997 but since then both AIS and ECDIS have become mandatory equipment on most ships, the latter though is still in a roll out programme, now almost complete. AIS was added to the list of equipment to be recorded in 2004 and in 2006 standards for software download of data were introduced to come into effect in 2008. New performance standards for VDRs were adopted by the IMO in 2012 and apply to all new and replacement VDRs fitted since 1 July 2014.

In the main, the newer standards are more concerned with the system data that must be recorded and the means of recording it. They added some new requirements that meant changes to some of the existing models sold by manufacturers, but there was no need for ships to change equipment already on board unless a replacement was necessary for some other reason.

Another item of bridge equipment is also currently the subject of a roll out programme for mandatory installation. The need for Bridge Navigation Watch Alert System) BNWAS has come about because of the number of collision and grounding incidents involving ships with one man operated bridges. The systems are intended to monitor activity – or rather lack of activity – on the bridge and to sound an alarm if regular prompts are not acknowledged by the watchkeeper.

The requirement for BNWAS is contained in SOLAS Chapter V Reg.19 2.2.3 as amended by resolution MSC.282(86), adopted in 2009. The original rollout programme is as follows:

  • Cargo ships of 150gt and upwards and passenger ships irrespective of size constructed on or after 1 July 2011;
  • Passenger ships irrespective of size constructed before 1 July 2011 not later than the first survey 1 July 2012
  • Cargo ships of 3,000gt and upwards constructed before 1 July 2011, not later than the first survey after 1 July 2012
  • Cargo ships of 500gt and upwards but less than 3,000gt constructed before 1 July 2011, not later than the first survey after 1 July 2013; and Cargo ships of 150gt and upwards but less than 500gt constructed before 1 July 2011, not later than the first survey after 1 July 2014.

Because of a problem with the initial wording of the regulation some flag states may not have interpreted the rules as they were intended, as a consequence a new rollout has been put in place for ships built before 2002 that had not installed a compliant system. This new programme follows the same sequence as the initial version but finalises in 2018.

There are performance standards for BNWAS but for ships which fitted systems voluntarily some dispensations are permitted if the system is not fully in accordance with the IMO standard.

Often confused with BNWAS but actually quite different are Bridge Alarm (or alert) Management Systems (BAMS). These are not mandatory under SOLAS but the IMO does recommend that flag states promote their installation and use on ships. BAMS are supposed to improve presentation and handling of alerts with a view to aiding the bridge team to identify and prioritise problems to maintain the safe operation of the ship.

BAMS should conform to the performance requirements stated in the annex to IMO Resolution MSC.302(87) but beyond that a free hand is given. Some systems that are on the market are stand alone, others are part of an integrated bridge system and at least one is combined with a BNWAS.