Safety and commercial needs under different rules
In an era of almost instantaneous communications, few modern ship operators or others connected with shipping will fully appreciate the limitations that existed even 20 years ago before GMDSS altered forever the field of marine communications. However, the basics of regulation were set down much earlier than that and still form the core framework of modern regulations.
Communications equipment and services on board vessels are internationally regulated under three separate areas; Carriage requirements covered by SOLAS; The regulations governing the use of maritime radio as detailed in the International Radio Regulations, set by the International Telecommunication Union (ITU) and finally operator certification covered by STCW. To these can also be added any regulation imposed by the flag state or restrictions imposed by a port state when a vessel is in territorial waters.
The carriage requirements are in force as far as SOLAS is concerned purely for safety and search and rescue and security requirements. The commercial aspect of communications is for the shipowner to decide, providing the rules for licensing and accounting are complied with. There is no given right for seafarers to have access to communications which remain at the shipowners’ discretion and company welfare philosophy.
There is a very good reason why an international body such as the ITU is needed to govern the use of communications equipment. The spectrum in which radio communications operate is limited and with more and more demands made on it by increasing use of technologies such as mobile telephones, wi-fi, radio-controlled devices and GPS as well as radio and TV the possibility for interference grows as well.
Interference can be a nuisance when it affects personal enjoyment of unessential services but if the system affected is one that is vital for safety or needed to operate production or control processes then interference can have a much more damaging effect. For this reason, the frequencies on which different types of equipment are permitted to operate have been subject to international agreement managed by the ITU.
The rules of the ITU are freely accessible from the organization’s website but are extensive and run into several volumes and thousands of pages. It is also not necessary to be fully conversant with all the rules but only those aspects that affect shipping such as licensing, accounting and use. The main regulations affecting shipping can be found in Volume I of the Radio Regulations. Chapter VII covers GMDSS and Chapter IX most other aspects of marine communications including licensing and operator certificate requirements. The latter are also covered in the STCW requirements for certain classes of navigating and deck officers.
Radio Station Licensing
Under SOLAS all ships above 300gt are obliged to carry radio and other communications equipment. The exact carriage requirements vary but are related to GMDSS. Before a ship can operate its radio equipment it must be licensed by the flag state. A Ship Radio licence is required even if the transmitting equipment is not in constant use, or if it is used only for distress purposes. The rules covering licences are contained within Articles 18 and 19 of the ITU’s Radio Regulations.
The issuing authority for ship’s radio licences is the flag state except under certain extraordinary circumstances when an interim certificate can be issued by a port state. Very often the licensing authority for ships is different and separate from any of the other maritime authorities. In the UK for example, it is the Office of Communications (Ofcom) which is responsible for the effective management of the civil radio spectrum and in the US it is the Federal Communications Commission (FCC). In most other countries similar arrangements exist although in many of the open registries, the license will be issued by the same body as other ships certificates and documents.
When the license is issued it will also give the call sign which is the unique identifier for the ship. The call sign and other details of vessels supplied by the licensing authority such as gross tonnage, vessel type and how many people it can carry will also be given to the ITU for inclusion in the list of call signs that all ships are obliged to carry. This information could be vital as it gives some information to those rendering assistance to a ship in distress.
The List of Ship Stations and Maritime Mobile Service Identity Assignments (List V) is a service publication prepared and issued annually in accordance with provision no. 20.8 of the Radio Regulations (RR). As stipulated in Appendix 16 to the RR, this List shall be provided to all ship stations for which a GMDSS installation is required by international agreement.
As well as its call sign, a vessel fitted with Digital Selective Calling (DSC) and/or (Satellite) Ship Earth Station (SES) equipment will also be allocated a unique Maritime Mobile Service Identity (MMSI) number.
The Ship Radio licence allows the licensee to install and if the relevant Maritime Radio Operators’ Certificate of Competence and Authority to Operate is held, use any combination of maritime radio equipment on the specified vessel. The equipment covered includes:-
- Digital Selective Calling (DSC) equipment associated with the Global Maritime Distress & Safety System (GMDSS);
- MF, HF, VHF equipment;
- Satellite communications equipment (Ship Earth Stations);
- RADAR; Search and Rescue Radar Transponders (SARTs);
- Low powered, on board maritime UHF communications equipment;
- UHF On board repeater stations;
- Aeronautical Search and Rescue equipment;
- Emergency Position Indicating Radio Beacons (EPIRBs) and Personal Locator Beacons (PLBs)
As regards VHF and UHF equipment, a licence usually allows for an unlimited number of hand portable sets for use on board.
Whilst it is not necessary to hold a Certificate of Competence in order to obtain a Ship Radio Licence or a Ship Portable Radio Licence, a maritime radio may be operated only by or under the direct personal supervision of a holder of the appropriate Certificate of Competence and Authority to Operate. This is done to maintain operational standards and ensure knowledge of current distress, emergency and safety procedures. Obviously in certain emergencies where all operators are incapacitated this provision is overridden.
The minimum Certificate of Competence that is required for use of a ship radio is the Short-Range Certificate. This certificate covers use of both standard VHF and VHF/DSC equipment under GMDSS in sea area A1.
Accounts and charges
Although emergency communications are intended to be free of charge, ships are obliged to pay for any commercial traffic. In accordance with the ITU radio regulations, it is necessary for each ship station to have an internationally recognised accounting authority. Maritime Radio Accounting Authorities (MRAAs) are organisations – generally commercial companies – recognised and registered by flag states. Their purpose is to facilitate the effective collection and distribution of telecommunications charges for non-emergency radio telephone, telex and other calls from ships into the international subscriber networks.
Each MRAA will be given a unique Accounting Authority Identification Code (AAIC). The AAIC consists of a two letter country code followed by a two digit numeric code denoting the particular Accounting Authority. The basic role, responsibilities and duties of MRAAs are governed by the ITU and are set down in Article 66 of the Radio Regulations and Appendix 2 of the International Telecommunication Regulations.
Recommendation D90 of the ITU Telecommunication Standardisation Sector gives directions on charging, accounting and refunds in the Maritime Mobile and Maritime Mobile-Satellite Services. The MRAAs collate the charges from different service providers and network operators and pass them on to license holders for settlement via the MRAA. All maritime communications traffic must be prefixed with the officially recognized AAIC for the accounting authority responsible for the settlement of their radio accounts.
Safety Radio Certificate
As well as a license, all ships are obliged under SOLAS Chapter I Regulation 9 to have a Safety Radio certificate. This certificate is one of the safety certificates normally required for a ship to produce when requesting customs clearance to depart a port. The radio installations of passenger ships are included in the Passenger Ship Certificate and for cargo ships the installation is covered by the Cargo Ship Safety Radio certificate.
The Passenger Ship Certificate is issued in accordance with SOLAS Chapter 1-B regulation 7 and is a single catch-all certificate covering construction, radio and safety equipment that is renewable annually. For cargo ships, separate certificates are issued with longer periods of validity. A cargo ship certificate is only issued after a survey carried out in accordance with SOLAS Chapter I-B Regulation 9 which reads:
Regulation 9 - Surveys of radio installations of cargo ships
(a) The radio installations, including those used in life-saving appliances, of cargo ships to which chapters III and IV apply shall be subject to the surveys specified below:
(i) an initial survey before the ship is put in service;
(ii) a renewal survey at intervals specified by the Administration but not exceeding five years, except where regulation 14(b), (e), (f) and (g) is applicable;
(iii) a periodical survey within three months before or after each anniversary date of the Cargo Ship Safety Radio Certificate;
(iv) an additional survey as prescribed for passenger ships in regulation 7(b)(iii).
(b) The surveys referred to in paragraph (a) shall be carried out as follows:
(i) the initial survey shall include a complete inspection of the radio installations of cargo ships, including those used in life-saving appliances, to ensure that they comply with the requirements of the present regulations;
(ii) the renewal and periodical surveys shall include an inspection of the radio installations of cargo ships, including those used in life-saving appliances, to ensure that they comply with the requirements of the present regulations.
(c) The periodical surveys referred to in paragraph (a)(iii) shall be endorsed on the Cargo Ship Safety Radio Certificate.
Certification of operators is a flag state matter but different categories of operator are recognised and the requirements for each contained in article 47 of the ITU Radio Regulations. Some of the categories in the ITU regulations cover non-SOLAS vessels and only four relate specifically to most commercial ships. These four categories of certificates which are also part of GMDSS rules are shown in descending order of requirements are:-
- First-class radio electronic certificate.
- Second-class radio electronic certificate.
- General operator’s certificate (GOC).
- Restricted operator’s certificate (ROC).
An operator meeting the requirements of a certificate automatically meets all of the requirements of lower order certificates. Holders of the first two certificates are capable of both operational and maintenance/repair roles while those holding the last two certificate types are considered as operators only. Most ships must have two or more crew holding GOCs with the ROCs only recognised for ships limited to coastal service.
Courses leading to certification are offered at many marine schools and other training establishments but not all will be recognised by all flag states. Crewing departments should ascertain whether a certificate will be recognised before allocating crew to ships and seafarers will also need to check if a certificate from a training establishment is recognised by the state issuing his certificate of competency.