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Regulation overview

However, the basics of regulation were set down much earlier than that and still form the core framework of modern regulations. GMDSS is a subject on its own and is covered elsewhere in this guide.

Communications equipment and services on board vessels are internationally regulated under three separate areas: Carriage requirements are 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 operator certification covered by STCW. To these can be added any regulation imposed by the flag state or restrictions imposed by a port state when a vessel is in territorial waters.

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, GPS, 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.

ITU’s rules are freely accessible from its 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.

It should be mentioned that SOLAS also regulates some other forms of communication such as light and sound signals.

SOLAS carriage requirements

The carriage requirements are in force as far as SOLAS is concerned purely for safety, search and rescue and security requirements. These will cover voice and electronic communications plus the use of lights, sounds and pyrotechnics.

The commercial aspect of communications is for the shipowner to decide, providing the rules for licensing and accounting are complied with. It should be noted that seafarers do not have an automatic right to have access to communications, which remains at the shipowner’s discretion and company welfare philosophy.

Radio station licence

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 issued with a Ship Radio licence by its flag state. This 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) that 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 licence will be issued by the same body as other ship certificates and documents.

When the licence is issued it will include 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 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; and
  • 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-held 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.

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