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NATIONAL GMDSS IMPLEMENTATION TASK FORCE

Captain Jack Fuechsel
Executive Director
7425 Elgar Street
Springfield, VA 22151

26 August 1997

RADM Robert C. North
Assistant Commandant for Maritime Safety and Environmental Protection
USCG Headquarters
Washington DC 20593

Dear Admiral North,

The National GMDSS Implementation Task Force was chartered by the U.S. Coast Guard to supplement government functions in expediting the implementation of the Global Maritime Distress and Safety System (GMDSS) now being introduced by the International Maritime Organization.

The Task Force membership is broad-based including government authorities, commercial vessel owners and operators, training institutions, service agents, manufacturers and maritime labor organizations. Previously the Task Force has forwarded recommendations regarding proposed training standards for GMDSS radio operators and recommended conditions for issuing STCW 95 GMDSS endorsements to officers.

The purpose of this letter is to transmit further recommendations specifically for expanding the scope of the Coast Guard's Port State Control (PSC) examination to include GMDSS compliance. The examination booklets presently in use include radio communications factors which need to be updated for GMDSS. It is also noted that several other nations have begun to conduct Port State inspections for GMDSS factors and some of the detentions they have reported have been for GMDSS violations. As you are no doubt aware, there is a global problem of excessive false alerts in all GMDSS systems which is seriously impacting the ability of rescue forces to respond. Further, enforcement of many of the GMDSS rules such as ensuring that all GMDSS radio equipment is operational before sailing, is typically left up to the ship and the Task Force believes that some ships may be sailing in violation of these rules.

The Task Force is mindful that the Coast Guard might find it difficult to mount an aggressive Port State GMDSS examination program which would significantly increase the current workload. We therefore have prepared our recommendation to fit within the already existing targeting and examination procedures already used in the Coast Guard Port State Control Program.

The Task Force has approved the GMDSS check list items attached to this letter and recommends that they be included in the Foreign Vessel Examination Book. The Task Force considers that the general examination factors can be accomplished by PSC inspectors without any specialized training. The items listed under the expanded examination probably require the use of inspectors with GMDSS background and it is recommended that a procedure be developed for utilizing appropriately trained personnel for that purpose in those few cases when preliminary screening or input from SAR or communications resources identifies a vessel which is probably deficient in GMDSS standards.

This recommendation for a Coast Guard GMDSS Port State Control examination was approved by the Task Force at its meeting on 24 July 1997 subject to final editing by the GMDSS Training Task Group which was completed 21 August 1997. Members of the Task Force will, of course, be available to assist your staff as desired in further development of the proposal.

Sincerely,

JACK FUECHSEL

Enclosure: Candidate items for inclusion in the Foreign Vessel Examination Book

Attachment to Task Force letter of 26 August to RADM North

General examination items for inclusion in the Foreign Vessel Examination Book

    1. Check for valid IMO Safety Certificate issued by country of registry

    2. Record assigned MMSI number for GMDSS Digital Selective Calling identity

    3. Record Inmarsat identification number for each GMDSS systems installed

    4. Check availability of at least one GMDSS radio operator holding the appropriate certificate issued in accordance with the International Radio Regulations

    5. Check that all deck officers have an STCW 95 GMDSS endorsement (after 2002)

    6. Check whether maintenance is by on-board maintainer or limited equipment duplication If on-board maintainer, check for test equipment and certification of maintainer If duplication utilized, check that duplicated equipment has power & antenna   

    7. Check installation of 406 Mhz Satellite EPIRB (record dates of last battery change and check of hydrostatic release mechanism)

    8. Spot check at least one GMDSS radio system to show that it operates properly

Expanded examination items for inclusion in the Foreign Vessel Examination

Book:

    1. Check that required GMDSS systems are on board and that operator demonstrates general competency in GMDSS equipment operation

                   VHF-DSC (2 sets required for duplication)

                   MF-DSC

                   HF-DSC (if HF option chosen)

                   Inmarsat A, B, or C (if satellite option chosen)

                   Inmarsat-C SafetyNET broadcast receiver (or HF alternative if Flag State permits)

                   NAVTEX coastal broadcast receiver

                  Additional HF or Satellite system (2 separate systems required for duplication)

                   Handheld VHF portables for survival craft and on-board use

                   Radar transponders (SART) for survival craft use

                   Check that both Radars are operational (an IMO non-GMDSS requirement)

    2. Examine radio logs for operational checks and record of safety events

    3. Check records for receipt of Marine Safety Information broadcasts

    4. Check operators set up of SafetyNET and DSC to receive geographic alerts

    5. Check Main and Reserve power arrangements for proper functional operation in accordance with requirements of the International Radio Regulations

    6. If notified that ship has been barred by Inmarsat, check GMDSS status of SES

    7. Does vessel have GPS or alternative? if so, connected to alerting systems? (after 2002)

Reasons for expanding a PSC examination with a focus on GMDSS compliance:

    a. Ship has originated false GMDSS alerts

    b. Ships has sent alerts with incorrect position information

    c. Ship has sent alerts containing incorrect identity information

    d. Ship has failed to respond when called by the RCC for SAR assistance

    e. Ship is suspected of having sailed with inoperative GMDSS equipment

    f. Ship has failed to conduct telephony communications with an operator adequately competent in the English language (after 2002)

    g. Ship has been barred by Inmarsat (if the SES is a GMDSS installation)

    h. Ship has been detained by other Administrations for GMDSS violations

    i. Ship is from a nation known to have numerous GMDSS violations

    j. Ship is owned or operated by a company known to have numerous GMDSS violations