Extension of the deadlines for conformance to MSC.511(105), MSC.512(105), and MSC.513(105) as well as MSC.1/Circ.1460
This document provides information about the recent decisions made at IMO in relation to conformance of the radio equipment for VHF, MF/HF and Inmarsat-C to the revised performance standards as well as updating of the VHF installations to meet the latest and in- force channel arrangement contained in appendix 18 to ITU Radio Regulations.
IMO, at MSC 107 (107th session of Maritime Safety Committee), which took place from 31 May to 9 June of 2023 at the IMO headquarters, London, the UK:
1.Agreed to extend the deadline for new installation for compliance with the revised performance standards for VHF radio installation with DSC (MSC.511(105)), MF/HF radio installation with DSC (MSC.512(105)) and Inmarsat-C ship earth station (MSC.513(105)) for four years, i.e., those installed on and after 1 January 2028.
2. Also, the Committee agreed to extend the deadline for updating of VHF radiocommunication equipment already installed onboard to meet the latest applicable ITU channel arrangement for maritime VHF band until the first radio survey after 1 January 2028* ¹ and approved the related new 4th revision of the MSC Circular (MSC.1/Circ.1460 Rev.4).
*1 This means that retrofit of non-compliant old radios would be necessary.
Discussion around modernization of the GMDSS has been in progress for more than ten years, and amendment to SOLAS as well as pertinent instruments, including revised performance standards and guidelines, have been adopted at MSC 105 in April 2022 with the entry into force date set at 1 January 2024 for new installations.
IMO MSC circular MSC.1/Circ.1460 rev.3 stipulates the necessity of update of the VHF radio installation already onboard to meet the latest channel arrangement for maritime VHF band, contained in appendix 18 to the ITU Radio Regulations (the RR). ITU World Radiocommunication Conference (WRC) made extensive changes to appendix 18 of the RR in 2012, 2015 and 2019. As the performance standards for shipborne VHF radio installations capable of communication and digital selective calling requires that VHF radio installation equipment should comply with the RR, the requirements for update of the VHF radio installation are retrospective in nature affecting the already installed equipment on top of newly installed equipment.
IMO NCSR 10 Discussion and subsequent adoption at MSC 107
IMO Sub-Committee on Navigation and Communications and Search and Rescue (NCSR) at its tenth session (NCSR 10) received an input from IEC and CIRM calling for two-year extension of the deadlines for conformance of new installations to the revised performance standards for VHF (MSC.511(105)) and MF/HF (MSC.512(105)), due largely to unavailability of the technical specifications within the ITU documents (the RR and ITU-R recommendations) necessary for development of the testing standards for the new requirements contained within the revised performance standards. The input was received with great sympathy by a number of IMO member states that pointed out that Inmarsat-C was also in the similar situation and that, taking into account the necessary transposition period by the member states after the testing standards are made available, the time frame for extension should carefully considered. Subsequently, the Sub-Committee agreed to propose to the MSC 107 that the four-year extension would be necessary for conformance of the new installations to the revised performance standards for VHF radio installation with DSC (MSC.511(105)), MF/HF radio installation with DSC (MSC.512(105)) and Inmarsat-C ship earth station (MSC.513(105) to which MSC 107 agreed.
NCSR 10 also noted a separate input from ICS (International Chamber of Shipping) had been submitted to MSC 107, asking for consideration for possible extension of the deadline specified in MSC.1/Circ.1460 Rev.3. This proposal was related to compliance of the radio installations already installed onboard. The request for the extension stemmed from the difficulty experienced by the shipping companies to obtain the necessary radio equipment due to unavailability of the parts and components. The Sub-Committee agreed to inform MSC of their recommended way forward on this subject matter, i.e., four-year extension of the deadline for updating of non-compliant onboard VHF installation to which MSC 107 agreed.
Implication of the decisions made at MSC 107
The decision on extension of deadline for the application of the revised performance standards for VHF, MF/HF and Inmarsat-C implies that it is allowed for continued installation of new radio equipment in question complying with the existing performance standards, i.e., A.803(19) for VHF, A.806(19) for MF/HF and A.807(19) for Inmarsat-C. It is important to note that this extension only applies to the conformance to the revised performance standards of the given radio equipment and that entry into force of SOLAS amendment in relation to modernization of the GMDSS is unchanged, i.e., 1 January 2024.
Also, it should be noted that the amended SOLAS chapter IV regulation 14 footnote 17 specifies that compliance with the presentation standards MSC.191(79) as amended by SC.466(101) is required for the GMDSS radio communication equipment as part of the general requirements. Taking into account the presentation standards have hitherto not been mandatory for any of the GMDSS radio installations, all the GMDSS radio installations are required to undergo testing in accordance with the presentation standards, i.e., MSC.191(79) as amended by MSC.466(101) and pertinent testing standards IEC 62288 Ed.3 as applicable before the end of 2023. This means that the radio equipment in question, i.e., FM-8900S, FS- xx75 and FELCOM18, if installed on and after 1 January 2024, are required to be certified in accordance with the presentation standards, notwithstanding of the four-year extension of the deadline for conformance to their respective revised performance standards.
The decision on extension of the deadline for MSC.1/Circ.1460 implies that the currently installed VHF radio installations can be continually used until the first radio survey after 1 January 2028, and this applies to both FM-8800S/D and FM-8900S. However, upon the first radio survey after 1 January 2028, the already installed FM-8800S/D shall be replaced by the FM-8900S and the already installed FM-8900S shall undergo SW update to the version that contains the latest channel arrangement in accordance with the RR that is in force (currently in force version of the RR is WRC-19, hence SW version 4.xx and onward) and is compliant with IEC 62288 Ed.3.