Iridium installations for GMDSS configurations
Resolution MSC.436(99) which is effective from January 1, 2020, introduces the definition of 'recognized mobile satellite service'. In the associated requirements of this chapter, the term 'Inmarsat ship earth station' has therefore been replaced by 'recognized mobile satellite service'.
With regard to the reception of maritime safety information as defined in SOLAS IV/2.1.9, SOLAS regulation IV/7 (Radio equipment – General), sub 1.5 requires the following:
“Every ship shall be provided with a radio facility for reception of maritime safety information by a recognized mobile satellite service enhanced group calling system if the ship is engaged in voyages in sea area A1, or A2 or A3 but in which an international NAVTEX service is not provided…”.
Every ship must be able to receive MSI. This is possible (along the coast) by NAVTEX and outside NAVTEX range the reception of MSI is secured by a recognized mobile satellite service EGC.
For the reception of EGC messages via a recognized mobile satellite service, the world is divided into 21 areas. The NAVAREA section is available to receive navigational warnings, including SAR messages and for the reception of weather reports the METAREA section is available. These areas are practically the same, but the information comes to the coordinator through different channels.
Inmarsat has the 'SafetyNET' system for EGC and this information comes on board via the Inmarsat-C installation and has the full coverage for the GMDSS A3 sea area.
Iridium has set up the 'SafetyCAST' system for the reception of MSI. However, the “SafetyCAST” system does not yet have worldwide coverage. On Iridium SafetyCast Implementation Status | IHO the current status of the different NAVAREAS and METAREAS can be verified.
An Iridium GMDSS system which has obtained an MED/wheelmark certificate indicating that it complies with MSC.434(98) – “Performance standards for a ship earth station for use in the GMDSS,” may be placed on board ships under the Dutch flag.
However, as mentioned above, the functional requirement “transmitting and receiving maritime safety information” is not yet fully met.
Therefore, ships operating outside NAVTEX service areas and relying upon Iridium SafetyCast for MSI should mitigate the risks of operating in an area where an MSI provider has not declared itself at full operational capability with SafetyCast1. Failure to mitigate these risks may be contrary to the requirements of the ISM Code.
Conclusion:
Currently, the Inmarsat-C terminal, via the SafetyNET system, is the only device which meets the functional requirement “transmitting and receiving maritime safety information” for the whole GMDSS sea area A3.
In the event of installation of a type-approved Iridium terminal as the recognized mobile satellite service, the NSI can agree with this subject to the following condition being followed and text stated on the relevant certificate(s):
In case of not mechanically propelled sail passenger ships (COS) the following note is to be included on or to the COS
“In the event that the ship sails in an area in which the receipt of maritime safety information, as required by SOLAS regulation IV/7.1.5, is covered by neither the Iridium installation nor an international NAVTEX service, the shipowner shall ensure that an additional type-approved Inmarsat-C device is temporarily installed on board. Subject (temporary) Inmarsat-C device shall be inspected / tested by a radio service company approved by the NSI prior to commencing the voyage.”
In case of a ship other than a ‘not mechanically propelled sail passenger ship (COS)’, the following condition is to be included on the '(Record of Equipment) to the Ships Safety Certificate'
“In the event that the ship sails in an area in which the receipt of maritime safety information, as required by SOLAS regulation IV/7.1.5, is covered by neither the Iridium installation nor an international NAVTEX service, the shipowner shall ensure that a type-approved Inmarsat-C device is temporarily installed on board in addition of the non-complying mobile satellite service(s), able to receive MSI (outside the scope of NAVTEX). Subject (temporary) Inmarsat-C device shall be inspected / tested by a radio service company approved by the NSI to commencing the voyage. Besides when relying (partly) upon Iridium SafetyCast service for MSI, measures shall be taken to mitigate risks in areas where a corresponding MSI provider has not declared at full operational capability with SafetyCast”
When the ship owner intends to replace the Inmarsat-C terminal by an Iridium installation under the above mentioned conditions, the ships RO shall be contacted for further instructions.
Occasional voyages in GMDSS sea area A4 for ships equipped with GMDSS A3 equipment
Valid until 01-01-2024
The acceptance of an “occasional voyage” in GMDSS sea area A4 (while equipped with equipment for GMDSS sea area A3) is based on paragraph 2.1.2 of IMO Resolution A.702(17), where the following is stated:
“... Ships operating in A4 area’s only occasionally and having originally installed an MF/HF radio installation, may, instead of the additional MF/HF radio installation, install an INMARSAT SES complying with the requirements of regulation IV/10.1.1...”
The existing INMARSAT-C SES installation may be the duplication of subject equipment, in case of occasional voyages in GMDSS sea area A4.
When a ship embarks upon such a voyage the following requirements shall be complied with:
- Before commencing the voyage subject ship(s) shall be provided with a type approved MF/HF with DSC, scanning MF/HF DSC watchkeeping receiver and direct printing telegraphy (NBDP), an EGC receiver for the INMARSAT ship earth station (should already have been provided), an EPIRB (COSPAS-SARSAT) and a second VHF/DSC (Resolution A.702(17)) in compliance with SOLAS regulation IV/11 (Radio equipment for sea areas A1, A2, A3 and A4)1;
- All equipment shall be type-approved in accordance with the relevant requirements; (MED 2014/90/EC, as amended)
- It shall be confirmed that the battery capacity is sufficient to cover any additional equipment;
- Before commencing the voyage the equipment shall be tested by an approved radio surveyor/service supplier, acceptable to the Recognized Organization (RO) and this shall be verified by the RO; and
- The NSI requires a confirmation from the RO that all of the above-mentioned requirements are complied with.
Remote verification
With reference to item ‘d’ above: “... and this shall be verified by the RO” the NSI deems it acceptable that subject verification by a surveyor from the RO is carried out remotely (in conjunction with Instruction to Recognised Organisations no. 32 - Remote Survey). In case extra GMDSS equipment is (temporarily) installed, or existing MF/DSC equipment is updated to MF/HF/NBDP equipment upon entering GMDSS sea area A4 waters, or de-commissioned upon leaving GMDSS sea-area A4 waters, a radio surveyor/service supplier acceptable to the RO always has to carry out an inspection on board. Due to the specific nature of subject equipment and the specific knowledge of the approved radio surveyor/service supplier, the physical attendance of a surveyor from the RO may be replaced by a remote verification by the RO. Such a remote survey may be carried out by the RO under the following conditions:
- The approved radio surveyor/service supplier is informed aforehand, and it shall be provided with any necessary equipment and it shall agree with the procedure;
- The Record of Equipment for Cargo Ship Safety Radio (Form R) shall be revised and the following remark shall be added: “Occasional voyage in GMDSS sea area A4 is allowed based on the (temporary) provision of MF/HF with NDBP;” this in compliance with the instructions from the Netherlands;
- Visual evidence shall be available for the RO (such as pictures, video, online meeting, etc.)
- A copy of the NBDP test shall be available for the RO;
- Evidence of an HF/DSC test call shall be available for the RO.