Global Maritime Distress and Safety System (GMDSS)

The IMO provides detailed guidelines through SOLAS Chapter IV and supporting circulars. According to SOLAS Regulation IV/15 on Maintenance Requirements:

"Equipment shall be so designed that the main units can be replaced readily, without elaborate recalibration or readjustment. Where applicable, equipment shall be constructed and installed in such a way that it is readily accessible for inspection and on-board maintenance purposes."

This regulation emphasizes availability and ease of maintenance to ensure distress functions remain operational. Furthermore, SOLAS IV/15.8 specifies maintenance methods:

"While all reasonable steps shall be taken to maintain the equipment in efficient working order to ensure compliance with all the functional requirements specified in regulation 4, malfunction of the equipment for providing the general radiocommunications required by regulation 4.8 shall not be considered as making the ship unseaworthy or as a reason for delaying the ship in ports where repair facilities are not readily available, provided the ship is capable of performing all distress and safety functions."

For ships operating in sea areas A3 and A4 (beyond VHF and MF coverage), a combination of at least two maintenance methods is required: shore-based maintenance, at-sea electronic maintenance, or duplication of equipment. These methods ensure redundancy, such as separate antennas and reserve power sources (e.g., batteries providing 1-6 hours of operation depending on the ship's emergency power setup).

Additional guidance is provided in IMO Circular COMSAR.1/Circ.32/Rev.3, which harmonizes GMDSS requirements:

"Radio equipment installations on SOLAS ships should meet the relevant IMO requirements and ITU recommendations and should be of a type-approved by the Administration."

This circular details functional requirements by sea area (A1-A4), including continuous watches on DSC frequencies and automatic position updating for distress alerts. Surveys must confirm compliance with performance standards like resolution MSC.511(105) for VHF equipment and MSC.512(105) for general GMDSS standards.

Recent updates, such as those in MSC.1/Circ.1460/Rev.5, require VHF equipment to comply with updated ITU channel arrangements by the first radio survey on or after 1 January 2028, ensuring compatibility with shore facilities.

Companies or firms conducting GMDSS radio surveys must be authorized to act on behalf of flag states or recognized organizations (ROs) to ensure impartiality and expertise. The IMO's Resolution A.739(18) provides guidelines for such authorization:

"The organization should be able to document extensive experience in assessing the design, construction and equipment of merchant ships and, as applicable, their radio installations."

Flag administrations may delegate surveys to ROs, such as classification societies (e.g., DNV, ABS, ClassNK), which in turn approve service suppliers. These suppliers must meet procedural requirements set by the International Association of Classification Societies (IACS) under UR Z17:

• Supervisor Qualifications: Minimum two years of technical school education, experience as an inspector, and preferably a General Operator’s Certificate (GOC) or GMDSS Radioelectronic Certificate (REC) recognized by the ITU.
• Inspector Qualifications: At least one year of technical training, one year as an assistant inspector, and preferably a national radio operator's certificate. They must complete internal training on radiotelephony, GMDSS, and surveys.
• Firm Requirements: Documented quality system (e.g., ISO 9000 compliant), personnel records, calibrated equipment (e.g., frequency meters, EPIRB testers), and procedures for reporting. Approval is granted after audits and demonstrations, with renewal every five years.

In practice, ship owners must engage firms approved by their vessel's classification society or flag state administration. For example, ClassNK requires radio firms to be approved for annual inspections. This ensures surveys align with IMO Resolution A.1156(32) on HSSC and flag-specific rules.

By adhering to these surveys and certifications, vessel operators can maintain compliance, enhance safety, and avoid penalties. For tailored advice, consult your flag state authority or recognized organization.

Ships subject to the Chapter IV of the Safety of Life at Sea (SOLAS) Convention have to fit GMDSS equipment. These include all ships engaged on international voyages except:

• Cargo ships less than 300 gross tonnage,
• Ships of war and troopships,
• Ships not propelled by mechanical means,
• Wooden ships of primitive build,
• Pleasure yachts not engaged in trade,
• Fishing vessels, and
• Ships being navigated within the Great Lakes of North America.

https://www.navcen.uscg.gov/?pageName=gmdssCompliance

The International Association of Classification Societies (IACS) is a non-governmental, not-for-profit organization that brings together the world's leading marine classification societies. Established in 1968 and headquartered in London, UK, IACS is dedicated to promoting high standards of safety at sea, preventing marine pollution, and ensuring clean seas through technical excellence.

Its primary mission is to establish, review, develop, and promote unified technical standards (known as Unified Requirements or URs) for the design, construction, maintenance, and survey of ships and offshore structures. These standards are adopted by its member societies and cover over 90% of the global cargo-carrying tonnage.

• Technical Standards and Harmonization: IACS develops Unified Requirements (e.g., UR Z17 for approval of service suppliers conducting radio surveys) and Unified Interpretations of IMO regulations to ensure consistent application worldwide.
• Support to IMO: As the only non-governmental organization with Observer status at the International Maritime Organization (IMO), IACS provides technical advice, helps interpret SOLAS and other conventions, and contributes to global maritime regulations.
• Quality Assurance: Through its Quality System Certification Scheme (QSCS), IACS ensures members maintain rigorous quality management systems.
• Surveys and Certification: Members act as Recognized Organizations (ROs) on behalf of flag states, conducting statutory surveys (including GMDSS radio surveys) and issuing certificates.
• Research and Development: IACS conducts R&D on emerging issues like cybersecurity, decarbonization, and digital transformation in shipping.

In the context of GMDSS radio surveys, IACS plays a critical role by setting procedural requirements (e.g., qualifications for radio inspectors and approval of service suppliers) that classification societies use to authorize companies performing these inspections.

IACS currently has 12 member classification societies:

• American Bureau of Shipping (ABS)
• Bureau Veritas (BV)
• China Classification Society (CCS)
• Croatian Register of Shipping (CRS)
• Det Norske Veritas (DNV)
• Indian Register of Shipping (IRS)
• Korean Register (KR)
• Lloyd's Register (LR)
• Nippon Kaiji Kyokai (ClassNK)
• Polski Rejestr Statków (PRS)
• Registro Italiano Navale (RINA)
• Türk Loydu

These members collectively set the benchmark for maritime classification and safety standards globally.

The Large Yacht Code, now formally known as the Red Ensign Group (REG) Yacht Code Part A (July 2024 Edition), is a code of practice developed by the Red Ensign Group (which includes maritime administrations from the UK and its overseas territories and crown dependencies, such as the Cayman Islands, Isle of Man, and British Virgin Islands). It establishes minimum standards for the design, construction, equipment, and operation of large commercial yachts to ensure safety at sea while providing practical equivalences to international maritime conventions where full compliance would be unreasonable or impracticable for yachts.

Originally introduced as the Large Commercial Yacht Code (LY1 in 1997, updated to LY2 in 2000 and LY3 in 2013), it was consolidated in 2019 into the REG Yacht Code to combine LY3 with the Passenger Yacht Code. Part A specifically applies to yachts in commercial use for sport or pleasure that carry no more than 12 passengers and do not carry cargo. It is intended exclusively for the yachting sector and does not apply to commercial cruise, excursion, or cargo vessels. Yachts complying with the Code are exempt from certain requirements, such as those in the High-Speed Craft (HSC) Code.

Key aspects of applicability include:

• Vessel Size: Applies to motor or sailing yachts of 24 meters or more in load line length (or 150 gross tons or more for vessels built before July 21, 1968). It categorizes yachts by gross tonnage (GT): less than 300 GT, 300–499 GT, and 500 GT or more.
• Operational Categories: Divided into short-range yachts (operating within 60–90 nautical miles of a safe haven, with wind limits of Beaufort Force 4 for motor yachts or Force 6 for sailing yachts) and long-range (unrestricted) yachts with no distance limitations.
• New vs. Existing Yachts: New yachts (keel laid on or after July 1, 2024) must fully comply with the current edition. Existing yachts may continue under previous editions (e.g., LY3) or transition with surveys. Major conversions or modifications are treated as new builds.
• Alignment with International Standards: It adapts conventions like SOLAS (Safety of Life at Sea), the Load Line Convention, STCW (Standards of Training, Certification and Watchkeeping), MARPOL (Marine Pollution), and MLC (Maritime Labour Convention). Equivalences are allowed with administration approval to maintain safety intent, such as relaxed stability criteria for short-range operations or alternatives for polar regions under the IMO Polar Code.
• Certification: Compliance is verified through surveys by Recognized Organizations (e.g., classification societies), leading to issuance of certificates like the Large Yacht Certificate of Compliance. A stability information booklet must be carried on board.

The Code emphasizes risk minimization for the yacht, persons on board, and the environment, covering areas like structural integrity, fire protection, life-saving appliances, navigation, and crew accommodations.

 Radio carriage requirements are detailed in Chapter 19 of the REG Yacht Code Part A (Radio Communications), which aligns with SOLAS Chapter IV but provides yacht-specific equivalences. These ensure effective distress alerting, search and rescue coordination, and general communications, often incorporating GMDSS (Global Maritime Distress and Safety System) principles. Requirements vary by gross tonnage, operational range, and vessel size, with mandatory equipment like VHF radios, EPIRBs (Emergency Position-Indicating Radio Beacons), and SARTs (Search and Rescue Transponders). All equipment must support distress functions (e.g., Digital Selective Calling or DSC, and GPS integration), be properly installed to avoid interference, and include maintenance records. Antennas must be positioned for optimal performance, and reserve power sources (e.g., batteries) are required for at least 3 hours of operation in emergencies for yachts under 300 GT.

• Yachts of 300 GT or More:
  • Must comply fully with SOLAS Chapter IV for GMDSS, covering Sea Areas A1 (VHF coastal), A2 (MF medium-range), A3 (HF/Inmarsat long-range), and A4 (HF polar areas) as applicable.
  • Short-Range Operations: VHF radiotelephone with DSC is sufficient if within reliable coastal station coverage (up to 60–90 nm from a safe haven).
  • Long-Range (Unrestricted) Operations: Full GMDSS suite, including VHF with DSC, MF/HF radios with DSC, satellite communications (e.g., Inmarsat), at least one EPIRB, two SARTs or AIS-SART equivalents, radar transponders, and long-range identification and tracking (LRIT) systems.
  • Additional: NAVTEX receiver for navigational warnings, and at least two portable two-way VHF radios for on-board communications.
• Yachts Under 300 GT:
  • GMDSS is not mandatory; equivalents are permitted if they ensure distress alerting and are approved by the administration.
  • Short-Range Operations: VHF radiotelephone with DSC only, provided the yacht stays within VHF coverage of coast stations. No satellite equipment required.
  • Long-Range (Unrestricted) Operations: VHF with DSC plus additional MF/HF radios or satellite systems (e.g., Inmarsat-C) for areas beyond VHF/MF coverage. Must include at least one EPIRB and one SART.
  • Transitional provisions allow existing yachts to retain pre-2024 installations (from LY3 or earlier) for up to 18 months post-Code update, subject to surveys confirming functionality.

Radio requirements extend to survival craft:

• All Yachts 24 m or More, 500 GT or More, or 85 m or More: At least two waterproof, portable two-way VHF radiotelephones (GMDSS-compliant) for use in liferafts or rescue boats, regardless of range. These must be stowed for quick deployment and capable of operating on distress frequencies.
• EPIRB: One float-free, automatically activated 406 MHz EPIRB with GPS, tested annually and serviced every 5 years by an approved provider.
• SART: One for yachts under 500 GT; two for 500 GT or more. AIS-SARTs may substitute if equivalent.
• For short-range yachts, reduced liferaft equipment packs (SOLAS Pack B) are allowed, but radio gear remains mandatory.

• Maintenance: Equipment must be serviced per manufacturer guidelines and SOLAS requirements. For GMDSS, shore-based maintenance contracts or duplication of equipment are needed for long-range operations.
• Surveys: Annual radio surveys verify functionality, as per the Harmonized System of Survey and Certification. For yachts under 300 GT, surveys focus on equivalents rather than full GMDSS.
• Equivalents and Exemptions: Alternatives to full SOLAS compliance are allowed if safety is not compromised (e.g., reduced reserve power for smaller yachts or modified antenna setups). Short-range yachts have relaxed requirements overall. Exemptions are rare and must be justified; for example, no EPIRB exemptions for ocean-going yachts. Proposals require engineering justification and are recorded in the yacht's documentation.
• Operator Qualifications: At least two crew members must hold GMDSS operator certificates (General Operator's Certificate for long-range).

These requirements ensure yachts can maintain continuous radio watches and distress capabilities tailored to their size and operations, with flexibility for the yachting industry.