August 04, 2006
Enman & Associates, Inc.
Maritime Marketing Alliance
10920 Baymeadows Rd.
Suite 27, PMB 304
Jacksonville, FL 32256 USA
Contact:
DAVE ENMAN
(904) 519-0469 tel
(904) 519-8580 fax
(904) 318-0909 mobile
shipyards@davidenman.com
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seacoast electronics, inc.
Global technology's solutions for today's waterborne commerce and defense
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RegulatoryAdvisory
From the International Maritime Organization (IMO):
Pursuant to IMO Annex 2, Resolution MSC.152(78), as adopted on May 20, 2004, Chapter IV, Life Saving Appliances and Arrangements, we wish to advise our clients that Regulation 15 states the following;
Satellite EPIRB’s shall be:
Annually tested for all aspects of operational efficiency, with special emphasis on checking the emission on operational frequencies, coding and registration, at intervals as specified below:
subject to maintenance at intervals not exceeding five years, to be performed at an approved shore-based maintenance facility.
a) on passenger ships, within 3 months before the expiry date of the Passenger Ship Safety Certificate; and
b) on cargo ships, within 3 months before the expiry date, or 3 months before or after the anniversary date, of the Cargo Ship Safety Radio Certificate.
The test may be conducted on board the ship or at an approved testing station; and
The Maritime Safety Committee has approved Guidelines for shore-based maintenance of satellite EPIRBs (see Annex II). It should be noted that .12 of MSC 1040 requires maintenance by an approved shore-based maintenance provider. The UK Administration accepts organizations nominated and approved by the EPIRB manufacturer to carry out shore-based maintenance. Shore-based maintenance shall be carried out, in accordance with the requirements of MSC/Circ 1039 (reproduced in annex 2), at an interval not exceeding five years or when battery replacement is due.
Our interpretation of this regulation and it’s effect on the vessel owner:
The vessels are compelled to carry a 406 MHz, satellite coherent, EPIRB. Each unit, irrespective of make or model, includes a battery and hydrostatic release mechanism. These require replacement at specific intervals. In addition, IMO now requires a detailed shore-based activity whereby the ship’s existing EPIRB must go through a rigorous test and certification process by an approved test facility and personnel by the respective OEM.
It is our contention that this will prove to be a difficult and possibly cumbersome evolution for the vessel owner, manager, or agent to accommodate during a routine port call. Our suggestion would be instead to fit a replacement EPIRB inclusive a fresh battery pack, release mechanism, and the OEM certification affixed meeting all current requirements under flag and classification society. A budgetary price list for approved replacement EPIRB units is attached.
For additional information please contact:
George DuBois |
Mike Pinkham |
Bob Kunkel |