200319 How to Reduce Unnecessary GMDSS Calls

How to Reduce Unnecessary GMDSS Calls
Report No. 200319

I would not presume to disagree with the need for a lookout in addition to the OOW - and I support the assertion that it is wrong to expect all Deck Officers to become experts in radio communication just because they have completed a GMDSS 'short course'. The standard GMDSS training course, on its own, is not enough to fully equip most candidates to use effectively GMDSS equipment that is very often 'non user-friendly'. But, hidden (?) in THE MARINER'S GUIDE TO MARINE COMMUNICATIONS* there are a few items that most ship's officers could attend to on their own vessel to reduce the number of unnecessary DSC alerts they receive or cause other vessels to receive. Whilst not reducing the level of own-vessel business/crew communications, the following should help reduce the number of unnecessary (false) alerts/log entries onboard all vessels:

1. Appendix X explains that vessels in Sea Area A3 do not need to maintain the HF DSC watch on 8414.5kHz 'and one other HF Distress Alerting frequency' if the vessel is maintaining an Inmarsat SafetyNET watch covering their location. The HF DSC/SafetyNET watch is maintained for the purposes of receiving Alerts/Messages 'from-shore' - and, in Sea Area A3, the HF DSC watch needs to be activated only when (if) the vessel's SafetyNET system fails. Despite this, many vessels maintain both watches simultaneously. The result is that they receive DSC Alerts from-ship stations as well as from shore stations and, in the vast majority of cases, the vessel sending the HF DSC Distress Alert/Distress Relay/Distress Acknowledgement is many hundreds - even thousands, of miles away and the receiving vessel is not close enough to assist. ACTION REQUIRED? Maintain the Inmarsat SafetyNET watch and disable the HF DSC watch until it has to be activated as the standby means of shore-ship alerting, should SafetyNET fail - or when the vessel moves into an A4 area. RESULT? A greatly reduced number of superfluous DSC Alerts.
2. The 'Automatic Distress Acknowledgement' on VHF and MF/HF DSC equipment can be disabled (page 202/204) - Some DSC equipment is programmed to automatically acknowledge a DSC Distress Alert. A DSC Distress Acknowledgement is an 'All Stations' call and, when generated, will activate all receivers on all vessels in range (and this can mean worldwide on High Frequency). This 'auto acknowledge' should be disabled so that any DSC Distress Acknowledgement must be sent manually. 'The Guide' explains in detail the limited circumstances where a DSC Distress Acknowledgement is allowed to be used (Chapter 5 - Distress, Urgency and Safety Communications). If in doubt, consult a Coast Station/RCC before sending a DSC Distress Acknowledgement (Page 97 of 'The Guide').
3. Do not send a DSC Distress Relay to 'All Ships/All Stations' before consulting a Coast Station/RCC, unless you have been appointed 'On-Scene Co-ordinator - OSC' by the RCC responsible for the area/incident (or as otherwise explained on Page 100 of 'The Guide'). When sending a DSC Distress Relay to shore, address the Relay to an individual Coast Station/RCC and not to 'All Stations' (Page 97-105 of 'The Guide').
4. Regarding the (written) Radio Log: under GMDSS regulations, vessels are required to log a summary of Distress (Mayday), Urgency (Pan Pan) and Safety (Securité) traffic (Page 24 of 'The Guide'). In the case of Safety traffic, you only need to record those message that are relevant to the location/voyage of your vessel. Maintaining a written log of 'routine' calls is not required under GMDSS rules (though company/ship's rules may require such items to be logged - in which case a review of company/ship's instructions may be in order). Reducing the number of 'false' or superfluous alerts (as detailed above) will also reduce the number of items to be logged.

The above suggestions will not solve the problems of minimum manning/minimum training but, if applied globally, should help relieve the situation for watchkeepers on all vessels.

*'The Mariner's Guide to Marine Communications' published by The Nautical Institute in June 2001. 'The Guide' was written to help Deck Officers manage their communications role, recognising that short courses, on their own were not enough for most candidates. Ian's GMDSS training courses are MCA-approved for STCW 95. More information can be found on www.gmdss4all.net

Readers' Feedback

The report states that it is not necessary to keep an HF DSC watch if the vessel is equipped and maintaining a watch on Inmarsat SafetyNET. It says that this can be justified by referring to Appendix X of the Mariners Guide to Marine Communications. I would dearly love to be able to stop the HF watch as we do have the Inmarsat SafetyNET but I can't justify it unless this same exception is noted in the IMO GMDSS handbook. Can you please inform me if this is in the IMO GMDSS handbook and if so where it might be found?

Ian Waugh replied (RB)

It's unlikely that you'll find the information in the IMO GMDSS Handbook. The handbook will have taken guidance from the International Radio Regulations (RRs). Those regulations which, in an ideal world, would provide the clear, unambiguous and definitive (practical?) guidance are the source of the 'problem'. When the RRs were re-written for the GMDSS, it was assumed that vessels operating in an A3 area would fit either HF DSC or Inmarsat - not both. A3 ships who chose the HF DSC (SSB Radio) option were required to maintain the HF DSC watch - primarily to allow them to receive shore-to-ship distress relays (i.e. from RCCs). Such ships would receive their Maritime Safety Information (MSI - weather, information and navigation warnings) using SSB Telex Over Radio. A3 ships who fitted the Inmarsat option would receive their shore-to-ship distress relays over the SafetyNET service - and also their MSI.

The practical outcome of GMDSS equipment fitting is that most A3 ships are fitted with Inmarsat-C (to give them SafetyNET coverage, and Distress Alerting ship-to-shore amongst other things) and, because they've fitted MF DSC for the A2 area, they have HF DSC by default (if you fit an MF DSC/SSB system, you get HF DSC as part of the package - whether you want it or not).

Now the problem: 'purists' will insist that a ship which is fitted with HF DSC must keep an HF DSC watch because the RRs say something along the lines of 'HF DSC ships will .... [keep the HF DSC watch]'. Pragmatists will read the spirit of the GMDSS RRs and not the letter, and will come to the same conclusion that I did - that a vessel must be able to receive Distress Relays from the shore by one system or the other but do not have to monitor both at the same time. RCCs who have (or assume) responsibility for shore-to-ship Distress Relays for any A3 area will be obliged to broadcast that information using both systems - otherwise they cannot alert all types of vessel (i.e. those who have fitted HF DSC without Inmarsat; and those who would have fitted Inmarsat-C without HF DSC - had that been possible).

To look at it from another angle: Inmarsat-A, Inmarsat-B and Fleet 77 equipment is all allowed to be installed as part of a ship's GMDSS fit. But if a ship already has a full GMDSS fit that includes, for example, Inmarsat-C with SafetyNET, they can (and do) fit A, B or F77 in addition to their GMDSS fit. Just because it's 'GMDSS-type equipment' does not make it part of the required GMDSS fit for that particular ship. So, if their Inmarsat-A happens to include a SafetyNET facility, they do not have to programme their 'A' to receive SafetyNET information in addition to their Inmarsat-C. Which supports my belief that a ship, which is covered for A3 service using their Inmarsat-C, does not have to monitor HF DSC at the same time just because that equipment is fitted onboard.
HF DSC is additional to their 'primary' GMDSS fit (and would be available if their Inmarsat-C/SafetyNET system failed).

If you can get hold of Seaways July 2003 (letters page) you will see the purist response to the original MARS article; whilst Seaways October 2003 (letters) shows the pragmatic response. Both respondents are directly involved in writing and/or interpreting RRs. I need to add here that 'purists' are not wrong just because they are purists and we should not just ignore any RR which doesn't suit us, just because we don't understand the reasoning behind that RR. It can (and does) happen that the reasoning behind a particular regulation is not clear to the 'lay' operator and is often (I understand from those involved) the subject of much debate amongst those who write/re-write those RRs (or, to put it another way - it's not just the guys & dolls at sea who're confused!). I'm a purist myself with regard to what I see as a miss-interpretation of certain other regulations and I stick to my guns where I consider that a wrongful interpretation could cause a problem for the safety of life at sea.

The Mariner's Guide to Marine Communications, commissioned by The Nautical Institute, was written to help Deck Officers and others who have responsibility for maintaining proper marine radio communications at sea. Such a guide was deemed necessary because of the vast number of publications and regulations the new breed of 'radio operator' would have to read, interpret and become familiar with - not all of which are readily understandable (or even easy to find!) - in addition to his/her main role onboard. In writing the Guide, I tried to make things as clear as possible and, where the occasional conflict occurred (like that you mention) I've made what I considered to be a sensible, pragmatic judgement in the spirit of the GMDSS regulations (and, on this point as with others, not without consulting people directly involved with setting the RRs).

The following was the response to Ian's advice. RB

I can tell you from the practical standpoint of those Mates standing watch at sea. Rightly or wrongly, for all intents and purpose the HF DSC alerts are pretty much ignored. The Mates press the "Silence" button and that is that. I guess after you have seen 100, 200 or even 500 false alerts, or alerts, far, far out of your area, you begin to get immune to "The sky is falling" alarm... It is sad really. The going joke on here is that if we ever had to send an alert it is going to be by Sat Phone and strapping the EPIRB to your lifeboat. Why... because we know that every other vessel is doing the same thing as we are... ignoring the DSC alerts. When in trouble the last thing that will get attention is a HF DSC alert. It should be easy, simple and clear to send a legitimate SOS and almost impossible to send false alerts. Unfortunately that's not how GMDSS turned out.

Ian Waugh further responded as follows. RB

I would support you using an INMARSAT 'Satphone', or Inmarsat-C, as a good first choice for your initial ship-to-shore alert/message in an A3 area - with HF DSC a good second choice if the Inmarsat system doesn't work for any reason (the EPIRB being the last resort). Either way, if you only get one chance at it, a Coast Station/RCC should take control and organise the SAR operation.

Having completed the initial ship-to-shore (RCC) exchange, if time allows, you should follow-up with an MF DSC Distress Alert to alert other ships 'in the vicinity' and get them onto 2182kHz - if you have time before abandoning ship. That's the correct procedure (do the ship-shore bit first and then the ship-ship) and one that I support (the purist in me!).

But - If the HF DSC option is chosen for the ship-to-shore alert, you will, as you know to your cost, also alert many other vessels on HF - and that's where the problem lies ... if they weren't watching HF DSC (in addition to SafetyNET) they wouldn't have to bother with those 'superfluous' alerts and the overall system would gain a bit more credibility, I expect!! Especially as many vessels receiving such alerts go into 'relay' or 'ack' mode because they are unsure how to handle this type of message - and that, usually, makes matters worse. If the powers that be will accept that there's no need for an HF DSC watch in addition to SafetyNET, in an A3 area, then that, in my opinion, by avoiding distracting watchkeepers unnecessarily, will benefit the safety of life at sea - and it's good to know that that view is strongly supported in the IMO 'COMSAR' (communications/search and rescue) Operational Working Group.