Within the marine industry, the importance of mandates in driving safety innovation and equipment adoption is widely known. From AIS electronics legislation for internal waterways, requirements for hands-free options on EPIRBS and the future banning of non-GNSS (GPS) EPIRBS, the US has been leading the way. Ireland’s BIM organisation used life jacket and PLB legislation to reflect government-stated policy of reduced deaths at sea, and New Zealand is looking at similar rules on automatic EPIRBS for its fishing fleet. Every year we hear calls for greater requirements for communications and location equipment to stem unnecessary deaths of people enjoying the water.
While marine legislation changes attitude and actions, and the purpose of the legislation is often clearly understood, there is still a need for greater clarity on what technology is deployed. Search and Rescue technologies’ complexity comes from its accelerated evolution and the impact of national and international legislation on what is and isn’t acceptable.
Seemly positive additions to tried and tested technologies can and will have unforeseen consequences, without rigorous field testing in conjunction with marine stakeholders that interact with the technology. Case-in-point is the inclusion of DSC radio alarms in some AIS MOB devices. While on paper a wide-ranging, localised alarm system should accelerate alert detection, the lack of a closed loop signal to end the emergency call renders DSC, in its present form, more of a distraction like a faulty car alarm. The result has been a wave of national regulations placing numerous restrictions or outright bans on the use of DSC in ASI MOBs. Whereas, earlier and more widespread discussions would have identified the need for the Class M variant, which overcomes many of the issues, to be the foundation for this innovation before it was deployed.
The new IMO Marine Fire Safety Legislation, Resolution MSC.338(91), seems to have lent itself to the same issue. On paper the mandate has a laser sharp focus, improving the safety of commercial shipping firefighting teams through effective communications equipment that reflects the unforgiving environment of the role. In reality, it is an opportunity to deploy dedicated, purpose-built communications tools that also encompasses ATEX requirements – basically, not generating sparks in a potentially explosive environment.
The mandatory provision of ATEX approved handheld two-way radios for firefighting operations, known as SOLAS Chapter II-2, Regulation 10.10.4, should support the clarity of the IMO regulation. However, the wording is such that the interruption of ATEX approved radios can mean the basic ‘intrinsically safe’ IECEx models, which offer a lower standard of protection that isn’t appropriate for all vessels and could reduce the level of crew safety. ATEX comes in differing levels, each offering additional protection for specific explosive environments. The higher the level, the greater the protection. For example, McMurdo’s R8F offers the higher equipment rating ATEX IIB - offering protection in Propane and Ethylene environments.
By not being specific with the technology requirement, the mandate is interpreted purely on a cost basis, rather than meeting the aims of the original legislation. While for many the basic intrinsically safe radio will be sufficient, encouraging deployment of basic models misses the opportunity to include additional safety features such as integral audio, UHF frequency and secure connection. It also increases the likelihood of confusion once deployed in the field. How, in an emergency, do the crews identify the correct radio and how can they be confident that it offers the protection for the environment they will be risking their lives in?
In the time-sensitive rush to avoid financial penalties by not complying to the July 2018 Regulation 10.10.4, the industry and the very bodies driving safety are missing an opportunity to install an infrastructure of safe and effective communication equipment, based on the most innovative and effective radios in the market today. With an estimated 200,000 plus radios required to be deployed to SOLAS vessels in the next twelve months, what seems like a cost-saving exercise could shorten the operational effectiveness of the investment, as regulations tighten or reflect new national requirements, and may reduce the safety of crews.
Legislation is key to both technology adoption and industry innovation. Although often seen purely as an operational cost, it provides an unmistakable opportunity to improve the industry and put safety first.