MF / HF Radio mandatory for UK flagged boats going offshore?

[terah]

@poiu Yeah the responses are a little frustrating but I guess in part that's down to the legislation, particularly the Exemptions, not being specific enough. I'll keep on at them.

@dockhead The GMDSS rules certainly are much clearer, and to me seem common sense. But, I've not found anything in the UK legislation to suggest that the GMDSS definitions should apply.

[poiu]

Originally Posted by Dockhead

No, it's very clear and prescribed precisely by GMDSS accordingly to the Sea Area. See: https://www.egmdss.com/gmdss-courses...ew.php?id=2213

In A2 you need MF and in A3 and A4 - HF. And it only counts if youhave DSC.

I disagree, I think it is far from clear.

Those regulations you linked to are derived from the SOLAS regs relating to commercial ships. They don't apply to our small pleasure boats, we are only bound by the safety regs in section V.

There is also no reference to the GMDSS rules or SOLAS Chapter IV in the guidance or legislation suggesting it might be in force, which would have been necessary to make had it been their intention to reference the Section IV radio rules.

Also, we may gain some clarification here - In the MCA guidance in MGN 538(M) they say:

Equivalent standards of safety have been agreed, following the identification of practical problems associated with complying with the Merchant Shipping Regulations for Life-Saving Appliances (detailed in 3.4.1) and the possible conflict in also having to comply with the Recreational Craft Directive (RCD), with which some vessels (see footnote 4) being placed on the EU market for the first time have to comply. These equivalent standards also take account of equipment which is readily available and commonly used by the private boat owner. Unlike the Merchant Shipping Regulations, the agreed equivalent standards require boats to carry maritime radio and this means of summoning help is reflected in the scale of equipment required, which varies according to the distance from the coast that the vessel will be operating.

This is not quite what the MCA announced when their guidelines were first issued and found here:
https://mcanet.mcga.gov.uk/public/ne...cga_news_id=33
The words used there are:

BMF, MCA and the Royal Yachting Association (RYA) have since met and agreed an equivalent standard of safety which avoids possible conflict with the RCD and takes account of equipment which is readily available and commonly used by the private boat owner. The equivalent standard requires boats to carry VHF radio. The MS Regulations do not require a VHF radio, and the availability of this means of summoning help, in the equivalent standards, is reflected in the scale of equipment required which varies according to the distance from the coast that the vessel will be operating.

Note in the original press release they referred to VHF radio. This was subsequently changed to 'maritime radio'. It is a clue as to the intention of the regulation guidance requiring VHF and of the power of VHF rather than MF/HF.

[Dockhead]

Originally Posted by poiu

I disagree, I think it is far from clear.

Those regulations you linked to are derived from the SOLAS regs relating to commercial ships. They don't apply to our small pleasure boats, we are only bound by the safety regs in section V.

There is also no reference to the GMDSS rules or SOLAS Chapter IV in the guidance or legislation suggesting it might be in force, which would have been necessary to make had it been their intention to reference the Section IV radio rules.

Also, we may gain some clarification here - In the MCA guidance in MGN 538(M) they say:

Equivalent standards of safety have been agreed, following the identification of practical problems associated with complying with the Merchant Shipping Regulations for Life-Saving Appliances (detailed in 3.4.1) and the possible conflict in also having to comply with the Recreational Craft Directive (RCD), with which some vessels (see footnote 4) being placed on the EU market for the first time have to comply. These equivalent standards also take account of equipment which is readily available and commonly used by the private boat owner. Unlike the Merchant Shipping Regulations, the agreed equivalent standards require boats to carry maritime radio and this means of summoning help is reflected in the scale of equipment required, which varies according to the distance from the coast that the vessel will be operating.

This is not quite what the MCA announced when their guidelines were first issued and found here:
https://mcanet.mcga.gov.uk/public/ne...cga_news_id=33
The words used there are:

BMF, MCA and the Royal Yachting Association (RYA) have since met and agreed an equivalent standard of safety which avoids possible conflict with the RCD and takes account of equipment which is readily available and commonly used by the private boat owner. The equivalent standard requires boats to carry VHF radio. The MS Regulations do not require a VHF radio, and the availability of this means of summoning help, in the equivalent standards, is reflected in the scale of equipment required which varies according to the distance from the coast that the vessel will be operating.

Note in the original press release they referred to VHF radio. This was subsequently changed to 'maritime radio'. It is a clue as to the intention of the regulation guidance requiring VHF and of the power of VHF rather than MF/HF.

The RYA did fumble the press release, and haven't explained it very well, but the situation is actually not all that mysterious.

GMDSS is the basic framework for distress signalling at sea. Among other things, GMDSS establishes what services must be available to mariners -- how do the various SAR and Coast Guard services receive distress signalling.

So GMDSS basically answers this question -- "if you need help, how do you reach the authorities?". And GMDSS establishes different Sea Areas where different systems must work. So that mariners know that if they are in such and such a Sea Area, they can use such and such a system. Most countries declare as Sea Area A1 in their coastal areas, which means that mariners have the right to rely on being hear on VHF. Not all, however -- Australia, for example, has Sea Area A2 around its coast, and so VHF is NOT an official distress signalling method in Australian coastal areas.

All of the foregoing is entirely separate from the question of what signalling equipment is REQUIRED CARRY. That is not part of GMDSS; that is SOLAS. Whether or not you are required to carry any kind of radio, the "appropriate" radio type is that which suits the Sea Area you are navigating in -- otherwise you won't be heard. So if they require you to carry "maritime radio", and if they explicitly say that the "scale of equipment required VARIES DEPENDING ON DISTANCE FROM THE COAST", then they are obviously talking about GMDSS Sea Areas. And if the "equipment required" "VARIES", then they are obviously not talking about a single type of equipment -- i.e., VHF.

I bet the actual text of the regulation would be more enlightening; however, I could not find it. Maybe someone else has it.

[poiu]

Originally Posted by Dockhead

The RYA did fumble the press release, and haven't explained it very well, but the situation is actually not all that mysterious.

GMDSS is the basic framework for distress signalling at sea. Among other things, GMDSS establishes what services must be available to mariners -- how do the various SAR and Coast Guard services receive distress signalling.

So GMDSS basically answers this question -- "if you need help, how do you reach the authorities?". And GMDSS establishes different Sea Areas where different systems must work. So that mariners know that if they are in such and such a Sea Area, they can use such and such a system. Most countries declare as Sea Area A1 in their coastal areas, which means that mariners have the right to rely on being hear on VHF. Not all, however -- Australia, for example, has Sea Area A2 around its coast, and so VHF is NOT an official distress signalling method in Australian coastal areas.

All of the foregoing is entirely separate from the question of what signalling equipment is REQUIRED CARRY. That is not part of GMDSS; that is SOLAS. Whether or not you are required to carry any kind of radio, the "appropriate" radio type is that which suits the Sea Area you are navigating in -- otherwise you won't be heard. So if they require you to carry "maritime radio", and if they explicitly say that the "scale of equipment required VARIES DEPENDING ON DISTANCE FROM THE COAST", then they are obviously talking about GMDSS Sea Areas. And if the "equipment required" "VARIES", then they are obviously not talking about a single type of equipment -- i.e., VHF.

I bet the actual text of the regulation would be more enlightening; however, I could not find it. Maybe someone else has it.

There are no specific regulations other than those in MGN 538.There is a heap of regulation for commercial and larger ships, who do have to follow the SOLAS and GMDSS rules and protocols concerning radios and communication. Class XII pleasure boats are exempted from all of that. The only bit of 'legislation' that is of relevance are the words in MGN 538..."one of which must be a maritime radio capable of transmitting and receiving calls and messages appropriate for the area of operation"

It's as clear as mud. I can see why the RYA went for HF/MF because they took the meaning of 'area of operation' to refer to the use of that term in the GMDSS rules, as it seems you do to, but as I mentioned above I don't think this is a correct interpretation:

1. It would mean that the thousands of pleasure motor yachts operating in the Med especially and pleasure yachts going moderately far from the coast anywhere were operating in breach of the regulations. If that really was the intention then the MCA would surely have piped up by now and put an end to illegal operation. There has been no squeak from them as far as I am aware.

2. There is another explanation, which is that the areas of operation might refer to the water categories A to D (essentially inland waterways),which are mentioned in various bits of the SOLAS regs as well as in MGN 538.

3. There is another interpretation that different maritime radios for different areas must refer to MF/HF and that is they are referring to different types of VHF. Handheld VHF is fine for certain inland areas and a full power VHF is fine for more distant areas, including at sea. Note the are is no requirement or mention in the regs or anywhere of a requirement to be able to contact a shore station and so we do not need to assume that HF/MF is required.

4. In the commercial regs, ships are permitted a Sat-C or equivalent as an alternative to HF/MF so surely that would be permitted for pleasure vessels too if the intention was to reflect the commercial rules. If it really was their intention of the MCA to require MF/HF then the RYA is mistaken in presuming that HF/HF is the only option and therefore obligatory.

5. The MCA went to the trouble to exempt class XII vessels from all the heavy duty complex safety rules in the commercial ship legislation by issuing MGN 538, but if it was their intention to require make the radio rules more complicated and to require class XII yachts comply with commercial yacht communication rules as in effect the RYA are suggesting then they would have amended the SOLAS radio regs to remove the exemptions provided in those rules. That would be super clear then as those rules are very clear, unlike MGN 538.

[boatman61]

They left pleasure vessels out of it because the radio's would be unusable.. can you imagine the havoc if the idiots who populate VHF and CH16 were let loose on the MF/HF airways..

[poiu]

Originally Posted by boatman61

They left pleasure vessels out of it because the radio's would be unusable.. can you imagine the havoc if the idiots who populate VHF and CH16 were let loose on the MF/HF airways..

Havoc redefined!

[terah]

While i don't think the GMDSS definitions specifically apply, I do think the most likely interpretation of MGN 538 is that mf/hf radio is required for offshore cruising.

Whether this is a practical requirement or not is a different question. The latest ARC survey had half of entrants with SSB - I might ask them how that breaks down for UK flagged vessels. Also, the rules are 15 years old and technology has moved on, particularly with the likes of Spot/inReach, so even if it was considered practical then, would it be now?

I hadn't realised the RYA were involved in creating the exemptions (MGN 538) until I read that press release @poiu posted in #22. That puts a slightly different slant on their view as they were active in the process rather than just interpreting the rules.

Given that there is currenly no type approved SSB radio in the UK this is an even more burdensome requirement.

@poiu Agree that satellite comms would be a sensible alternative, just not sure how that would comply with "maritime radio". Again the lack of definition here is the issue. At the very least the RYA/MCA should be able to define this better.

[terah]

Have just had a chat with the MCA. They said that the MGN 538 rules are derived from SOLAS and that the A1/A2/A3/A4 sea areas and requirements as defined in GMDSS are a sensible way of interpreting these rules.

I've asked if there is anywhere that explicitly defines "maritime radio" in the context of MGN 538, and also if a Class XII vessel with VHF and Satellite comms would be considered compliant. They are going to look into the rules in more detail and get back to me.