GMDSS Log Book Entries

It has been brought to our attention that during a recent CDI inspection an issue was raised regarding GMDSS log book entries, which lead to an observation relating to EPIRBs (Emergency Position-Indicating Radio Beacon). The observation stated that the EPIRBs were not being recorded as being in an efficient working order before sailing.

We would like to refer to the following  statutory requirements in order to clarify this aspect and reduce the possibility of observations during either CDI or SIRE  inspections.

Section 1.4.16 of the CDI report which reads "Prior to sailing, the fact that this equipment (as listed in CDI 1.4.4) is in an efficient working condition is to be recorded in the radio log.

A routine record of inspection and testing should also be available. Where the design of the EPIRB does not permit a function test to be carried out then a check should be made of the date stamp on the equipment to ensure it is still valid."

STCW 95 Section B VIII/2  Part 3.3 item 14 "Prior to sailing the radio operator designated as having primary responsibility for radio communications during distress incidents should ensure that: 14.1 all distress and safety radio equipment and the reserve source of energy are in efficient working condition and that this is recorded in the radio log".

It is clear from the STCW regulation that an entry does have to be made regarding the GMDSS equipment and associated distress equipment being in an efficient working condition prior to sailing. This should not be confused by the further statement under CDI section 1.4.16 regarding a record of inspection and testing should also be available. This is as per the requirements under the GMDSS regulations and refers to the monthly testing of EPIRB equipment.

To summarise, all equipment should be "confirmed" as being operational prior to sailing, there is no additional requirement to test the EPIRB at this time as long as the monthly testing is being carried out.

We would also like to draw attention to the OCIMF VIQ section 11.1.6 which also makes reference to EPIRB testing and recording of the same tests in the GMDSS log book. The OCIMF VIQ guidance incorrectly makes reference to the testing being made weekly, instead of monthly, which is specified in the Appendix to the GMDSS Logbook. We can confirm that after consulting with OCIMF on the matter, this printing error was discovered soon after publication of the VIQ, and that it has been brought to the attention of SIRE accredited inspectors. OCIMF advises that if inspector observations are made relating to the frequency of EPIRB testing, the VIQ error should be pointed out.

One final point regarding SIRE Inspections; the SIRE Inspector should always be asked to show proof of identity in the form of their SIRE Inspector Accreditation card when boarding.

ContactPhilip Shenton