1. VDR including Type Approval and Carriage Requirements.
Acceptability of pre-Jul 2002 equipment: Following two appeals by MCA to the EC over Directive 2002/59/EC, the Commission confirms that all ro-ro passenger vessels and HSCs must be equipped with fully compliant VDRs. The EC response reads: “Article 10 of this Directive abolishes, from 5 August 2002, exemptions regarding “voyage data recording systems” (black boxes) granted to ro-ro ferries or high speed passenger craft under Article 4(1)(d) of Council Directive 1999/35/EC.”
To this end, all vessels known to be fitted with non-compliant VDRs now have a plan to replace them. For passenger vessels other than ro-ros, we have requested operators to produce a replacement plan but this is less urgent because IMO exemptions/equivalents have been applied for the short term.
Exemptions to requirement to interface to certain items of equipment.
Technically, in accordance with the rejection of our appeal (as above), exemptions to interfaces on ro-ro and HSCs cannot be granted. In practice, there will be a few situations where interfacing is near to impossible. The EC has tacitly recognised this and we may consider registering exceptional cases with them.
Retrofitting of VDR’s to existing vessels – Data Items to be recorded, associated interfacing considerations and possible requirements for exemption. (Note – depending on vessel class/size, some of the following items may not be carriage requirement).
Acceptability of pre-Jul 2002 equipment: Following two appeals by MCA to the EC over Directive 2002/59/EC, the Commission confirms that all ro-ro passenger vessels and HSCs must be equipped with fully compliant VDRs. The EC response reads: “Article 10 of this Directive abolishes, from 5 August 2002, exemptions regarding “voyage data recording systems” (black boxes) granted to ro-ro ferries or high speed passenger craft under Article 4(1)(d) of Council Directive 1999/35/EC.”
Items to be recorded - reference: IMO Assembly Resolution A861 (20) Clause 5.4
(This resolution/clause gives further detail of the requirement and should be read in conjunction with this paper)
1. Date & Time – Available from GNSS receiver. No perceived grounds for exemption.
2. Speed – Available in electronic format from SDME and/or GNSS receiver. No perceived grounds for exemption.
3. Ship’s position – Available from GNSS receiver. No perceived grounds for exemption.
4. Heading – Available electronically from gyrocompass or Transmitting Heading Device (THD). No perceived grounds for exemption.
5. Bridge Audio – Microphones, amplifiers etc form part of VDR fit. No perceived grounds for exemption and should not be considered.
6. Communications Audio – Easily achieved with simple buffer amplifiers attached to VHF transceiver. No perceived grounds for exemption.
7. Radar data, post-display selection –
a. All recently built radars should provide suitable interface.
b. Older radars may provide electronic output which may be converted/connected via interface unit.
c. Radars with no electronic output are likely to be very old and require replacement in near future.
d. Radars with manufacturer-specific digital coded outputs. Interfaces may need to be designed/built for these.
(Note reference 7.c.&7.d. – In these cases, it may be necessary to consider exemption for a limited period only. This is to give sufficient time to order and fit the necessary equipment. A specific date must be agreed for replacement (and connecting post-display radar to VDR). “By next survey” or “by 200X” is not acceptable.)
8. Echo Sounder –
a. If any form of electrical/electronic output is available, should be connected.
b. If no electrical/electronic output is available, may be necessary to consider exemption.
c. In all cases, any replacement equipment fitted in future must provide required interface and be connected to VDR.
(Note reference 8.b. – consideration to be given to restricting exemption to “home route” and not beyond the next scheduled dry-docking. If the vessel is to sail a new route, the exemption should be reviewed.)
9. Main alarms – All bridge indications will be electrical/electronic therefore interfacing easily achievable. No perceived grounds for exemption.
10. Rudder Order and Response –
a. Electric/electronic systems should provide signals which may be interfaced via suitable interface units therefore no grounds for exemption.
b. Purely mechanical systems may require exemption. However, any/all associated electrical/electronic sensor (eg rudder angle sensor for autopilot) should be interfaced.
11. Engine order and response –
a. Electric/electronic systems should provide signals which may be interfaced via suitable interface units, therefore no grounds for exemption.
b. Purely mechanical systems may require exemption. However, any/all associated electrical/electronic sensor (eg shaft/engine rpm indicator) should be interfaced.
c. Thrusters should be treated in same way as main engines.
12. Hull Opening Status - All bridge indications will be electrical/electronic therefore interfacing easily achievable. No perceived grounds for exemption.
13. Watertight and fire door Status - All bridge indications will be electrical/electronic therefore interfacing easily achievable. No perceived grounds for exemption.
14. Acceleration and hull stresses – If fitted, any equipment will have electrical/electronic readout. Signals will therefore be available which may be interfaced via suitable interface units. No perceived grounds for exemption.
15. Wind speed and direction – If fitted, any equipment will have electrical/electronic readout. Signals will therefore be available which may be interfaced via suitable interface units. No perceived grounds for exemption.
In all cases, any replacement equipment fitted in future must provide required interface and be connected to VDR.
Recording of General Alarm: Not specifically mentioned in Code of Alarms & Indicators or VDR standards therefore not essential.
Annual Performance Check and Certification:
Agreement has been reached with UK VDR manufacturers to use a standard certificate form to which will be appended the print-out of 12 hours of data. The certificate will confirm the full working condition of the VDR and include a log of any remedial action taken.
October 2004 update: MGN 272 (M) VOYAGE DATA RECORDER’S (VDRs) – PERFORMANCE TESTING has been published and requires that Voyage Data Recorders (VDRs) should be tested after installation and then annually. The MGN gives details of those competent to do this work and lists requirements for a 12-hour print-out of data.
VDR interfacing issues
Racal Decca ARPA 2690 BT X & S band radars use “4-bit digital code which is impossible to be captured for recording” – Mick Williams Sperry 17.10.02.
However, possibility of using Litton Colour Decoder assembly to produce postdisplay RGB.
QUESTION:
Paragraph 3.3 of Annex 10 of Safety of Navigation SOLAS V states that: “The responsibility issue remains complicated but the MCA would look to the authority requesting surveyor certification (ship-owner, prime contractor or 'system integrator') to take responsibility for proving / demonstrating all aspects of the VDR system to the satisfaction of the surveyor."
Can you please clarify what is intended by "surveyor certification". Does this mean that the MCA surveyor is to issue separate certification relating to the installation tests of the VDR? Or, does the word "certification" refer to the statutory certificate issued at the satisfactory completion of a survey for the issue of a Passenger Certificate or a Cargo Ship Safety Equipment Certificate.
October 2004 update: MGN 272 (M) for further details.
REPLY:
Point 1 - the text should read "... survey or certification ....". There is no intention to issue or provide a separate certificate but the complete VDR system installation should have been tested to the Surveyor's satisfaction before the Passenger Certificate or Cargo Ship Safety Equipment Certificate is issued.
Point 2 - The surveyor may not be present throughout initial testing of the VDR but would be expected to assure himself that all elements of the VDR system have been tested after installation and that all data can be accurately recorded and reproduced. These tests should cover all elements of the system from the sensing element (eg switch activated by the bow door) through to the ability to analyse and reproduce recorded data. The owner/installer may wish to conduct a complete system trial (eg open bow door/close bow door, record times and check that reproduced data reflects these) or show evidence that the mandatory alarms have been tested as far as the bridge and then that the status of lamps on the bridge is correctly recorded/reproduced by the VDR itself.