Dear ISAF Oceanic Committee member,
Chairman Bruce Eissner asked me to circulate recent correspondence regarding
ISAF and the International Maritime Organisation, some of you will already
have received these papers and correspondence.
Michael Devonshire as Chairman of the ISAF International Regulations
Committee is co-ordinating a UK-based panel which is attending IMO meetings
and includes David Arnold and Alan Green.
The three documents below are:
A - Note by Government of Australia to IMO
B - Message from Alan Green to Michael Devonshire 27 May 99
C- Submission by ISAF to IMO regarding note by Government of Australia
____________________________________________________________________________
A - Note by Government of Australia
SUB-COMMITTEE ON COMSAR 4/8/7
RADIOCOMMUNICATIONS AND SEARCH 12 April 1999
AND RESCUE Original: ENGLISH
4th session
Agenda item 8
MATTERS CONCERNING SEARCH AND RESCUE, INCLUDING THOSE RELATED TO THE 1979 SAR CONFERENCE AND THE INTRODUCTION OF THE GMDSS
Mutual responsibility and the International Convention on Maritime Search and Rescue, 1979
Note by Australia
SUMMARY
Executive summary: Race organisers share the responsibility for vessel safety.
Action to be taken: Paragraph 7
Related documents: The 1979 International Convention on Maritime SAR and amendments
Introduction
The International Convention on Maritime Search and Rescue, 1979 applies to all persons in distress at sea. Parties to the Convention 'shall ensure that assistance be provided to any person in distress at sea. They shall do so regardless of the nationality or the status of such a person or the circumstances in which that person is found (2.1.10).
Yacht races and other activities involving high risk
2 In recent years there has been an increase in the number of'around-the-world' yacht races and balloon flights resulting in the need for rescue. Many of these events involve vessels which are designed for maximum performance rather than for safety. Yacht races which seek the shortest and fastest route use tracks which run deep into the southern oceans. These regions are a significant challenge for any country's SAR resources.
Mutual Obligations
3 It is Australia's view that organisers of such events have a responsibility to closely liaise with the SAR agencies of the search and rescue regions (SRRs) through which their event will transit. The planned track and associated waypoints should give weight to the available SAR resources. Wherever possible the event should be staged to allow for rescue by other vessels in the same event. Where this is not possible, such as non-stop races, the route should be agreed with the relevant SAR
authorities. Race organisers should liaise with SAR agencies as necessary to provide regular position reports. This is often done via the Internet. COMSAR 4/8/7 -2-
4 There are numerous safety precautions which should be the
responsibility of the race organisers. Vessels should be fitted with multiple communications and distress alerting systems and wherever possible achieve GMDSS compatibility. Planning should take account of capsize and the potential shielding of distress systems by carbon-fibre hulls and similar materials.
5 Other lessons learnt from ocean racing in Australian waters include the following:
.1 yacht colour is important, white is hard to see in high sea states, yellow or orange is a better choice, including for the bottom of the hull;
.2 for large ocean areas, EPIRBs with homing frequencies are appropriate, coded EPIRB identities should be advised to all relevant RCCs and consideration should be given to distress beacons which incorporate QPS;
.3 individuals might carry PLBs as well as the boat being fitted with EPIRBs;
.4 appropriate survival gear is essential and this should include full immersion suits for southern regions;
.5 waterproof portable VHF channel 16-capable radios and VHF aviation frequency-capable radios (121.5 MHz and 123.1 MHz) should be considered for communications with SAR aircraft;
.6 life raft construction and quality is important. Those which employ a toroidal skirt for stability are considered the most serviceable;
.7 a man overboard' is hard to detect from the air. Clothing might be coloured yellow or orange, watch-keepers on deck, particularly at night, might carry a survival pack on their person containing items such as strobe lights, day/night flares, sea-dye, and other signalling devices;
.8 race participants should have survival training and pre-race briefs should include details of SAR arrangements in areas they plan to transit; and
.9 race organisers should keep details of the survival gear carried on each vessel including details of liferaft make and model.
Conclusion
6 Whilst Parties to the International Convention on Maritime Search and Rescue, 1979 accept their responsibilities to rescue 'any person at sea within their SRR, there should also be recognition of the mutual responsibility placed upon race organisers to liaise closely with the relevant SAR agencies during the planning and execution of these events.
Action requested of the Sub-Committee
7 The Sub-Committee is invited to note the information provided in this document and to request Member States to take action as appropriate.
B
Message from Alan Green to Michael Devonshire
Date: 5/27/99 6:00 PM
RE: ISAF at IMO
Dear Michael
IMO sub-committee on COMSAR - observations from Australia.
Whilst having respect, sympathy and appreciation for SAR authorities I think we must be extremely careful NOT to hand over the rights to decide where and how racing is conducted, to them. In fact this is not what the Australians have suggested -they only asked for "close liaison" -and I have no problem with that.
As an example of existing cooperation, on the RORC Special Regulations committee I have permanent representation from both MCA (Marine and Coastguard Agency) and RNLI (Royal National Lifeboat Institution). (Names in brackets in case this note is circulated to sailors outside UK). All RORC races are conducted in close cooperation with the coastguard at an operational level.
In world-girdling races going through the Southern Ocean "multiple communications" are the norm. From my experience of Whitbread (Volvo), BT Global Challenge and its forerunner the British Steel Challenge, also from my knowledge of some of the FICO events, boats in those would typically carry INMARSAT-C as a staple, possibly with a second C terminal or an A or B, or possibly with an SSB radio. Often they would have one or even two Argos beacons which offer limited emergency coded signals as well asdistress alerts and routinely, position reporting. I would say that all
would carry VHF .
Under ORC Special Regulations category zero boats are required to have:- 3.24 (e) -a waterproof hand-held VHF transceiver 4.18(a)-an EPIRB 4.18(b) and 5.07(b)-a PLB for each person with suitable on-board D/F equipment
5.07 (a)-an immersion suit for each person -attention drawn to PrEN 1913
5.03-personal location lights (mini flares or strobe lights) for each person
In the BT and Whitbread (Volvo) races certainly full records are kept of all safety gear on board each boat. In ordinary RORC races we have access to liferaft numbers and crew details, and in the Fastnet and other long-distance races, keep the data at race HQ.
I do not know of any race organisation that requires an aviation VHF or UHF comms set on board: most air-sea rescue aircraft nowadays seem to be equipped to use marine VHF channel 16 but perhaps this is not always the case.
The "toroidal skirt" superiority is a new one on me. I would like to know more about this as no doubt would the working party on ISO 9650 liferafts.
In FICO races it is now a normal requirement for underwater appendages to be painted fluorescent orange. This idea is under study for the next Volvo Race, as also is the idea to have all foul-weather gear a bright yellow or orange colour.
Training for survival situations is receiving active planning in the Volvo Race safety committee and some training is routinely included for crews on the BTGC race. I have no doubt that the sailing community could do more work in this area.
To summarise, I think we sailors should always be ready to discuss safety techniques and equipment, especially with professional safety agencies, but that at the end of the day we must look after our own show. Provided that we do it properly I can see no reason for any closer involvement and would strongly resist giving up our decision-making authority over what we do.
Alan Green, ISAF at IMO team.
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C -
From: HHJ Devonshire [[email protected]]
Sent: 15 June 1999 19:21
To: Simon
Subject: IMO
The following documents are submitted to IMO on behalf of the International Sailing Federation (ISAF).
M N Devonshire - Chairman ISAF International Regulations Committee
SUB-COMMITTEE ON COMSAR 4/8/7 RADIOCOMMUNICATIONS AND SEARCH AND RESCUE
4th session Agenda item 8
MATTERS CONCERNING SEARCH AND RESCUE, INCLUDING THOSE RELATED TO THE 1979 SAR CONFERENCE AND THE INTRODUCTION OF THE GMDSS
Mutual responsibility and the International Convention on Maritime Search
and Rescue, 1979
Note by the International Sailing Federation
SUMMARY
Executive Summary: This document comments on the information which is contained in the Note by the Government of Australia and explains the steps which the International Sailing Federation is taking to improve the safety of vessels participating in long distance yacht races. Action to betaken: Paragraph 5.
Related Documents: COMSAR 4/8/7
Introduction
1. The International Sailing Federation (ISAF),as the World Governing body for the Sport of Sailing, has for some time recognised the increased interest amongst sailors in long distance yacht races. These have increased in number of events, in the size of participation and in public attention. It recognises that long distance racing brings with it risks.
Those risks participants accept as have mariners throughout the ages. It also recognises that such events should not impose unreasonable burdens on the SAR agencies of the search and rescue regions through which the events transit. It believes that the key to a reduction in risk is the education of organisers and participants.
Steps taken by ISAF
2. In 1997 it convened a major conference of organisers and participants from the major yachting nations to discuss safety and to pool experience.As a result of this conference it crated an Oceanic Committee to advise on the organisation of long distance races with a wide spread of membership.
3. The Offshore Racing Council, a member of ISAF, has for many years published Special Regulations for the Equipment of Yachts which participate in Races offshore. These classify Races by the type of waters in which the event is held and are updated at least annually to takeaccount of recent experience and the development in equipment design.
These regulations already require that each boat participating in long distance ocean races should carry:
2.
1. In addition to fixed communication equipment a waterproof hand-held VHF transceiver. 2. An EPIRB 3. An PLB for each person on board with suitable on-board D/F equipment 4. An immersion suit and personal location light (mini flares or strobe lights) for each person .
Records of safety equipment on board should routinely be maintained by organisers. It is the experience of ISAF that aircraft used for air-sea rescue operate on marine channels. It would seem to be onerous to require yachts to be equipped to a higher standard than other ships.
3. It worthy of note that races held in the last 12 months have been routed on a more northerly course in the Southern Oceans.
Conclusion
4. ISAF welcomes the comments of the Government of Australia and the lessons which it seeks to draw from recent events in the Southern Oceans.
It will take every step in its power to draw the points which have been made to the attention of Race Organisers and to encourage proper liaison with the relevant SAR agencies.
Action requested of the Sub-Committee
5. The Sub-Committee is invited to note the actions already taken and to be taken by ISAF.
SUB COMMITTEE ON SAFETY OF NAVIGATION 45th Session Agenda Item 5
WORK PROGRAMME
Consideration of Amendments to the International Regulations for Preventing Collisions at Sea 1972
Submitted by the International Sailing Federation (ISAF)
Executive Summary This paper continues consideration of amendments to the Regulations concerning whistles bells and lights in the International Regulations for Preventing Collisions at Sea I 972.
Action to be taken See Paragraph 5
Related Documents MSC 69/20/4 19 December 1997 Japan
1. Introduction
1.1 Japan noted in Document MSC 69/20/4 a) increasing international trade in yachts and pleasure boats and b) strong discontent with the whistles and bells required by current COLREGS due to their size and weight shown by many owners of such vessels c) that the so-called tricolour light is more easily seen than sidelights in a small vessel but is not permitted on vessels sailing which are also propelled by machinery
1.2 Japan further noted that many yachts and pleasure boats as made and sold are not fitted with compliant whistles and bells and must subsequently be modified by their owners. This is a barrier to trade in small vessels and probably occurs through adoption by the originating countries of local modifications to current COLREGS permitted under Rule
1(b)
1 3 The views of Japan are based on those of a domestic committee established to consider and inquire widely into the matter.
l 4 The International Sailing Federation confirms the view that owners and users of yachts and pleasure boats are discontent regarding whistles and bells and would extend this to include owners and users of all forms of recreational craft. Additionally it should be noted that many such vessels are marketed internationally without any formal provision for making sound-signals.
Whistles
2.1 ISAF confirms that whistles complying with the current ColRegs are too large for the space available in small recreational craft and are too heavy in relation to overall displacement. Furthermore such whistles are difficult to fit and operate satisfactorily and under some circumstances may be dangerous on small sailing vessels. It is the experience of the United States governing bodies for recreational craft that the higher frequency devices locally permitted obviate some of these problems and have the same practical audibility and general effectiveness as COLREG-compliant whistles.
2.2 ISAF therefore supports the draft amendments to ColRegs suggested in Annex I of MSC 69/20/4 to allow the use of higher audio frequencies for vessels under 2Om in length.
3 Bells
3.1 ISAF also confirms that few recreational craft under 20m carry bells to COLREG specification and that this is due to lack of easily accessible stowage accommodation, difficulty in use and a perceived lack of need in practical circumstances. 3.2 ISAF concurs with the analysis and conclusion presented by Japan that installation of bells compliant with the ColRegs on craft under 20m in length is not necessary and that alternative means of communication are generally available.
3.3 ISAF therefore supports the draft amendments to ColRegs suggested in Annex 2 of MSC/69/2O/4 for recreational craft under 20m in length.
4 Lights
4.1 Document MSC 69/20/4 argues that exhibition of a white red and green light combined in one lantern at or near the top of the mast (the so-called tricolour light) is more easily seen by other vessels than sidelights placed on the hull near the surface of the sea. and therefore should be available to sailing vessels when also being propelled by machinery.
4.2 The tncolour light is a very practical light for small sailing vessels which often have problems in providing sufficient power for other lights prescribed by the Rules. However there can be problems with tricolour lights on small vessels navigating inshore being difficult to observe or being confused with shore lights and even with stars when viewed from the low eye-level of other small vessels.
4.4 For the reasons given at 4.2 above it is important to retain the alternative arrangements for lights permitted under Rule 25 (a)(sidelights and sternlight) to indicate a sailing vessel underway.
45 Such a vessel when also propelled by machinery will additionally display a masthead light forward and appear as a conventional power-driven vessel. Due to the leeway induced in such vessels by the effects of the wind their track may be significantly different from their heading withoutthis being immediately evident.
4.6 The use of a tricolour light with no other navigation lights by a small vessel propelled by machinery will cause confusion. It would not be possible for another vessel to determine easily the course of such avessel.
4.5 A sailing vessel underway may display the lights described at Rule 25(c) (red over green at masthead). It should be noted that such vessels may have rotating masts thereby making the use of a tricolour undesirable and any proposals should continue to permit the use of the rule 25(c) lights. This use should be considered when considering the possibility of confusion with other prescribed lights.
4.6 ISAF has noted with concern proposals recently discussed at a working Group of the International Standards Organisation for a standard for navigation lights on recreational craft which would permit visibility ranges lower than those contained in COLREGS. It suggests that there should be one standard only, that contained in Annex 1 to the COLREGS.
Action to be taken 5.1 ISAF fully supports the recommendation of MSC 69/20/4 that questions of whistles bells and motor-sailing lights for small craft should be considered immediately by the appropriate Sub-Committee.
