Open Letter to the Hon. François-Philippe Champagne, Minister of Innovation, Science, & Economic Development

Mariners who fall overboard, in our cold Canadian waters, face immediate and serious danger. Survival rates in a mariner overboard (MOB) situation drop precipitously as minutes tick by. The most crucial factor in survival is prompt extraction of the person from the cold water, either by their own ship or by any other vessel in the vicinity.

In recent years, engineers in many of our peer nations have developed technology to aid the identification and quick extraction of such casualties. Among the most useful (and now thoroughly proven) technology is personal MOB beacons that transmit a VHF-DSC Class M distress call, along with an AIS Class M signal, both of which include the exact GPS coordinates of the person in distress. These enable other nearby vessels to quickly respond and assist, often in less time than it would take the person’s own ship to turn around, and without wasting precious minutes on a search pattern.

In Canada, the VHF-DSC Class M component of these devices is at present not explicitly authorized. Their use is not, and cannot, be prohibited, thanks to Chapter IV Reg.1 Clause 3 of the International Convention for the Safety of Life at Sea (SOLAS):

“No provision in this chapter shall prevent the use by any ship, survival craft or person in distress, of any means at their disposal to attract attention, make known their position and obtain help.”

However, without the proper domestic regulatory frameworks, it is not possible for manufacturers and distributors to sell or program these devices in Canada.

We believe that this omission is due to the lack of international harmonization of standards in the early days of VHF-DSC and AIS technology, the potential risk of confusion from other Autonomous Maritime Radio Devices (AMRDs) such as fishnet markers, diver locating devices, etc., and the potential risk of DSC Distress signal overload that may have existed with previous, less sophisticated generations of this technology.

Those issues have now been fully resolved with VHF-DSC Class M + AIS, as harmonized in European regulation ECC/DEC/(22)02.

We have reviewed the European regulation and the standards & recommendations referenced by it, specifically ITU-R M.493[2], ITU-R M.1371[3], and ITU-R M.585[4]. We are confident that MOB beacons using VHF-DSC Class M + AIS in compliance with these existing standards are inherently and fully compatible with existing GMDSS infrastructure in Canada and can be implemented here in their already-extant form, with no technical changes, and with no risk of disruption to any existing services.

We encourage the Minister to ask ISED staff to promptly update the relevant Canadian regulations and databases to be harmonized with ECC/DEC/(22)02 and its referenced ITU standards, and to advise the marine electronics manufacturer and vendor community that MOB beacons using VHF-DSC Class M + AIS can, and should, be widely deployed to protect the lives of Canadian mariners.

This letter is submitted with best regards by Matthew Marsh, P.Eng, MASc of South Frontenac, ON and by John Harries of Hermans Island, NS, and countersigned by the following members of the Canadian and global maritime community.