LRIT – Compliance after 31 December 2008
LRIT entered into force on 1 January 2008.
The new SOLAS regulation on long-range identification and tracking (LRIT) entered into force on 1 January 2008. This gives SOLAS Contracting Governments a year to set up and test the LRIT system infrastructure. Ship operators will be able to use this time span to start fitting the necessary equipment or upgrading so that their ships can transmit LRIT information.
The regulation in SOLAS chapter V19-1 Safety of Navigation, introduces LRIT as a:
- Mandatory requirement for the following ships on international voyages: passenger ships, cargo ships, including high-speed craft, of 300 gross tonnage and upward; and mobile offshore drilling units.
- Ships constructed on or after 31 December 2008 must be fitted with a system to transmit automatically the identity of the ship, the position of the ship (latitude and longitude) and the date and time of the position provided.
- Ships constructed before 31 December 2008 and certified for operations in sea areas A1 and A2, or A1, A2 and A3, must be fitted with the equipment not later than the first survey of the radio installation after 31 December 2008.
- Ships constructed before 31 December 2008 certified for operations in sea areas Al, A2, A3 and A4, must comply not later than the first survey of the radio installation after 1 July 2009 (but must comply by 31 December 2008 if they operate within sea areas A2 and A3).
- Ships operating exclusively in sea area A1 and fitted with an automatic identification system (AIS) are exempted from the requirement to transmit LRIT information.
The LRIT system is intended to be operational with respect to the transmission of LRIT information by ships from 31 December 2008.
Ship owners do not have to pay for the transmissions of LRIT information as these costs will be charged to the Administrations.
Ship owner obligations
It is the responsibility of the ship owner to ensure provision of a compliant terminal which should be of a type approved by the Flag (see Conformance Test) and conform to the Revised Performance Standards and functional requirements adopted by the IMO as defined in Resolution MSC.263(84).
The ship owner should be aware that there is a 20-25% probability of existing Inmarsat C GMDSS terminals are not conforming to the Performance Standards and functional requirements for a range of operational, physical and technical reasons, including: uncontrolled in-port logoff and / or power-down procedures,
- poor antenna mounting location,
- satellite line-of-sight blockage by the ship’s superstructure,
- interference from the ship’s radar,
- external wide-area radio interference in certain locations, and
- crucially the inability to meet these requirements due to out-of-date software and / or unsupported hardware.
LRIT terminals must be capable of being controlled and programmed by the Flag’s ASP and, because of the serious consequences of non-compliance, it is important that equipment performance is as reliable as possible.
Existing Inmarsat C GMDSS equipment will in most cases be technically compliant. However, full compliance with the Performance Standards and functional requirements requires that the correct operational procedures are followed on board the vessel. Ship owners are advised to regularly check that they have the latest Flag marine guidance notices in this respect. The most reliable and appropriate solution to ensure full compliance is to use a terminal that is designed to be ‘always-on’ and not capable of being reconfigured or disabled on board the vessel, and as far as is possible not affected by competing functions such as email /messaging communications. Consequently it is recommend to use an integrated Inmarsat Mini-C transceiver as the optimum LRIT terminal solution.
Ship owners have to pay for the costs to ensure that their vessels are able to transmit LRIT information.
Conformance testing should be conducted by either a recognized ASP or an authorized testing ASP. (Conformance testing will be the “type approval” evidence as long as there is no type approved equipment available)
For ships constructed on or after 31 December 2008, the conformance test should be:
- conducted after the completion of the initial survey of the radio installation, provided such survey has indicated that, as far as the radio installation is concerned, the ship meets the related requirements for the issue of a radio related certificate, and
- satisfactorily completed prior to the issue of a radio related certificate
For ships constructed before 31 December 2008, the conformance test should be:
- conducted within a period of three months prior to the date on which a ship would need to demonstrate compliance with the requirements of regulation V/19-1; and
- satisfactorily completed prior to the amendment of the record of equipment to document compliance with the requirements relating to LRIT
Such a conformance test is estimated to last at least 30 hours. This conformance test should result in a Conformance Test report which should be on board during the survey for LRIT compliance and at the renewal and annual surveys for the issue and endorsement of the relevant Certificate (Safety Equipment)
When a ship is transferred to another flag state the Conformance Test report should remain valid if the ASP, conducting the conformance test, is also recognized by the new flag state. However the ASP should reissue the Conformance test report with the new particulars of the ship.
If the ASP is not recognized by the new flag state than a new conformance test should be conducted prior to the issue of a certificate and evidence should be available on board.
In general ship owners have to pay for the Conformance Testing and ensuring the availability of Conformance Test Reports on their ships.
Ship Security Alert Systems (SSAS)
The collective industry view is that SSAS systems, with their prime purpose being that of SOLAS XI-2 Security, should not, as far as possible, be used for other regulatory purposes e.g. SOLAS V Safety.
Due to the nature of SSAS operation the most effective and reliable SSAS systems are specifically designed as a ‘closed system’; such as Inmarsat D+ based DSAS / DSAS-L and Alert products which provide a totally secure system with its programming and data use exclusively under the control of the Company Security Officer.
In contrast, because LRIT equipment must be remotely controlled and programmed by the Flag’s ASP, an LRIT system must be an ‘open system’.
For all the above reasons LRIT ASP (Application Service Provider) providers and SSAS providers, will/may not approve the use of any Inmarsat D+ based SSAS equipment for LRIT compliance.
However, an integrated Inmarsat Mini-C SSAS, whilst not the optimum design for a SSAS due to its ‘open system’ design, is acceptable for LRIT for this very reason.
Ships operating in polar Sea Area A4 above 70 degrees latitude will require a non-Inmarsat terminal that operates in conjunction with a low-earth orbit Communication Service Provider (CSP) approved by the Flag in conjunction with its appointed Application Service Provider (ASP).
The Radio Holland Group investigated the LRIT compliance of Inmarsat-C equipment fitted on board ships.
SOLAS V/19-1 Long Range Identification and Tracking
- IMO Resolution MSC.202(81)
- IMO Resolution MSC.263(84) Revised Performance Standards
- IMO Resolution MSC.211(81)
- IMO MSC.1/Circ 1257 on Guidance on Survey and Certification of compliance of ships with the requirement to transmit LRIT information
- IMO MSC.1/Circ1256 on Guidance on the implementation of the LRIT System
Further information: email@example.com or
Henk Middelkoop tel. +31 (0)10 4283325.