To assist in casualty investigations, ships engaged on international voyages show be fitted with a VDR as follows:
1.1 passenger ships constructed on or after 1 July 2002;
1.2 ro-ro passenger ships constructed before 1 July 2002 not later than the first survey on or after 1 July 2002;
1.3 passenger ships other than ro-ro passenger ships constructed before 1 July 2002 not later than 1 January 2004; and
1.4 ships, other than passenger ships, of 3,000 gross tonnage and upwards constructed on or after 1 July 2002.
The mandatory regulations are contained in chapter V of SOLAS.
Regulation of SOLAS Chapter V States
“The voyage data recorder (VDR) system, including all sensors, shall be subjected to an annual performance test. A copy of the certificate of compliance issued by the testing facility, stating the date of compliance and the applicable performance standards, shall be retained on board the ship.”
If interpreted literally, this could require a full check of the entire system (and sensors) which would be even more complicated than the System Installation Test. This is considered too onerous for an annual check, the essence of which is perceived to be to ensure data is recorded and replayed reliably. The following would be more appropriate:
“Onboard inspection of equipment to ensure batteries, enclosures and location aids are in good condition and operational. This should be undertaken in accordance with the manufacturer’s instructions by suitably qualified / experienced personnel. Successful completion of the maintenance routine should be recorded in the ship’s onboard planned maintenance log.”
To assist in casualty investigations cargo ships when engaged on international voyages shall be fitted with a VDR which may be a S VDR (simplified voyage data recorder) as follows:
- In the case of cargo ships of 20,000 gross tonnage and upwards constructed before 1 July 2002, at the first scheduled dry-docking after 1 July 2006 but not later than 1 July 2009;in the case of cargo ships of 3,000 gross tonnage and upwards but less than 20,000 gross tonnage constructed before 1 July 2002, at the first scheduled dry-docking after 1 July 2007 but not later than 1 July 2010; and
- Administrations may exempt cargo ships from the application of the requirements when such ships will be taken permanently out of service within two years after the implementation date specified above.