FCC Mandatory Sticker
Since my first boat which included a DSC-capable VHF marine radio I’ve been wondering about the warning sticker that came with the radio. The manual for my Icom M506 VHF has the warning:
A WARNING STICKER is supplied with the U.S.A. version
To comply with FCC regulations, this sticker must be affixed in
such a location as to be readily seen from the operating controls
of the radio as in the diagram below. Make sure the chosen
location is clean and dry before applying the sticker.
Other radios have similar stickers and warnings in their manuals.
While I’m all for complying with regulations, I find it a bit annoying that the actual regulation (if any) isn’t cited so that I could see if, indeed, it’s necessary to mess up my helm with extra stickers. A quick review of boating blogs wasn’t very helpful – I didn’t find the regulation cited anyplace – just several people commenting on whether or not it’s needed, and a few saying that it was necessary to pass a Coast Guard safety check.
So, I did some research into the FCC regulations (47 CFR 80 contains the regulations for marine radios).
Success. In 47 CFR §80.225(b) it states:
(b) Manufacturers of Class C DSC equipment to be used on United States vessels must affix a clearly discernible permanent plate or label visible from the operating controls containing the following:
Warning. This equipment is designed to generate a digital maritime distress and safety signal to facilitate search and rescue. To be effective as a safety device, this equipment must be used only within communication range of a shore-based VHF marine channel 70 distress and safety watch system. The range of the signal may vary but under normal conditions should be approximately 20 nautical miles.
Now, this section specifically states that the requirement applies to “Class C DSC” equipment. Indeed, the only place in Part 80 of the FCC regulations that appears to apply to the mandatory label applies to “Class C DSC.” So, logically, I needed to look up what constitutes “Class C DSC.” A quick search on “Class C DSC” brought me to the USCG Navigation Center where the various classes of Digital Selective Calling are described.
Guess what? No Class C is defined!
It turns out that Class C is a specification that was withdrawn by the International Maritime Organization (IMO). While some early radios, like the Icom M58, were Class C, those radios have been superseded by other radios. For example, my M506 and M424 are Class D DSC and my M802 is Class E DSC (and the M802 does not have the warning).
So, according to the FCC regulations, since these are not Class C, there really appears to be no requirement for the warning sticker. The technical reason Class C DSC has been discontinued is that in a Class C DSC radio, a single receiver section is time shared between channel 70 and whatever other channel the receiver is tuned to. This makes it possible to miss a DSC call if the receiver was switched to the other channel when the DSC call came in. In Class D radios, this time sharing goes away because there are two receiver sections in a Class D radio. One receiver is always monitoring channel 70, so a DSC call can’t be missed due to a shared receiver switching channels.
This detail makes the FCC warning make more (but not complete) sense. The warning states: “To be effective as a safety device, this equipment must be used only within communication range of a shore-based VHF marine channel 70 distress and safety watch system.” (emphasis added). What this means is that other boats in your area, with class C devices, might not be listening to channel 70 at the time you make your call, so your distress call will go unanswered. In contrast, if your near a shore station, those stations would have dedicated channel 70 receivers and are guaranteed to hear your call if you’re within range.
Of course, the same situation would exist with a Class D DSC radio if you’re out of range of both shore and any other boats (or if a boat that’s in range has a Class C DSC and your call comes in at the wrong time). So, the logic that applies to Class C DSC radios would still apply to Class D DSC radios meaning that while the sticker does not appear to be required by regulation for a Class D radio, the effectiveness of the radio as a safety device will be better if you’re within range of a shore station. That may be why radio manufacturers still include the sticker, even for Class D radios in an overabundance of caution.
Of course, if the Coast Guard boards you and wants to see the sticker (for reasons that wouldn’t be clear), it’s probably not the right time to explain the nuances of FCC, IMO and ITU regulations. However, like far too many things in today’s society, the path of least resistance would be to put the apparently unnecessary sticker on the helm and save the cost and aggravation of a legal fight.
Also, don’t confuse the FCC-required sticker with the nifty colored “VHF Radio Call Sticker” that gets passed around at safe boating classes. Some voluntary safety inspectors seem to think that this is the sticker required by the FCC. While that sticker has radio procedure information on it, it is not the FCC-required sticker for Class C DSC radios. If you’re going worry about the “FCC regulations require” warning in your manual, at least make sure your sticker has the FCC-required text on it!
Bottom line – if you’re in distress, push the button.