3.3 Miscellaneous Rules and International Carriage (Key Topic 6)

3.3 Miscellaneous Rules and International Carriage (Key Topic 6)

Key Topics 4 and 5 stay inside the logbook. Key Topic 6 steps onto the bridge and into international waters. This OpenExamPrep section helps learners study six Element 1 facts that still appear as one exam item among the six Rules-and-Regulations questions: which rules apply offshore, who may speak on the microphone, where a GMDSS inspection application is filed on the pool, who has ultimate control, where the principal radiotelephone must sit, and which ships must carry radio for safety of life at sea. Current Part 80 supplies the same answers on control, carriage, operating position, and unlicensed speakers, with one inspection-procedure update that candidates should know without dropping the pool fact.

International waters: Part 80 plus the ITU Radio Regulations

47 CFR 80.86 is short and enough for the exam. In addition to being regulated by Part 80, the use and operation of stations subject to Part 80 are governed by the Radio Regulations and the radio provisions of all other international agreements in force to which the United States is a party. For a U.S.-licensed ship station in international waters, Element 1 states that as Part 80 of the FCC Rules plus the international Radio Regulations and agreements to which the United States is a party.

That pair is the tested combination. It is not “IMO personnel rules and a radio officers' union.” It is not a free-standing set of ITU “Maritime Mobile Directives” that replace Part 80. It is not a stack of desk instructions from a Washington, DC bureau office standing alone. Crossing the 12-nautical-mile line does not turn the MP holder into an unregulated operator, and it does not let the operator ignore ITU distress, identification, and watchkeeping rules that the United States has accepted.

In practice the two layers work together. Part 80 tells a U.S. ship how the Commission will enforce maritime radio in and under U.S. jurisdiction, including logkeeping, operator licensing, and technical standards. The ITU Radio Regulations supply the international frequency table, the meaning of distress, urgency, and safety signals, and the duties of stations in the maritime mobile service. When those texts overlap, a U.S. operator follows both. When the ship visits a foreign port, 80.79 still allows that government to inspect the radio installation against the Radio Regulations. Carry the station license and be ready to produce it.

Who may speak over the transmitter

An unlicensed person may speak over a ship radio only under the supervision of the licensed operator. Element 1 rejects “never, under any circumstances,” rejects a 200-watt PEP power exception, and rejects “while the radio officer is off duty” as a standing permission. Supervision means the licensed operator is in control of the station: present, able to take the microphone, and responsible for frequency, power, identification, and content.

47 CFR 80.156 states the current U.S. rule in operator-license language. On ships required to have a holder of a commercial operator license or permit on board, the operator may, if authorized by the station licensee or master, permit an unlicensed person to modulate the transmitting apparatus for all modes of communication except Morse code radiotelegraphy. The MP holder does not abandon the circuit. A passenger greeting family on a public-correspondence channel, a master giving a navigational report, or a medical person describing symptoms can talk into the microphone while the licensed operator remains in charge of the transmitter. Morse telegraphy is not part of that permission.

Do not confuse this microphone rule with the maintenance rule in Key Topic 4. An unlicensed speaker under supervision is not the person who signs a service log as the operator responsible for maintenance. Do not confuse it with voluntary domestic VHF operated license-by-rule on a recreational boat; this Key Topic 6 fact is about ships that must have a commercial operator on board.

GMDSS inspection: pool filing address and current Part 80 path

The 2009 Element 1 pool still asks where you make an application for inspection of a ship GMDSS radio station. The tested answer is the FCC Engineer-in-Charge of the FCC District Office nearest the proposed place of inspection. It is not a COLEM, not FCC headquarters in Washington, DC as the filing office, and not an FCC-licensed GMDSS maintainer acting as the application addressee. Memorize that pool answer. It is still how the live exam item is keyed.

Current 47 CFR 80.59 takes a different operational path that an MP holder should also know for real ships. The Commission will not normally conduct the required inspections of ships subject to Part II or III of Title III of the Communications Act or the Safety Convention. There are no FCC prior-notice requirements for those inspections. A mandatory inspection of a U.S. GMDSS ship is conducted by an FCC-licensed technician holding a GMDSS Radio Maintainer's License. 80.1067 requires that inspection at least once every 12 months. If the ship passes, the technician issues a Safety Certificate. The technician must not be the vessel's owner, operator, master, or their employee or affiliate. The inspecting technician certifies in the log, and the owner, operator, or master also certifies that the inspection was satisfactory.

Study both sentences without mixing the addressees. On the exam, the application goes to the Engineer-in-Charge of the nearest district office. On a 2026 dock, you hire a qualified GMDSS maintainer, you do not file a prior-notice application with that district office under current 80.59, and you still log the inspection under 80.409(e)(13) and 80.409(f). Passenger vessels on an international voyage have an extra current step: the inspecting technician must send a completed FCC Form 806 to the Officer in Charge, Marine Safety Office, U.S. Coast Guard, in the Marine Inspection Zone where the ship is inspected.

The master has ultimate control

47 CFR 80.114(a) is the control rule. The service of each ship station must at all times be under the ultimate control of the master, who must require that each operator of the station comply with the Radio Regulations in force and that the ship station is used in accordance with those regulations. Element 1 states the same fact: the master of the ship has ultimate control of service at the ship's radio station.

Ultimate control is not a First Class radiotelegraph certificate with a sea-service endorsement, not a “radio officer-in-charge” invented by the captain as a substitute for the master, and not an appointed operator who merely promises to follow the Radio Regulations. The licensed operator runs the circuit. The master can order the station used, unused, or used in a particular way, including whether an unlicensed person may speak under 80.156. That is why Key Topic 4 can assign log maintenance to the licensee and the operator in charge without taking the radio away from the master's authority. If equipment is improperly operating, 80.409(e)(10) still requires notifying the master and logging that notice.

Principal radiotelephone operating position

Element 1 places the principal radiotelephone operating position in the room from which the ship is normally steered while at sea, or in an adjoining room. It is not a circular “principal radio operating position” defined only by a label. It is not a free choice among chart room, master's quarters, or wheelhouse. It is not “main wheelhouse level or one deck above the main deck” as a substitute for the steering-room rule.

Current 47 CFR 80.853(d) (compulsory radiotelephone ships under Subpart R) states that the principal operating position must be in the room from which the ship is normally steered while at sea. On cargo ships of 300 gross tons and upwards but less than 500 gross tons with keel laid before January 1, 1965, the principal operating controls may be in a room adjoining and opening into the steering room. If the station can be operated from any other location, a positive means must be provided at the principal operating position to take full control of the station. 80.853(c) separately requires the radiotelephone station and necessary controls to be located at the level of the main wheelhouse or at least one deck above the main deck — that is a deck-height rule, not the definition of the principal operating position. 80.907 (small passenger vessels over 100 gross tons) likewise puts the principal operating position in the room from which the vessel is normally steered while at sea, with the same take-control requirement for remote positions.

The exam's “room or adjoining room” wording matches the steering-room rule plus the adjoining-room exception. Put the working microphone where the ship is actually conned, or immediately next to that space with a door into it on the old-tonnage exception, and make sure a remote wing or after-steering radio can be seized from that principal position.

SOLAS radio carriage: 300 GT cargo and more than 12 passengers

By international agreement, ships that must carry radio equipment for the safety of life at sea are cargo ships of more than 300 gross tons and vessels carrying more than 12 passengers. That is the Element 1 carriage pair. It is not “every ship more than 100 miles out,” not “cargo ships over 100 gross tons plus deep-sea passenger ships,” and not “all cargo ships over 100 gross tons.”

Current 47 CFR 80.1065(a) applies GMDSS Subpart W to all passenger ships regardless of size and cargo ships of 300 tons gross tonnage and upwards. SOLAS treats a passenger ship as a ship carrying more than 12 passengers; the pool uses that passenger threshold in so many words. 80.1065(b) does not wipe out Great Lakes (Subpart T) or small-passenger (Subpart S / Communications Act Part III) radio rules. Those fleets still have their own carriage and inspection schemes. 80.1065(c) preserves the right of any ship, survival craft, or person in distress to use any means to attract attention and obtain help.

Do not confuse SOLAS's more than 12 passengers with the Marine Radio Operator Permit trigger for certain U.S. vessels carrying more than six passengers for hire in the open sea or U.S. tidewater, which is a licensing fact from Chapter 1, not the SOLAS carriage pair. Do not substitute 100 GT for 300 GT. The safety-of-life radio obligation that Element 1 tests is the 300 GT cargo / more-than-12-passenger pair.

Taken together, Key Topic 6 is the authority map around the logbook: international rules ride with Part 80, the licensed operator supervises the microphone, the master commands the service, the radio lives at the conning position, SOLAS names which ships must carry the equipment, and the inspection question still points at the Engineer-in-Charge even though today's inspections are performed by licensed GMDSS maintainers.