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PLB instead of EPIRB - Maritime Safety Vic Viewpoint

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PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby Reeling » 23 Jan 2019, 11:07

I know there has been some discussions on here in the past regarding whether a PLB would be more appropriate than an EPIRB for kayakers. Furthermore, the hypothesis that it would be simply a matter of time before Vic Safety would change their legislation. Well I thought I would be a bit proactive and followed this up with Maritime Safety Victoria. I have now had agreement with them to circulate my discussions with you. So here it is:

To whom it may concern,

I am writing to you as an active member of Victorian Kayak Fishing community who fishes Port Phillip Bay, Western Port and Offshore. Staying safe is a top priority for me and with that, as well as always fishing with one or more individuals I ensure I carry all required safety equipment necessary.

My contact with you today is regarding the differences between an approved EPIRB vs. an unapproved GPS PLB (Personal Location Beacon) and hopefully to obtain some formal communication as to the differences that do not currently permit a PLB to be used as a direct alternative to an EPIRB. It is my understanding that both pieces of safety equipment perform very similar tasks with the following exceptions:

- EPIRB is registered to Vessel, PLB is registered to an individual
- Battery life once activated varies – PLB generally 24hrs, EPIRB 48-72hrs
- GPS accuracy – EPIRB is <2metres, although KTI stipulate on their website that “Whilst the GPS receiver has an accuracy of 1.8 metres, search-and-rescue authorities advise that the maximum accuracy they can resolve in all cases from an EPIRB is 120 metres”

Kayaking, compared to boating, is an activity where the individual is much more likely to go overboard in adverse conditions. In these conditions, it is not implausible that the individual can find themselves detached from their kayak an unable to swim back. In moderate winds (15knots) a kayak can easily drift 2-3 kph, so one can easily find themselves unable to make contact with their kayak when restricted by clothing and PFD.

In such an event, the individual does not have an opportunity to activate their EPIRB as it would be mounted to their kayak due to the size. Conversely, they would be able to activate a PLB as this will be on their person.

I would very much like to discuss the feasibility of the amendment to the offshore safety requirements for human powered vessels – kayaks and similar – where being permanently detached from one’s vessel is a very plausible issue which would render the carrying of a mandatory EPRIB inadequate.

Many individuals within the kayak fishing community hold the similar view that a PLB would make them more safe and likely to be recovered than an carrying an EPIRB and a modification to the current legislation to enable individuals to carry either/or would enhance people’s safety.

I very much look forward to hearing from you in response to my queries.

Kind Regards,

Nathan
0403 xxx xxx


Hi Nathan

Thanks for getting in touch. It is great to hear of a community of boaters that take safety seriously. One of the roles of MSV is to advise government on legislative changes that would improve the safety of waterway users in Victoria and we are happy to consider suggestions from boaters on which issues to prioritise in our considerations. The Safety Director of TSV is also able to grant exemptions when they consider that the requirement has been substantially complied with, the purpose of the requirement has been met or compliance would, in the particular circumstances, be impracticable, unnecessary or inappropriate. (Marine Safety Act 2010 Vic Sect 260).

I take your point that a worn PLB is more useful to a paddler who has been separated from their craft, than a stowed EPIRB. However the key difference that you have failed to identify is that an EPIRB is buoyant and will float in a position that allows the signal to be transmitted off the surface of the water. The main weakness of the PLB is that they do not float upright (indeed – only float if contained within a buoyant pouch), and need to be held above the water to maintain transmission of a signal.

I have attached a link to a lessons learnt article where a kayaker had trouble holding up his PLB, and the signal kept dropping in an out whenever his PLB entered the water.

We are aware that in some other states there is an allowance for light craft to carry PLB’s rather than EPIRBs or even share distress beacon between human powered craft paddling in a group. Our role is to ensure that safety of the participant is maintained ‘so far as is reasonably practicable’. I have previously paddled with an EPIRB in my grab bag in my seakayak and a PLB attached to my lifejacket. This demonstrates that it is practicable to carry both and thereby have the best features of both devices available.

Having said that – I would be happy to record your proposal for consideration when the next opportunity for legislative change arises and I would also be happy to engage with your group to discuss how an application for exemption from the requirement should be presented if you were to be asking the Safety Director to grant an exemption. Legislative changes is a process that takes a number of years, while an exemption process can sometime be finalised within 6 months.

Feel free to get in touch if you have any further questions or suggestions.

Rgds
__________________________________________________

Gareth Johnson
Manager Recreational Boating Safety

Maritime Safety Victoria
A branch of Transport Safety Victoria




Good morning Gareth,

Thank you for your prompt and thorough response.

Thank you also for highlighting the buoyancy difference which I eluded to list in my previous email. I was aware of the lack of buoyancy of a PLB. I suppose it was not something that came across as an issue as a PLB is connected to an individual and if worn high on the person – i.e. shoulder strap of a PFD where mine is permanently mounted – will have the best chance of continually transmitting. Again, please correct me if I am inaccurate in this statement. I do appreciate though, that this is inferior to the buoyancy of an EPIRB where the signal will inherently be more consistent. Buoyancy aides can be purchased for at least some of the PLB’s currently on the market.

The forum that I am an active member of, index.php, is very good at circulating all safety concerns be it near misses and kayak rescues in an aide to minimise the chances of future mishaps. The rescue that you provided a link to of the Lessons Learnt was one of the circulated articles and I would be more than happy for you to read members’ comments: viewtopic.php?f=8&t=24461&p=262693&hilit=commute%23p262693.

I am more than happy to relay our conversation on our forum, with your permission, and if at all possible, would encourage you to join the forum when the time comes to review this legislation for a more comprehensive opinion. If you do not mine, then I will also ask our community their views on whether to wait for the next review, or whetehr they would like to proceed with presenting a case for exemption to the Safety Director.

There is no doubt that it is possible for individuals to carry both PLB’s and EPIRBs. Although a price cannot be put on safety, I feel many users are tossing up between satisfying legislation and doing what they believe would give them the best chance of being rescued when they are faced with spending $300. Again, one view could be that there is no point having a floating EPIRB if it is inaccessible due to capsize or the individual is detached from their vessel.

Thank you once again,

Regards,

Nathan Wooldridge




Hi Nathan

I would be happy for you to post our conversation on your blog. We have a Prepare to Survive: Know the Five campaign on at the moment, and our next monthly message will be Carry a Distress Beacon in Feb. MSV is happy to generate discussion on these topics, so it would probably be a good time to promote this message amongst your members.

I have cc’d Jenny above who might get in touch to provide you with some content for Feb that has some good images.

Rgds

____________________________________________________

Gareth Johnson
Manager Recreational Boating Safety

Maritime Safety Victoria
A branch of Transport Safety Victoria


So it would appear to that there is no intended changes to be made to human powered vessels, namely kayaks, for enabling a PLB to be used as an equivalent alternative to an EPIRB. There is a process however by means of an exception which can be put forward for consideration.
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby peatop » 23 Jan 2019, 12:10

Good on you nath, this was one of the issues i was asking last year when looking into purchasing the safety equipment why why why? We/most of us practice re-entry who ever if at the time we can't re-enter our kayay then there is a use for the EPIRB however as you say in many cases we could get separated from our kayak, in both cases the PLB becomes useful however the EPIRB fails on seperation, i bought both as safety comes first, but i really only got the EPIRB as a requirement.

I also contacted MSV by email with regards to some retail chains selling kayaks and not informing the perspective purchases the safety requirements by law and also recommendation for what was suitable to their requirements, rather than just making a quick sale, although i got a response it wasn't as good as yours ;)

On my way back in at Barwon heads on sunday there were pwc's everywhere, i only noticed one person wearing a PFD one guy paddled right past me at the outer beacon in a ski only wearing shorts :o many around the the launch were kids in those 10ft jobs tide was still on the run out.
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby laneends » 23 Jan 2019, 13:19

One consideration is that only those who are taking going offshore would go through the expense of an EPIRB. If it wasn't a requirement more would just do it without taking offshore serious in the first place. ie it flags it as a "better take this seriously" mindset
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby Reeling » 23 Jan 2019, 13:56

laneends wrote:One consideration is that only those who are taking going offshore would go through the expense of an EPIRB. If it wasn't a requirement more would just do it without taking offshore serious in the first place. ie it flags it as a "better take this seriously" mindset


The exploration with Marine Safety Victoria was with reference to replacing the EPIRB with a PLB, not simply getting rid of the EPIRB. As you know, the current legislation is for only an EPIRB even though I believe many would feel more comfortable have a PLB - which results in them purchasing both.

Personally, I would like to see legislation replace the EPIRB with a PLB and amend it to any tidal waters - not just offshore
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby maverick » 23 Jan 2019, 14:31

MSV were investigating the use the PFD with shoulder holders for the PLB so they remained vertical and out of the water. SLH was looking into importing them. I must follow up.
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby laneends » 23 Jan 2019, 14:37

Agree with expading situations at least when plb should be required. Even a couple kms out in the bay and you could be in deep poo. Even my leak out at bouchiers could have serious if it was bigger and i was on my own with no means communication. Cant rely on phone out there.

Maybe if they add a proviso that it needs to have form of floatation.

Tip out of you kayak while at anchor in high tide and an EPIRB is of no use as you drift away.

Some kind of flotation aid and tether that you could use once you set off a plb would not be a bad idea, regardless of where you are would help with signal loss issue raised.
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby peatop » 23 Jan 2019, 16:58

Nath although your idea of having a PLB for tidal waters and offshore is good it would have to have conditions somewhat like the current ones, as there are many people who buy small and larger yaks just for close to shore play, then there is also sup users, the difficulty would be how to set the boundaries, tbh i think if you use a PWC for fishing you should have a PLB and flares wouldn't be a bad idea as well, now i have all my safety equipment, its always on board and in serviceable condition, as for it's location i will be asking advice on this friday when i receive my new PFD.
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby Reeling » 23 Jan 2019, 17:54

Peter, they have regulations for intertidal fishing and 400m distance requirements for SUPs to wear pfd so could easily tag the PLB/EPIRB legislation on the back of the 400m requirement
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Re: PLB instead of EPIRB - Maritime Safety Vic Viewpoint

Postby peatop » 23 Jan 2019, 18:14

Reeling wrote:Peter, they have regulations for intertidal fishing and 400m distance requirements for SUPs to wear pfd so could easily tag the PLB/EPIRB legislation on the back of the 400m requirement

True, i don't know about laws for sup ;)
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