Applicability:  shipowners, ship operators, ship managers, ship masters, designers and shipbuilders.

What should shipowners and ship managers do now?

Shipowners and ship managers should ensure that Voyage data recorders (S-VDRs/VDRs) and Emergency Position-Indicating Radio Beacons (EPIRBs) due to be installed on or after 1 July 2022* are approved to the latest performance standards.The testing and maintenance of EPIRBs should also be done according to the latest guidelines, particularly for GNSS/AIS enabled EPIRBs. 


Float-Free EPIRBs form an important part of the GMDSS equipment on sea-going vessels.

The IMO has published Resolution MSC.471(101), which contains a revised performance standard for EPIRBs aimed at further improving the capability of these devices to assist in distress alerting and locating.

The main updates in the new performance standard are mandatory requirements for the beacon to include a global navigation satellite system (GNSS) receiver (e.g. GPS, GLONASS) and an Automatic Identification System (AIS) transmitter, so that the beacon’s emergency signal includes a position fix and AIS locating signal.

EPIRBs installed on or after 1 July 2022* are required to be type approved to the new performance standard.

*For application of resolution MSC.471(101), the phrase “installed on or after 1 July 2022” has been interpreted by IACS as follows:

  1. for ships for which the building contract is placed on or after 1 July 2022, or in the absence of the contract, constructed on or after 1 July 2022, "installed on or after 1 July 2022" means any installation on the ship; and
  2. for ships other than those ships prescribed in (1) above, "installed on or after 1 July 2022" means a contractual delivery date for the equipment or, in the absence of a contractual delivery date, the actual delivery of the equipment to the ship on or after 1 July 2022.

As a result of the new performance standard, the IMO has revised the following guidance documents relating to testing and maintenance of EPIRBs to include requirements for the new GNSS/AIS enabled EPIRBs:


VDRs are the equivalent of an airplane’s ‘black box’ equipment carried on sea-going vessels.

The update to the EPIRB performance standard has had a knock-on effect on the IMO’s VDR and S-VDR performance standards, as the VDR’s float-free data capsule is required to meet the requirements of the latest EPIRB performance standard.

VDRs installed on or after 1 July 2022*, are to be approved to IMO Resolution MSC.333(90), as amended by MSC.494(104). Similarly, S-VDRs installed on or after 1 July 2022*, are to be approved to IMO Resolution MSC.163(78), as amended by resolution MSC.214(81) and MSC.493(104).

A useful summary table of SOLAS Requirements for Maintenance Servicing, Testing and Drills can be found here.

For more details, please contact your local LR office or

Download PDF version of Class News 06/2022