The Automatic Identification System (AIS) fitted on board ships, as mandated by the SOLAS convention, has promoted data availability in navigation and collision prevention, as well as information transmission between ships and shore. However, using the AIS in a nonstandard way, like not keeping the device on the entire time or not updating ship’s information regularly, tends to imperil ship safety and security.

I.   Legislation and regulations

Regulation 19 of SOLAS Chapter V

2.4  All ships of 300 gross tonnage and upwards engaged on international voyages and cargo ships of 500 gross tonnage and upwards not engaged on international voyages and passenger ships irrespective of size shall be fitted with an automatic identification system (AIS).

2.4.5 AIS shall:

.1 provide automatically to appropriately equipped shore stations, other ships and aircraft information, including the ship’s identity, type, position, course, speed, navigational status and other safety-related information;

.2 receive automatically such information from similarly fitted ships;

.3 monitor and track ships; and

.4 exchange data with shore-based facilities.

2.4.6 the requirements of paragraph 2.4.5 shall not be applied to cases where international agreements, rules or standards provide for the protection of navigational information.

2.4.7 AIS shall be operated taking into account the guidelines adopted by the Organization. Ships fitted with AIS shall maintain AIS in operation at all times except where international agreements, rules or standards provide for the protection of navigational information.

IMO Resolution A.1106(29) AIS operation manual

21. Activation: AIS should always be in operation when ships are underway or at anchor. If the master believes that the continual operation of AIS might compromise the safety or security of his/her ship or where security incidents are imminent, the AIS may be switched off. Unless it would further compromise the safety or security, if the ship is operating in a mandatory ship reporting system, the master should report this action and the reason for doing so to the competent authority. Actions of this nature should always be recorded in the ship's logbook together with the reason for doing so. The master should however restart the AIS as soon as the source of danger has disappeared. If the AIS is shut down, static data and voyage-related information remains stored. Restart is done by switching on the power to the AIS unit. Ship's own data will be transmitted after a two-minute initialization period. In ports AIS operation should be in accordance with port requirements.

22. Manual input of data: The OOW should manually input the following data at the start of the voyage and whenever changes occur, using an input device such as a keyboard:

- ship's draught;

- hazardous cargo;

- departure, destination and ETA;

- route plan (way points);

- the correct navigational status; and

- short safety-related text messages.

It is recommended to use the United Nations Code for Trade and Transport Locations (UN/LOCODE) for the entry of the port of destination. In addition, it is recommended that the existing destination field be used for entering both the port of departure and the next port of call (space for 20 characters of 6 bit ASCII is available) using the UN/LOCODE.

23. Check of information: To ensure that own ship's static information is correct and up-to-date, the OOW should check the data whenever there is a reason for it. As a minimum, this should be done once per voyage or once per month, whichever is shorter. The data may be changed only on the authority of the master.

24. The OOW should also periodically check the following dynamic information:

- positions given according to WGS 84;

- speed over ground; and

- sensor information.

Regulation of the PRC on Administrative Penalties for Maritime Affairs

Article 24 In violation of the provisions of Article 9 of the Maritime Traffic Safety Law, personnel on ships and facilities fail to comply with relevant regulations and operating procedures, in accordance with Article 44 of the Maritime Traffic Safety Law and Article 56 of the Crew Regulations, shall be imposed of a fine of 1,000 to 10,000 yuan; in the event of serious violation, the person’s certificate of competency shall be detained for 6 to 24 months until the penalty is revoked. In the event of an accident, the person’s certificate of competency shall be detained or revoked according to the provisions of Article 25.

The non-compliance with the rules and regulations as mentioned in the preceding paragraph of this article includes the following situations:

(12) Failure to maintain the ship’s AIS in a normal working state in accordance with the regulations, or fail to enter accurate information in the ship’s AIS equipment in accordance with the regulations, or fail to report to the maritime authorities in time when the ship’s AIS fails.

OFAC global advisory

Deceptive Shipping Practices

Disabling Automatic Identification System (AIS): AIS is a collision avoidance system, which transmits, at a minimum, a vessel’s identification and select navigational and positional data via very high frequency (VHF) radio waves. While AIS was not specifically designed for vessel tracking, it is often used for this purpose via terrestrial and satellite receivers feeding this information to commercial ship tracking services. Ships meeting certain tonnage thresholds and engaged in international voyages are required to carry and operate AIS; however, vessels carrying petroleum to Syria have been known to intentionally disable their AIS transponders to mask their movements. This tactic can conceal the destination of cargo destined for the Government of Syria.

Vessel Name Changes: The owners of vessels that have engaged in illicit activities are known to change the name of a vessel in an attempt to obfuscate its prior illicit activities. For this reason, it is essential to research a vessel not only by name, but also by its International Maritime Organization (IMO) number.

Risk Mitigation Measures

Monitor for AIS Manipulation: Ship registries, insurers, charterers, vessel owners, or port operators should consider investigating vessels that appear to have turned off their AIS while operating in the Mediterranean and Red Seas. Any other signs of manipulating AIS transponders should be considered red flags for potential illicit activity and should be investigated fully prior to continuing to provide services to, processing transactions involving, or engaging in other activities with such vessels.

Regulation of Indonesia Ministry of Transportation

All ships sailing in Indonesian territorial waters will be required to install and activate an AIS with effect from 20 August 2019. If the AIS is not functioning, the master will be required to submit this information to the relevant authority and record the incident appropriately. Administrative sanctions may be imposed on vessels for non-compliance, such as suspension of departure approval until the AIS is installed and/or active. If a master does not activate AIS during the voyage and does not provide the correct information, an administrative sanction may be in the form of revocation of the COE.

II.   Errors in AIS operation

The Club has noticed some incorrect operation of the AIS in recent cases.

1.   The AIS device on board ship is not type-approved or certificated.

2.   Power supply of the Class A AIS transponder is not supported by an alternative one.

3.   The antennas are not tightly installed or have fallen off.

4.   The device is turned off without any justification or failures of the device are not properly recorded.

5.   The input of ship’s static and dynamic data are not correct.

6.   Ship’s information is not available to shore stations or passing ships.

7.   Key crew members are not familiar with AIS operation, like not being able to conduct tests on the device with shore stations or other ships.

III.   Risks in using AIS

Pursuant to the SOLAS convention and the IMO guidelines, the shipborne AIS should remain activated unless the operation of AIS may threaten the safety and security of ships. When and where the device is turned off as well as the reasons for doing so should be recorded in the logbook, and the device should be turned on as soon as the situation is clear. Also, owners and masters should be aware of the OFAC advisory issued on March 25th highlighting sanction risks related to ships turning off the AIS in certain areas – allegedly a deceptive shipping practice.

There’s no doubt that AIS has significantly promoted navigation safety for seafarers and facilitated ship management for owners and maritime authorities. However, it should be understood that not properly using the device may lead to certain safety risks – port authorities may file a warning for incorrect input of ship information, and penalties like a fine or a detention may be levied in PSC inspections for AIS deficiencies.

IV.    Advice to Members

Seafarers are reminded of the following operations apart from the daily maintenance and tests of the device.

1.   Every time before the voyage commences or when ship’s dynamic information changes, the OOW should manually update such data as draught, carriage of dangerous cargo, port of destination, ETA, route plan (waypoints), navigational status and short safety-related messages.

2.   In order to keep the static information updated, the OOW should check the AIS data at regular intervals – one time for every voyage or once a month at least. Alteration of such information is allowed only with the master’s authorization.

3.   The OOW should verify the dynamic information for accuracy by checking the ship’s GPS position, speed and other data synchronized by the transducers.

4.   Unless where necessary and for the safety and security of ships, the AIS should remain activated the entire time of the voyage or while at anchor. Use the device in compliance with regulations of the port authority while calling at ports.

5.   If the master decides that the continual operation of the device will compromise the safety and security of ships, the AIS may be turned off. When and where it’s turned off and the reasons for doing so should be recorded in the logbook and restart the device as soon as the source of danger disappears.

6.   When transiting in areas where mandatory ship reporting system is adopted and the AIS is switched off for safety considerations, the master should report to the authority reasons for turning of the device and write them down in the logbook.

7.   For any technical problems with the AIS, when and where the problem arises should be recorded in the logbook, ask for shore support if necessary and report to flag State administration or the port authority at the same time.

8.   When transiting in areas with enhanced risks like the Mediterranean and the Red Sea, masters should exercise caution in the status of the AIS and the accuracy of information input. Report immediately to flag State administration or the port authority when AIS signals go dark to prevent any investigation or sanction risks.

For more information, please contact your manager at the Club.