Annex 10 - Voyage Data Recorders (VDRs)

1. Carriage requirements

2. Download and Playback equipmen

3. Exemptions

4. System Installation Test

5. Annual Performance Check and Certification.

6. IMO Guidelines on Voyage Data Recorders (VDR) Ownership and Recovery

APPENDIX - Data to be recorded


Regulation 20: carriage of Voyage Data Recorders (VDR or S-VDR) – Timetable for fitting


Type of vessel

Date by which VDR or S-VDR must be fitted


Passenger ships constructed on or after 1 July 2002

VDR - Date of build


Ro-ro passenger ships constructed before 1 July 2002

VDR - Date of first survey on or after 1 July 2002


Passenger ships other than ro-ro constructed before 1 July 2002

VDR - 1 January 2004

20.1.4 Ships other than passenger ships of 3000 gt. and upwards constructed on or after 1 July 2002 VDR - Date of build
20.2.1 Cargo ships of 20000 gt. and upwards constructed before 1 July 2002* VDR or S-VDR** - Date of first scheduled dry docking after 1 July 2006 but not later than 1 July 2008
20.2.2 Cargo ships of 3000 gt. up to 20000 gt. constructed before 1 July 2002 * VDR or S-VDR** - Date of first scheduled dry docking after 1 July 2007 but not later than 1 July 2010

* Cargo ships built before 1 July 2002 may be exempted from requirements to carry VDR /S-VDR when they are to be taken permanently out of service within 2 years of the relevant implementation date.


** See APPENDIX to this Annex for a table of data items to be recorded by VDRs and S-VDRs.

For EU Requirements for ships on domestic voyages see paragraph 1.4

1.1)  Regulation 20 requires VDRs to be fitted to ships built on or after 1 July 2002 according to the timetable above.

1.2)  Regulation 20.2 requires cargo ships built before 1 July 2002 to be fitted with VDRs, or Simplified VDRs (S-VDR) as an alternative.

1.3)  Regulation 20.3 recognises that older ships may have difficulties in interfacing equipment with VDRs and allows Administrations to make exemptions. (See Section 3 of this Annex)



1.4 EU Council Directive 2002/59/EC (Vessel Traffic Monitoring Directive) requires all ships calling at a port of a Member State to be fitted with a VDR. This includes ships on UK domestic voyages. Ships operating only in coastal waters that are classified for domestic passenge ships as EC classes B,C or D (see Table 3 in Annex 1) may be exempted.


An amendment to the performance standards for VDRs and S-VDRs was adopted on 12 May 2006 (IMO Resolution MSC.214(81)). This requires the equipment to be fitted with an interface compatible with an internationally recognised format, so that stored data can be downloaded and played back by investigationg authorities on a portable computer.

These additional requirements for interfacing to allow download and playback apply to all VDR and S-VDR equipment fitted on or after 1 June 2008


3.1) Exemptions to Carriage Requirements (existing vessels).

3.1.1) Regulation 20.3 of SOLAS Chapter V states that: Administrations may exempt ships, other than ro-ro passenger ships, constructed before 1 July 2002 from being fitted with a VDR where it can be demonstrated that interfacing a VDR with the existing equipment on the ship is unreasonable and impracticable. However cargo ships built before 1 July 2002 must fit VDRs or S-VDRs according to the timetable in section 1 above.

3.1.2) EU Council Directive 1999/35/EC states that: For VDR's to be placed on board ro-ro ferries and high-speed passenger craft built before entry into force of the directive, exemptions for compliance with some of the requirements may be granted.

3.1.3) EU Council Directive 2002/59/EC requires that all ships calling at a port of a Member State are fitted with a Voyage Data Recorder (VDR)….. meeting the performance standards of IMO Resolution A.861(20). And that any exemptions granted to ro-ro ferries or high speed passenger craft under Article 4(1)(d) of Council Directive 1999/35/EC of 29 April 1999 on a system of mandatory surveys for the safe operation of regular ro-ro ferry and high-speed passenger craft services shall terminate on 5 August 2002. This Directive came into force in February 2004.

3.1.4) Under current proposals, there will be no exemption for early scrapping of ro-ro and passenger vessels.

3.2) Exemptions to requirement to interface to certain items of equipment.

3.2.1) There have been requests for partial exemptions for retrofitted VDRs. Technically, it is possible to interface almost any sensor to the VDR using some form of additional interface box. However cost, reliability, accuracy, degradation of sensor output and approval of such interfaces must be taken into consideration.

3.2.2) Information to be interfaced to VDRs and S-VDRs, its source and format are given in the Appendix following these notes. Equipment to be interfaced can be divided into number of categories:

3.3) Navigational equipment.

3.3.1) Most items of navigational equipment will already have the standard IEC 61162 (NMEA 0183) interface and so interfacing will be possible. For those that have some other form of electrical / electronic interface, it should be possible to interface to the VDR via an interface box.

3.3.2) In the case of a piece of navigational equipment having no electronic interface, it may be necessary to replace that equipment in order to obtain an interface. Other options may include:

3.3.3) A technical solution achieved by obtaining a suitable signal from within the equipment and converting this to the correct format, without nullifying the equipment's Type Approval.

3.4) Communications audio: Standard audio interfaces exist and are in use so interfacing, possibly with the aid of an additional buffer amplifier / mixer should not present a problem.

3.5) Bridge alarms, hull opening, watertight and fire door status.

3.5.1) As defined in the performance standard, the requirement is to record information displayed on the bridge. Bridge indicators are likely to have simple on / off status represented by closing contacts or the presence / absence of a voltage. Technically, it will not be difficult to convert such signals to the required IEC 61162 format.

3.6) Rudder and Engine (including thrusters) order and response.

3.6.1) These systems may be engineered in many ways (some not using electricity or electronics) and older systems are most unlikely to have any form of interface. New electro-mechanical sensors may need to be installed to sense mechanical positions of controls and the outputs from these sensors converted to the correct format.

3.6.2) Care will is needed when running cabling from these additional sensors to the bridge/location of the VDR to avoid causing additional problems.

3.7) Approval of Interface Boxes. IEC 61996 requires that interface boxes should meet the requirements of IEC 60945. This standard deals only with environmental and EMC issues.


4.1) The VDR, and possibly the interface boxes, will be Type Approved but to ensure the correct functioning of an installed VDR system, an overall installation test or check will be required. This will require each of the sensor inputs to be 'exercised’ in turn, information recorded and the recording analysed for accuracy. There appear to be a number of options for conducting testing including:

4.1.1) During the proving of sensor equipment - the results would be a thorough test of the system from sensor to replayed output.

4.1.2) After all sensor equipment has been proven as far as the bridge, simulating, where necessary, inputs to the VDR - will require facilities to inject or simulate inputs.

4.1.3) During functional tests of ship's equipment by a surveyor - less complex than a full methodical check but might not prove every sensor input.

4.2) Surveyor certification is achieved through witnessing a proving/demonstration (by the prime contractor/ manufacturer/ installer) of all aspects of the VDR system to the satisfaction of the surveyor.

5.) Annual Performance Check and Certification.

5.1) Regulation 18.8 of SOLAS Chapter V requires that:

The voyage data recorder system, including all sensors, shall be subjected to an annual performance test. The test shall be conducted by an approved testing or servicing facility to verify the accuracy, duration and recoverability of the recorded data. In addition, tests and inspections shall be conducted to determine the serviceability of all protective enclosures and devices fitted to aid location. A copy of the certificate of compliance issued by the testing facility, stating the date of compliance and the applicable performance standards, shall be retained on board the ship.

5.2) If interpreted literally, this could require a full check of the entire system (and sensors) which would be even more complicated than the System Installation Test (4 above). This is considered too onerous for an annual check, the essence of which is perceived to be to ensure data is recorded and replayed reliably. The following would be more appropriate:

5.3) Onboard inspection of equipment to ensure batteries, enclosures and location aids are in good condition and operational. This should be undertaken in accordance with the manufacturer's instructions by suitably qualified / experienced personnel. Successful completion of the maintenance routine should be recorded in the ship’s onboard planned maintenance log.

5.4) A 12 hour recording should cover an operational period when the majority of sensors will be exercised. E.g. arrival, disembarkation, embarkation and departure of a ro-ro ferry. Download of this recorded data or exchange of recording medium. Offline analysis of recorded data by the manufacturer’s certified representative to verify the accuracy, duration and recoverability of the recorded data. A certificate confirming the satisfactory results of this test should be retained onboard.



1.) Ownership of VDR/data:

The ship owner will, in all circumstances and at all times, own the VDR and its data. however, in the event of an accident the following guidelines would apply.

2.) Recovery of VDR:

Recovery of the VDR is conditional on the accessibility of the VDR or the data contained therein.

a.) In the case of a non-catastrophic accident, recovery of the memory should be straightforward. For example, in some VDRs it can be accomplished by removal of a hard disc from the VDR unit. This action will have to be taken soon after the accident to best preserve the relevant evidence for use by both the investigator [1] and the ship owner. As the investigator is very unlikely to be in a position to instigate this action soon enough after the accident, the owner must be responsible, through its on-board standing orders, for ensuring the timely preservation of this evidence in this circumstance.

b.) In the case of abandonment of a vessel during an emergency, masters should, where time and other responsibilities permit, recover the memory and remove it to a place of safety and preserve it until it can be passed to the investigator.

c.) In the case of a catastrophic accident, where the VDR is inaccessible and the data has not been retrieved prior to abandonment, a decision will need to be taken by the Flag State in co-operation with any other substantially interested States [2] on the viability and cost of recovering the VDR balanced against the potential use of the information. If it is decided to recover the VDR the investigator should be responsible for co-ordinating its recovery. The possibility of the capsule having sustained damage must be considered and specialist expertise will be required to ensure the best chance of recovering and preserving the evidence. In addition the assistance and co-operation of the owners, insurers and the manufacturers of the VDR and those of the protective capsule may be required.

3.) Custody of VDR/data:

In all circumstances, during the course of an investigation, the investigator should have custody of the original VDR data, perhaps in the form of the whole or part(s) of the VDR itself, in the same way as if he has custody of other records or evidence under the Code for the Investigation of Marine Casualties and Incidents.

4.) Read-out of VDR/data:

In all circumstances the responsibility to arrange down loading and read-out of the data  from the recovered memory in whatever form should, in the first instance, be undertaken by the investigator who should keep the ship owner fully informed. Additionally, specially in the case of a catastrophic accident where the memory may have sustained damage, the assistance of specialist expertise may be required to ensure the best chance of success.

5.) Access to the data:

Although the investigator will have custody of the original VDR memory in whatever form for the duration of the investigation, a copy of the data must be provided to the ship owner at an early stage in all circumstances. Further access to the data will be governed by the applicable domestic legislation of the flag state, coastal state and the lead investigating state as appropriate and the guidelines given in the Code for the Investigation of Marine Casualties and Incidents.

1. The term investigator refers to the Marine Casualty Investigator of the flag State or, where it has been agreed, under the terms of the Code for Investigation of Marine Casualties and Incidents, that another State will lead the investigation, the Marine Casualty Investigator of that State

2. Refer to resolution A 849(20) – Code for the Investigation of Marine Casualties and Incidents, para. 4.11.



IMO Performance Standard (Res. A.861(20)) and
IEC Information format (IEC 61996).

A.861(20) REF




Date & time

Preferably external to ship (e.g.GNSS)


Ship’s position

Electronic Positioning system


Speed (through water or over ground)

Ship’s SDME



Ship’s compass


Bridge Audio

1 or more bridge microphones


Comms. Audio



Radar data- post display selection

Master radar display


Water depth

Echo Sounder


Main alarms

All mandatory alarms on bridge


Rudder order & response

Steering gear & autopilot


Engine order & response

Telegraphs, controls and thrusters


Hull openings status

All mandatory status information displayed on bridge


Watertight & fire door status

All mandatory status information displayed on bridge


Acceleration & hull stresses

Hull stress and response monitoring equipment where fitted


Wind speed & direction

Anemometer when fitted


IMO Performance Standard (Res. MSC.163 (78)) and
IEC Information format (IEC 61996).

MSC.163(78) REF.
5.4.1 Date and time Preferably external to ship (e.g. GNSS)
5.4.2 Ship's position electronic positioning system
5.4.3 Speed (Through the water or over the ground) Ship's SDME
5.4.4 Heading Ship's compass
5.4.5 Bridge Audio 1 or more bridge microphones
5.4.6 Communications audio VHF communications
5.4.7 Radar data: post-display selection Master radar display
5.4.8 AIS Data

AIS to be recorded if it is impossible to record radar data.
If radar is recorded AIS may be recorded as an additional source of information.

5.4.9 Other items Additional items required for VDR (Res.A.861(20)) when interfacing available.



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