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Author Topic:   Mandatory FCC Warning Label
jimh posted 12-26-2008 11:07 AM ET (US)   Profile for jimh   Send Email to jimh  
When you buy a VHF Marine Band Radio with Class-D DSC capabilities there is a special warning sticker that is included with the radio. The sticker comes with these instructions:

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WARNING STICKER ATTACHMENT
To comply with FCC regulations, this sticker must be affixed in such a location as to be readily seen from the operating controls of the radio. Make sure the chosen location is clean and dry before applying the sticker.

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The sticker itself has this text:
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WARNING
This equipment is designed to generate a digital maritime distress and safety signal to facilitate search and rescue. To be effective as a safety device, this equipment must be used only within communication range of a shore-based VHF marine channel 70 distress and safety watch system. The range of the signal may vary but under normal conditions should be approximately 20 miles.

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Imagine someone in a distress situation and considering use of the radio. Would they bother to take the time to read the warning label? If they did read the label, after reading the label, would they feel inclined to not use the radio to summon help because they were more than 20-miles from shore?

I can't really see any other purpose to the label. It seems intended to discourage use of the equipment. How in the world would I know if I am within 20 miles of a "shore-based VHF marine channel 70 distress and safety watch system" or not?

I really have no idea if the FCC actually requires this label. I can tell you that the reason I can quote the label is because it is not installed on my boat near the radio. It is stuck in a folder with paperwork and instruction manuals.

I spent some time trying to find the actual FCC regulations which require that this warning label be included. It seems to be quite universal among VHF Marine Band radio manufacturers, so I assume they've been advised to include it.

Also, I found the wording of the label to be somewhat awkward. I put the text into an automated reader that grades English text on reading level. It found:

Reading Level Analysis
Flesch-Kincaid (FK) Score: 13.9
Flesch Reading Ease (FRE) Score: 33

The FK Score is equivalent to grade level, so the warning label text at 13.9 grades out at about a second year of college reading level.

The FRE score is an index of ease of reading, and the higher the score the easier to read, on a range of 0 to 100. The easier a text is to read, the more people can read and understand it. In this case the score is low, 33, or not very easy to read.

Considering that the label might be read during a distress situation, its college-level reading difficulty make it difficult to understand. Although I have read it myself many times, I still do not completely understand the intent of the text. It is framed as a warning message, so my reaction is that it is explaining something to me that might be dangerous or harmful. Typically a warning message is more explicit and gives direct instruction. For example, as I have read this message and understood its intent, I would re-write the warning this way:

WARNING
Do not operate this equipment unless within 20-miles of shore.

Please understand that I am not making that as a personal recommendation, but as an interpretation of what the actual content of the original warning message was, just expressed more simply and directly.

Actually, I disagree with the message as I have interpreted above. If there is a distress situation, I will use the radio even if I am more than 20-miles from shore. Exactly what is there to lose? If I send a distress message and I am 21-miles out, there is still a chance it will be received. I'd rather take that chance. As far as I can tell, there is hardly a situation in which transmitting a distress message would cause my chance of facilitating search and rescue to be decreased.

Based on the age we live in and the tendency for products to have crazily written disclaimers about exactly what the products does or does not provide, I am inclined to look at this warning message more as a disclaimer. In that regard it seems to be saying that your expectation of a rescue are limited by the conditions of the shore based safety watch and your distance from shore. In that case, it might be more simply written as:

WARNING
Do not expect this equipment to summon a search and rescue response unless within 20-miles of shore.

But, again, in a distress situation, what do I have to lose by pushing the EMERGENCY button on a DSC radio? Is there any scenario in which you can imagine that it would be more beneficial to you to not use the radio to call for help?

Please let me know your interpretation of the WARNING label. Give me an alternative wording based on how you read it.

How would this label affect your action in a maritime distress situation?

---
For information on reading level difficulty analysis see:
<http://webapps.lib.utexas.edu/TxReadability/app>

HAPPYJIM posted 12-26-2008 11:15 AM ET (US)     Profile for HAPPYJIM  Send Email to HAPPYJIM     
Coast Guard Stations have very tall towers for receiving VHF signals. That warning sounds more like lawyer talk. Kinda like the warnings they put on ladders warning you not to use it if you weigh more than 250 lbs. My fat but weighs 254 lbs and I disregard that warning as much as the VHF warning. In fact, I wouldn't clutter up my boat with any stickers other than the CG safety sticker.
jimh posted 12-26-2008 11:22 AM ET (US)     Profile for jimh  Send Email to jimh     
I can't recall seeing any installations of a DSC radio where the vessel had the sticker displayed. It is interesting that this sticker is required by the FCC. The FCC is not the Coast Guard. The FCC regulates radio transmitters in the United States. Just out of curiosity: when was the last FCC inspection of the radio transmitter on a recreational marine vessel which was voluntarily equipped with an unlicensed VHF Marine Radio transmitter?
jimh posted 12-26-2008 11:44 AM ET (US)     Profile for jimh  Send Email to jimh     
ASIDE: It occurred to me after writing the above article that I should analyze my own composition with the same reading difficulty analyzer I had used with the FCC warning label text. I analyzed a number of paragraphs separately. The reading level scores were mainly in the Grade 7 to Grade 8 range. One paragraph scored at a Grade 11 reading level.
Bulldog posted 12-26-2008 04:50 PM ET (US)     Profile for Bulldog  Send Email to Bulldog     
One point is, the radio might only transmit 20 miles and if you are 40 miles from shore you still can get help from nearby boaters. Reading the sticker would suggest you just sit there and slowly expire from some distress instead of calling for help cause you are too far from shore! They will fix that with another sticker, I'm sure.....Jack

PS: I try to keep my writing at a second grade level, so I can proof read it!

bluewaterpirate posted 12-27-2008 11:28 PM ET (US)     Profile for bluewaterpirate  Send Email to bluewaterpirate     
CTB (Covering Their Backsides). I have mine displayed as required. Coast Guard boarded me this fall and I was the star of the ball. I'm the only boater they've ever seen with the sticker displyed as required. Mine has been there two years. Use all means available regardless of range to communicate with the beach/other boaters in the event of an emergency! Commons sense dictates.

http://cdn-2-service.phanfare.com/images/ 4892322_2160277_31027131_WebSmall_3/ Image-4892322-31027131-2-WebSmall_0_a53e319abfe69e0c1d68efa810ed2f32_1

http://cdn-2-service.phanfare.com/images/ 4892322_2160277_56572241_WebSmall_3/ Image-4892322-56572241-2-WebSmall_0_697c7e9dadc929dbebadd5cb0d7310a5_1

We've freaking lost control ... I bought a new hammer last week and it had a warning label on it stating "The hammer could cause bodily harm if you hit yourself with it." Probably spent a couple mil doing research on the same.

Tom

jmorgan40 posted 12-28-2008 11:03 AM ET (US)     Profile for jmorgan40  Send Email to jmorgan40     
Tom,
I also have my warning label applied to the console. I guess you are not the only one. I guess it goes back to my captain days and making sure I obey all the rules.

I can remember two separate instances where I received warning letters from the FCC back when VHFs needed to be licensed.
Joe

DeeVee posted 12-28-2008 11:55 AM ET (US)     Profile for DeeVee  Send Email to DeeVee     
I have the carbon monoxide warning label displayed, as required by Washington State.

I bought the boat with the radio installed. I had never heard of this requirement until now.

I have been inspected twice by Coast Guard Auxilliary teams in the past couple of years. I thought I had passed with every requirement covered. I guess they don't know about it either.

Doug

jimh posted 12-28-2008 01:50 PM ET (US)     Profile for jimh  Send Email to jimh     
My interpretation of the warning label is that it is required by the Federal Communications Commission. I don't think it is required by the Coast Guard. If your recreational vessel which you have voluntarily equipped with a VHF Marine Band radio that does not require a license is ever inspected by an FCC field engineer for compliance, you might be cited.

Years ago it was routine that broadcast stations were visited by FCC field engineers at least annually, and just about all aspects of the transmitter operation were checked for compliance. But in the past ten years I don't recall seeing an FCC inspector visiting a broadcast station.

The last FCC field engineer I saw while on official business was involved in trying to locate a renegade microwave transmitter that was interfering with some licensed stations.

SC Joe posted 01-01-2009 10:26 PM ET (US)     Profile for SC Joe  Send Email to SC Joe     
Interesting.

My Boston Whaler factory installed VHF does not have that sticker displayed, nor was it inucluded with any of the radio's documentation.

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