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Old 2nd November 2023, 14:11   #1
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Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Hello
I need to write a letter to DOT about clarity on carrying a Man-Overboard SOS Device in carry-on luggage in the aircraft - which basically sends GPS location signal via AIS signalling when activated (seafarers will know). Last time I tried to board a flight at Kochi airport I was given a tough time by CISF security who denied me permission. Due to a very delicate screw that I had over tightened I could not remove the lithium batteries after half an hour of struggle and had to leave it behind at the airlines office to collect it later on return - as I did not want to check-in lithium batteries and endanger the whole flight (I could have played smart as the batteries were not identifiable as lithium batteries, but in the interest of safety my conscience did not allow it).

I had no such problems at the Bangalore airport while the Kochi airport security showed me the DOT regulations documents showing “satellite and GPS” devices were banned. I argued for an hour almost that this was not a communications device with satellite based signalling just a homing beacon and that the regulations did not say “satellite, and GPS are not allowed…” therefore it was legal, but the significance of the missing comma “,” was lost on the CISF Jawans who were non-English speaking and from the deep interior rural hinterlands of India…

I tried searching online but could not locate whom in the ministry to contact and how to correctly draft a letter requesting that an addendum or clarification regarding permitting MOB SOS devices in carry-on luggage be issued to all airports across India.

If you have experience in communicating with DOT on policy matters, can you please contact me and help me with this?

The reason for not simply opting to check-in the device is that it is made with extremely delicate and tiny screws (wristwatch tiny size screws - and just one or two excess turns has damaged the threading (a matter which I have not yet overcome)- so frequently unscrewing and screwing to remove and install batteries is not an option (The batteries are made to last 5 years once installed)… as the slightest unseen damage can undo the waterproofing of the housing.

I would also like to humbly request that if you are unable to directly help in this matter please do not engage in chatter that side-tracks the purpose of this thread.

Last edited by Ragul : 2nd November 2023 at 14:13.
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Old 3rd November 2023, 15:30   #2
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Why is a MOB device built with such fragile parts.

The device is supposed to be used in life at risk situation so it must be built to be way more rugged!
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Old 3rd November 2023, 17:51   #3
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Quote:
Originally Posted by Ragul View Post

I had no such problems at the Bangalore airport while the Kochi airport security showed me the DOT regulations documents showing “satellite and GPS” devices were banned. I argued for an hour almost that this was not a communications device with satellite based signalling just a homing beacon and that the regulations did not say “satellite, and GPS are not allowed…” therefore it was legal, but the significance of the missing comma “,” was lost on the CISF Jawans who were non-English speaking and from the deep interior rural hinterlands of India…
.
Just to prove some clarity for members who have never heard of this Man Overboard Devices. The GPS chip determines the location which is subsequently broad coasted on AIS so all ships (with AIS receivers) can see them.

These MOB devices are commonly known as EPIRB. The GPS chip determines the location which is subsequently broadcast on AIS so all ships (with AIS receivers) can see them.

https://en.wikipedia.org/wiki/Emerge...ng_radiobeacon

This question does pop up from time to time on Yachting forums. Most are just concerned about the lithium battery. As long as the battery complies with relevant aviation restrictions on lithium batteries in the cabin you are fine. The GPS and satellite thing is not a problem in most countries

I often see a response along the lines, check with your airline. That won’t help I believe as security checks on any airport are not done by the airlines themselves.

I would contact the manufacturer of the device and ask them for advice. They must have had the question before.

Good luck with getting clarity from the DOT.

Jeroen

Last edited by libranof1987 : 4th November 2023 at 11:02. Reason: Minor typo
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Old 3rd November 2023, 19:01   #4
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Quote:
Originally Posted by Mohitkumaar View Post
Why is a MOB device built with such fragile parts.

The device is supposed to be used in life at risk situation so it must be built to be way more rugged!
The device as a whole is rugged, it’s the tiny screws that gets their head worn off with the slightest force. It’s a question I am drafting to the support team of the manufacturer as well.

Quote:
Originally Posted by Jeroen View Post
This question does pop up from time to time on Yachting forums. Most are just concerned about the lithium battery. As long as the battery complies with relevant aviation restrictions on lithium batteries in the cabin you are fine. The GPS and satellite thing is not a problem in most countries

I often see a response along the lines, check with your airline. That won’t help I believe as security checks on any airport are not done by the airlines themselves.

Good luck with getting clarity from the DOT.

Jeroen
In this case it wasn’t the airline but the CISF at the security X-ray machine that decided he had a problem with it. The battery is a removable off-the-shelf CR123 version. However due to the very fragile screwhead I wore off the head with just a little extra force and struggled to remove the casing for half an hour afterwards, else I would have pocketed the battery and checked-in in the device. As a matter of chance, I also forgot I had stashed some lithium batteries into my check-in luggage and got called by the security to the cargo X-ray screening area in the high security basement to remove them from my luggage, so I could have just slipped in the device when I opened my checked-in baggage to extract the batteries.
Luckily I had landed at the airport a good 3 hrs before boarding so I had time to calm myself down and think about alternative options as the clock was ticking for boarding…

I had to run back upstairs and clear security once again with removing all the stash from my pocket, my belt etc and it was frustrating!

Last edited by Ragul : 3rd November 2023 at 19:16.
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Old 3rd November 2023, 20:37   #5
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Quote:
Originally Posted by Ragul View Post
I need to write a letter to DOT about clarity on carrying a Man-Overboard SOS Device in carry-on luggage in the aircraft
You can try submitting a query on pgportal.gov.in

https://www.team-bhp.com/forum/shift...me-you-do.html (Heard of pgportal.gov.in? About time you do)

Although you don't want to submit a grievance, I'd think that submitting a query here might at least get you a lead on whom to contact.

Also, wouldn't Airports Authority of India or Ministry of Civil Aviation be the more appropriate departments to contact, rather than department of transportation?

Good luck!

Last edited by comfortablynumb : 3rd November 2023 at 20:40.
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Old 3rd November 2023, 22:06   #6
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Originally Posted by comfortablynumb View Post
You can try submitting a query on pgportal.gov.in

Also, wouldn't Airports Authority of India or Ministry of Civil Aviation be the more appropriate departments to contact, rather than department of transportation?

Good luck!
Thank you for that suggestion. It does look like Ministry of Civil Aviation might be the right department to contact (why on earth did I think of DOT in the first place?!! I guess it was because I had the satellite phone restrictions stuck in my head… actually the Airport security was clubbing any GPS radio device together with satellite phones as belonging to the same class). However a forum member has contacted me via DM and given me some leads within DOT which I intend to peruse tomorrow, after which I will consider the MoCA…

PS: The grievances portal seems to be exclusively for service delivery complaints and mine does not fall into that category.

Regards

Quote:
Originally Posted by comfortablynumb View Post

Also, wouldn't Airports Authority of India or Ministry of Civil Aviation be the more appropriate departments to contact, rather than department of transportation?

Good luck!
FYI - DOT is the Dept. of Telecommunications in India not Dept., of Transportation. They would be the authoritative decision makers (technical and licensing) regarding satellite phone restrictions in the country and the likely origin/author for any internal security related directives about communications devices that may go to the MoCA - about what is permissible and what is not. Hence I thought that I should begin with addressing them rather than any other ministry as it would have to be forwarded to DOT for review in any case, to be qualified as exempted from restrictions.

So my intent and end-goal is to make them aware of a class of radio signalling devices known as EPIRB or Emergency Position-Indicating Radio Beacon that are harmless to Internal Security considerations of the country, and for them to categorise devices of this class as exempt from any restrictions to carry on-board aircraft - and issue a communique to MoCA in this regard. It gets a little complicated because there are also satellite based EPIRB that will work even if there are no boats with AIS receivers within a 50km vicinity (some even allow short text messaging - useful for land based SAR). Mine is purely AIS (non-satellite based) capable device FYI and (should be considered) relatively harmless, compared to say a common Android phone with 4G/5G voice and data signalling together with GPS capability which every damn individual carries on them these days!

I just realised that other readers might also make the same mistake of interpretation (what is DOT?), so adding a clarification here..

Regards

Last edited by GTO : 6th November 2023 at 16:08. Reason: Merging back to back posts
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Old 4th November 2023, 09:56   #7
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

All over the world people with restrictive luggage that seems to be caught often as no fly objects, usually travel by road with adequate paperwork such as use of the instrument, its capability and usual official documents. You can also use train if you want less headache and some relaxation on the journey.

You wouldn't get any letter from any dept. No NOC will be provided, as devices can be altered each time and there is no safeguard mechanism to prevent it.
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Old 4th November 2023, 13:17   #8
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

My mother-in-law needs an oxygen concentrator and it gets questioned whenever she travels by air. Two things that helped:
  1. The manufacturer/distributor can provide a letter saying the device has US FAA (Federal Aviation Administration) certification for in-cabin and/or checked in transport (as applicable). Similar one maybe available for your device.
  2. A letter from the doctor saying she needs to use this device regularly. While not applicable in your case, maybe a letter from a safety body/institute saying this device is required might help.
Despite this we had to argue and haggle, especially at small airports, where they don't see such devices often. We usually go couple of hours in advance, as they need time to escalate internally, until someone calls their Delhi office and gets clearance. It is generally better in the metro airports as they see such devices more often.

In office we transport radio equipment (thankfully without batteries in them), we often have to try different names like radio unit, base station, man pack, battery-less electronic device until we hit something they understand.

Last edited by wocanak : 4th November 2023 at 13:25.
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Old 4th November 2023, 13:21   #9
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

You may also want to check with people from Bureau of Civil Aviation Security.
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Old 4th November 2023, 16:36   #10
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Quote:
Originally Posted by Sran View Post
All over the world people with restrictive luggage that seems to be caught often as no fly objects, usually travel by road with adequate paperwork such as use of the instrument, its capability and usual official documents. You can also use train if you want less headache and some relaxation on the journey.

You wouldn't get any letter from any dept. No NOC will be provided, as devices can be altered each time and there is no safeguard mechanism to prevent it.
I need to fly International and the last time I checked there are no trains to remote islands anywhere in the world.

I am not asking for a personal letter of approval to carry with me - looks like you misunderstood the objectives I posted above.
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Old 4th November 2023, 17:19   #11
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

I would suggest you to send Right to Information queries to both the Ministry of Civil Aviation and the Department of Telecommunications under Ministry of Communication regarding your issue and issue of relevant circulars allowing/disallowing Man-Overboard SOS devices with its lithium batteries with carry-on luggage in civil flights.

If you check their websites, these will feature the Central Public Information Officer (CPIO) by their names and designations with their landline contact numbers and exact addresses including their room nos. in the respective office. If insufficient information is provided by the CPIO, you can send a First Appeal to his Appellate Authority who holds a senior position. Then of course the Second Appeal lies with the office of the Chief Information Commissioner ( done through their website) if both replies are unsatisfactory.

The information so gathered can help you form a base for taking up your grievance with the Appropriate Authority in the Union Ministry of Civil Aviation, as the issue of allowing or disallowing any objects into passenger flights is their sole perogative.

Last edited by anjan_c2007 : 4th November 2023 at 17:21.
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Old 5th November 2023, 11:40   #12
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

You could submit an RTI query to Ministry of Civil Aviation.
https://rtionline.gov.in/
They are obliged to reply with in 30 days.
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Old 5th November 2023, 22:05   #13
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Quote:
Originally Posted by Ragul View Post
Hello


I had no such problems at the Bangalore airport while the Kochi airport security showed me the DOT regulations documents showing “satellite and GPS” devices were banned. I argued for an hour almost that this was not a communications device with satellite based signalling just a homing beacon and that the regulations did not say “satellite, and GPS are not allowed…” therefore it was legal, but the significance of the missing comma “,” was lost on the CISF Jawans who were non-English speaking and from the deep interior rural hinterlands of India…

.
OT, I too have seen that the CISF Jawans at Kochi airport are double strict , to the extent of borderline arrogance. Asking for directions too are frowned by them. I am talking on my personal experiances. I may be wrong. I do not wish to start a debate on this.

I have seen the most friendly security at Pune airport.
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Old 5th November 2023, 22:10   #14
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

I frequently travel in and out of Kochi airport. The amount of pain provided by CISF is immense. The arrogance of the constables is unimaginable. I have dealt with them multiple times as my better half requires medicines, treatment equipment which contains fluids. The last resort for me was to ask for a senior officer before going into screening(at the checkpoint where they scan your boarding pass - the one after immigration) - Normally you get an officer who has some world knowledge and appreciative of situation.

Go with a lot of paper work and with lot of literature. They always were helpful.

Once you get stuck with the lower level ones after the scan, there is little the senior officers could do.
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Old 6th November 2023, 00:17   #15
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Re: Want to carry Man-Overboard SOS device in carry-on luggage | How to write to DoT?

Quote:
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I need to fly International and the last time I checked there are no trains to remote islands anywhere in the world.

I am not asking for a personal letter of approval to carry with me - looks like you misunderstood the objectives I posted above.
I don't understand why you needed to be sarcastic when someone was trying to help. It is never mentioned in any of the earlier posts that you were traveling internationally.

Now coming to the query, did you try reaching out to the manufacturer and getting some paperwork? And I have a feeling the screws might not be delicate, rather you are not using the right (sized) screwdriver if you are stripping the screws. Remember, everything that looks like a philps head is not a philips head. IMO, figuring out how to properly remove the battery is the only permanent solution. There will always be some country/airport where you will be stopped.
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