Introduced in the 5th amendment of the Marine Equipment Directive (Directive 2009/26/EC), ISO24408 introduced high quality testing standards for all manufacturers of position indicating lights (A.1/1.2) to adhere to in production, similar to the requirements for type approval MSC81(70). This standard was removed from the 6th amendment (Directive 2010/68/EU), but Daniamant felt at the time that production testing was and still is the only way that manufacturers, Notified Bodies and Administrations can ensure that the products produced today meet the same exacting high standards demanded by type approval.
ISO24408 was never designed for comprehensive type approval, those requirements are already detailed in MSC81(70) and the LSA Code – it was designed to ensure that type approved product was kept at the same standard when in manufacture. IMO, through SOLAS Chapter III Regulation 5 states: “The Administration shall require life-saving appliances to be subjected to such production tests as are necessary to ensure that the life-saving appliances are manufactured to the same standard as the approved prototype”.
This situation remained unchanged until 2020 at which time it was added to the Implementing Regulation (EU 2020/1170). As Daniamant had made a significant financial investment in the equipment required to test to this ISO production test standard we continued to test all of our survivor location lights to these demanding standards. However, as time has moved on this ISO standard becomes more and more irrelevant to today’s technology. It must be noted that this standard was written for Incandescent Light Bulbs, so it is not directly applicable to the majority of life-saving appliance position-indicating lights on the market today (i.e. LED types of lights).
The Marine Equipment Directive: Article 1(a) of the IMO Convention states that IMO should “facilitate the general adoption of the highest practicable standards in matters concerning…maritime safety”. ISO24408 is still the only standard available today that allows for consistency in how manufacturers ensure production units meet the same standards as those units that were type approved. Daniamant still carry out production tests, as it is a legal requirement (and this is a philosophy that Daniamant will continue to uphold), this means that the product you receive today has been through a testing regime, similar to original type approval and ensures you only receive high quality product.
However, Daniamant continues to lobby Notified Bodies, Administrations, EMSA and EMEC for these production testing standards to be updated so that they are more relevant and applicable for all manufacturers of LSA.