"Radio Check" (calls to "Any Station" prohibited
Radio checks are specifically authorized on VHF Ch. 16 (the only exception being that one may not call the Coast Guard for a radio check on 2182 or 16FM). 47 C.M.R. sec. 80.101.
I am aware that, in some locations, USCG stations may respond to a CQ sigrep call on Ch. 16 with an announcement to the effect, "Channel 16 is reserved for hailing and distress only. Take your radio checks to Channel 9." There is no basis in the FCC regulations for this statement.
No, in fact "radio checks" are not authorized on Ch-16 or 2182 KHz. The cite of 80.101 misinterprets the specific test procedures authorized there, and neglects mention of the prohibition of calls to any station or any vessel which is addressed in 80.89 (unauthorized transmissions), and Subpart-S 80.931 which addresses cumpulsory-only vessels required to perform tests of radiotelephone equipment.
99.9% of the radio checks made by vessels on Ch-16 are violations of at least one FCC regulation, the majority of which are due to a failure to address a specific coast station or vessel with subsequent shifting to a working channel.
Except in cases of distress, at no time may any vessel or coast station place a call to "Any vessel" or "Any Station", thus the transmission "Radio Check" is never authorized.
I have included some relevant material from Part 80 that reinforces these comments.
Jack Painter
District Staff Officer Communications
U.S. Coast Guard Auxiliary
Sec. 80.89 Unauthorized transmissions.
Stations must not:
(a) Engage in superfluous radio communication.
(b) Use telephony on 243 MHz.
(c) Use selective calling on 2182 kHz or 156.800 MHz.
(d) When using telephony, transmit signals or communications not
addressed to a particular station or stations. This provision does not
apply to the transmission of distress, alarm, urgency, or safety signals
or messages, or to test transmissions.
Subpart S_Compulsory Radiotelephone Installations for Small Passenger
Boats
Sec. 80.931 Test of radiotelephone installation.
Unless normal use of the radiotelephone installation demonstrates
that the equipment is in proper operating condition, a test
communication on a required frequency in the 1605 to 27500 kHz band or
the 156 to 162 MHz band must be made by a qualified operator each day
the vessel is navigated. If the equipment is not in proper operating
condition, the master must be promptly notified.
Sec. 80.101 Radiotelephone testing procedures.
This section is applicable to all stations using telephony except
where otherwise specified.
(a) Station licensees must not cause harmful interference. When
radiation is necessary or unavoidable, the testing procedure described
below must be followed:
(1) The operator must not interfere with transmissions in progress.
(2) The testing station's call sign, followed by the word ``test'',
must be announced on the radio-channel being used for the test.
(3) If any station responds ``wait'', the test must be suspended for
a minimum of 30 seconds, then repeat the call sign followed by the word
``test'' and listen again for a response. To continue the test, the
operator must use counts or phrases which do not conflict with normal
operating signals, and must end with the station's call sign. Test
signals must not exceed ten seconds, and must not be repeated until at
least one minute has elapsed. On the frequency 2182 kHz or 156.800 MHz,
the time between tests must be a minimum of five minutes.
(b) Testing of transmitters must be confined to single frequency
channels on working frequencies. However, 2182 kHz and 156.800 MHz may
be used to contact ship or coast stations as appropriate when signal
reports are necessary. Short tests on 4125 kHz are permitted by vessels
equipped with MF/HF radios to evaluate the compatibility of the
equipment for distress and safety purposes. U.S. Coast Guard stations
may be contacted on 2182 kHz or 156.800 MHz for test purposes only when
tests are being conducted by Commission employees, when FCC-licensed
technicians are conducting inspections on behalf of the Commission, when
qualified technicians are installing or repairing radiotelephone
equipment, or when qualified ship's personnel conduct an operational
check requested by the U.S. Coast Guard. In these cases the test must be
identified as ``FCC'' or ``technical.''
(c) Survival craft transmitter tests must not be made within
actuating range of automatic alarm receivers.