Alan de Enfield

Exactly in line with the RCD/RCR statement, except, that evidence of equivalence has to be submitted to the RCD/RCR and included in the technical manual. Other ways to comply with the essential requirements. The application of harmonised standards is not the only means to demonstrate the conformity of a product. However, only harmonised standards, after publication of references in the Official Journal of the EU (OJEU), may provide an automatic presumption of conformity against essential requirements covered by such standards. With the exception of the Directive’s mandatory reference to some harmonised standards (see Point 3), the manufacturer can choose whether or not to apply and refer to harmonised standards. However, if the manufacturer chooses not to follow the harmonised standards, he has the obligation to demonstrate that his products are in conformity with essential requirements by the use of other means that provide for at least an equivalent level of safety or protection. These can be technical specifications such as national standards, European or international standards which are not harmonised, i.e. not published in the OJEU, rules of notified bodies or the manufacturer’s own specifications. In these cases the manufacturer does not benefit from the presumption of conformity, but has to demonstrate the conformity himself. This implies that he demonstrates, in the technical documentation of a relevant product, in a more detailed manner how the technical specifications he uses provide conformity with the essential requirements. Manufacturers are advised to stay informed about the developments in international standardisation. Even if the manufacturer has not used harmonised standards, a change in the relevant harmonised standard could mean a change in the state of the art that implies that his product may not be compliant.

So, when I earlier said "I think your examiner is maybe working to his own agenda" I was probably correct ?

On another forum : I was issued marine insurance for my narrowboat for one year, ending 1 June 2024, but was recently told by Haven Knox-Johnston that the reinsurer, MS Amlin, will no longer allow HK-J to insure Americans, although he probably meant Amlin will no longer insure non-UK residents. I was not aware a narrowboat, used exclusively on UK/CRT canals and rivers could have a State of Nationality other than UK. Do you know if this is possible? I fully expect to be forced to sell my narrowboat, which I only purchased this year, due to lack of insurance. My details are: -Permanent US resident owner. -US citizenship of owner. -Vessel is a narrowboat used on the CRT canal and river system, currently moored in a marina connected to the CRT canal system in England. -Presumed UK flagged vessel. I've called all the insurers on the CRT list and none of them will agree to insure a UK based boat to non-UK resident. Any useful information you have would be greatly appreciated.

No need - the OP is obviously fully aware as he expects the surveyor to check that the HIN numbers match.

But similar result to tying up tight and opening the paddle.

Even tying to the bollards is no guarantee .............. Meadow Lane Lock

Indeed he could, but the boat would need to be owned by his Father - you cannot insure something in your name that you do not have a "legal interest" in. If necessary he could be added to the insurance as a 'named driver' but that is not normally necessary on boats, where any suitable person can 'drive'.

I believe that you are incorrect. The GSIUR is a legally binding regulation made by Parliament - despite any delusions of grandeur that C&RT and the BSS may have, they cannot overule Government legislation. https://www.legislation.gov.uk/uksi/1998/2451/introduction

It is the GSIUR and is applicable to all liveaboard and commercial boats. Extract GSIUR .............. Room-sealed appliances 30.—(1) No person shall install a gas appliance in a room used or intended to be used as a bathroom or a shower room unless it is a room-sealed appliance. The GSIUR 'trumps' the BSS, and the GSIUR is why the BSS does not allow non-gas certified engineers to do the gas checks (using a manometer) or work on a liveaboard boat. From the BSS ................ The examiners who are not on the Gas Safe register are advised as part of their initial dealings with owners to ask in advance of turning up at the mooring, about the status of the craft. To avoid falling foul of UK law and avoiding criminal prosecution they need to find out whether the boat's use will mean they should not carry out a tightness-test using a manometer. They may ask the following questions, just for their own personal record: Is the boat hired out in the course of a business? Is the boat used primarily by anyone for domestic or residential purposes (In this matter, it makes no difference to if the boat is owner-occupied or rented-out)? Are people invited on board the boat in the course of a business, e.g. is it a café or shop? Even if the answer to all the questions above is 'no', the examiner is advised to make a brief record that he or she has asked the questions and received the negative answers. This information will not be shared with BSS Office or other parties unless there is an investigation linked to gas testing by the examiner.

If it a liveaboard than certainly installation in a bathroom is not allowed. If it is a non-liveaboard than the BSS allows for non-room sealed water heaters to be used Extract from the BSS on the subject of ventilation. This derogation is currently being investigated by the BSS as more room-sealed water heaters have become available. BUT, as of today, the derogation is still in force. There is a growing recognition of the risks associated with the use of non room-sealed gas appliances when used in confined spaces such as boats. These risks include poisoning and suffocation to individuals on board from improperly flued and ventilated appliances. So new LPG appliances must be room sealed, except where room-sealing is not physically possible, i.e. cooking appliances. There is one specific exception to this rule and this is for LPG instantaneous water heaters. Based on the good previous safety record of these particular appliances, and until such a time as a room-sealed direct replacement becomes easily available, British Waterways and the Environment Agency accept the continued installation of instantaneous water heaters on private boats. If you are changing your non-room sealed instantaneous water heater it's strongly recommended that you consider room sealed alternatives. I think your examiner is maybe working to his own agenda

The Regulations have requirements, the standards are simply methods of achieving the requirements. The regulatory requirements are identified and then standards are written to achieve them, the regulations/requirements are not written around standards. As is regularly pointed out, the RCR does not demand that the ISO standards are used, it says that if they are used, then there is an automatic assumption of compliance, but, you can achieve the requirements in other ways if you wish.

Wasn't there an example (a few years ago) of a boat on the K&A that went cruising (unusual I know) and when he returned he could not fit into the lock. Whilst he was cruising C&RT had done work on the lock and it no longer met C&RTs own 'lock dimensions' and, meant that some boats that used it previously were 'trapped' on the wrong side.

Just a thought before you pay £1000s - have you contacted any insurers to see if they will give you cover ? (without insurance you will be unable to get the boat licenced) There are several non-uk residents on this forum who have been unable to get boat insurance for their UK based boats. You will generally find that there is a "one liner" hidden away in the T&Cs where you are required to confirm that your permanent residence is the UK For example : "Craftinsure" online insurance brokers are probably the main provider of inland waterways insurance - when you complete the application forms it will not let you proceed after you put in a non-uk address. (You MUST provide a UK postcode / Zipcode)

Sure - but "most boats travel at 4mph"?

Really - you must have been on very different canals to me !