Tacet

A well made point about Hertford Lock. Some (but not all) guides have the locks marked as "Old Ford" Locks but I'm not convinced about the name as there are (and were already when the Duckett's opened) another two Old Ford Locks in the locality, which is surely enough.

Your position is that the RCR requires the "equivalent" of the ISO - which would surely amount to the same thing, on this occasion Is this the RCR or the ISO handbook; it's easy to get confused....

Alan is confusing the RCR with ISOs again. The RCR Essential Requirement, in this context, is: "All watercraft, taking into account their design category and their characteristics, shall be fitted with one or more strong points or other means capable of safely accepting anchoring, mooring and towing loads." It is the ISO 15084 that gives the complicated formula. The RCR say (put simply) that meeting the ISO satisfies the Essential Requirement. But the RCR does not insist you meet the ISO. If your narrowboat strong point is capable of safely accepting etc etc , that's enough. There is always the question of how do you know if your strong point is sufficiently strong; this applies whether ISO or not, albeit with ISO you could do the test. Being realistic, if a strong point is much the same as many other similar craft, it is likely to comply with the law.

Alan is dancing to and fro between RCR Essential Requirements and ISOs. One is mandatory, one is not

The Essential Requirement that deals most with electrical matters says "Electrical system Electrical systems shall be designed and installed so as to ensure proper operation of the watercraft under normal conditions of use and shall be such as to minimise risk of fire and electric shock. All electrical circuits, except engine starting circuits supplied from batteries, shall remain safe when exposed to overload. Electric propulsion circuits shall not interact with other circuits in such a way that either would fail to operate as intended. Ventilation shall be provided to prevent the accumulation of explosive gases which might be emitted from batteries. Batteries shall be firmly secured and protected from ingress of water." You need to comply in full. If you want to take advantage of the presumption of conformity, you need to follow the ISOs so far as they relate to the Essential Requirements. If ISO 12345 relates only to these matters - you need to follow it in full if you want the presumption to cover all the electrical works. But if ISO 12345 deals with other things beyond the scope of the Essential Requirements - it does not somehow make them Essential Requirements. Even if ISO 12345 deals only with Essential Requirements matters you do not have follow it in full just because you have followed it in part. For example, you could follow it insofar as it remained safe when subject to overload but not when it deals with explosive gases. You could conceivably adopt another method of addressing accumulated gases. That method would, if course, need to comply with the Essential Requirements. You would not have the benefit of the presumption of conformity for all electrical matters - but if you met the Essential Requirements you would be fine with the RCR. The bottom line is there is no RCR demand that you follow the ISOs. You can (and almost inevitably will) find yourself in accordance with some Standards. But it does not follow that just because you follow part of a Standard, you must follow it in its entirety. And there is no need to prove that any non ISO standards work is equal or better. You need to meet the Essential Requirements - that's enough (for the RCR). The RCR could have set out the ISOs to be followed - but it didn't.

There is no requirement to prove that your method is equal or better than the ISO spec. The RCR requires you to meet the Essential Requirements. If you think otherwise, please provide chapter and verse from the RCR (not someone else's opinion on the web)

Yes, in my view. There is no RCR obligation to meet ISO standards, so if you deliberately (or even accidentally) meet part of an ISO standard, that's neither here nor there. You must, of course, comply with the RCR Essential Requirements one way or another. Yes, in my view. If you meet an Essential Requirement fully, by utilising ISO standards methods etc, you (rebuttable apart) are deemed to have met that Essential Requirement. The fact that the same ISO provides standards for things that are not Essential Requirements at all does not make the extraneous issues mandatory for RCR purposes. It could hardly be otherwise. Even if you never referred to ISOs when building a boat, you would inevitably find that you had accidentally met part of one standard. Your way of thinking would be that the ISOs would be invoked in full. A boat builder not wanting to meet all of the relevant ISO would have to study them very carefully to avoid every aspect - and no doubt a very curious vessel would be the result! The bottom line is that it is the Essential Requirements that must be met to comply with the RCR. You can do so by adopting ISO standards - but you do not bring the whole lot down upon you if you follow only part of a standard and still comply with the Essential Requirements. If you don't adopt ISO standards, you still have to meet the Essential Requirements of course. You may find yourself having to demonstrate that your means and methods do, in fact, meet the Essential Requirements as it could be more subjective.

I don't argue the no-one-will-know-or-care point. Where I dispute with Alan is his exaggeration of the reach and details of the RCR (e.g. British Marine is the enforcement agency; all boats must have fuel tank inspection hatches. This is how it works, in simplified form. For relevant vessels etc, the Essential Requirements of the Recreational Craft Regulations must be met. Here they are: https://www.legislation.gov.uk/uksi/2017/737/schedule/1 Some of the requirements are a bit woolly e.g. "Fuel tanks, lines and hoses shall be secured and separated or protected from any source of significant heat". How much heat is significant? How secure is secure? How much separation is required? The RCR helpfully (?) provides "41.—(1) A product which is in conformity with a designated standard (or part of such a standard) is to be presumed to be in conformity with the essential requirements covered by that standard (or that part of that standard). (2) The presumption in paragraph (1) is rebuttable." So, putting aside the rebuttable bit, which won't come into play often, if ever, if there is a designated standard (i.e. ISO) dealing with protecting boat fuel lines from significant heat (and I have no idea if there is!) and the vessel meets that standard, you're well on the way to complying with that Essential Requirement. Where Alan misunderstands is his belief that every boat orientated ISO is also automatically an Essential Requirement for the RCR. Therefore since there is (he says - and I don't doubt) an ISO dealing with fuel tank inspection hatches, he thinks that there is an Essential Requirement to have one - notwithstanding the RCR being silent on this point. Put another way the Essential Requirements of the RCR are ... err...all the essential requirements. You can meet these Essential Requirements by the means and methods in a relevant ISO. But a boaty ISO doesn't lead directly to a mandatory direction for RCR purposes.

You're clutching at straws. You would be kept rather busy if you sought to have sufficient evidence to readily refute every allegation that could possibly be made against you by anyone at any time. So BMF has both replaced RYA and hasn't replaced the RYA? Neither party is an administrator of the RCR in any accepted sense; the RCR the law and is subject to enforcement - not administration. And it is somewhat improbable that either a trade organisation or a yachting association would be entrusted with enforcing the law

Not so. The prosecution would have to prove to the Court that the vessel was non-compliant. BM does not administer the RCD (or RCR). It has only a very minor role - it maintains a register of hull marking codes. It has no statutory role in enforcement or monitoring.

May do or have to? There is an important distinction between it being an RCR requirement to meet the ISOs - and the meeting the ISOs as one means of complying with RCR Essential Requirements. Which do you think it is? Contrary to your post, it is, in fact the latter that is the case - as is evident from your cut and paste extract. Hence your previous assertions that a fuel tank inspection hatch (inter alia) is mandatory under the RCR because it is necessary if you want to meet the ISO, is fundamentally incorrect. One problem with taking the full ISO route as the gold standard is there being no comprehensive list of which ISOs must be met for RCR purposes. For example ISO BS7001 deals with signage on toilet doors; if you consider meeting ISOs is the RCR law, must you have compliant graphics on your boat?

My mistake then. I thought it was you with the long held opinion that the RCR required meeting relevant ISOs or demonstrating equivalence. Would you like me to provide some quotes? Such as a vessel MUST (your emphasis, not mine) a fuel tank inspection hatch to comply with RCR as there is an ISO which requires one, should you want to meet the standards. Para 11 of the RCR 2017 requires the manufacturer to keep the technical documentation for 10 years. https://www.legislation.gov.uk/uksi/2017/737 But it does not require it to keep evidence (or is it proof? - you interchange between them) supporting the compliance. Is such a requirement elsewhere?

Why do you say that evidence (of compliance) must be available? Obviously, if one was prosecuted for a breach of the RCR it would be helpful to have evidence available that the vessel was, in fact, compliant. But is this not only in the same way that if one was prosecuted for housebreaking, it would be helpful to have an alibi? Have you now corrected your position, Alan? You have frequently asserted that a vessel must meet BSs and ISOs (or at least reach an equivalent standard and demonstrate it) in order to compy with the RCR.

No. BM (and RYA before it) has a very limited role in dispensing and recording hull identification codes