Licensing and BSS order of events

[jetzi]

Hi canalworldians, we've been the proud and happy owners of NB Butterfly for almost a year now, and that means the time has come to renew our CaRT license. There are some nuances to our situation that I'd be most grateful if someone could explain.

 

Our license expires 30th Sep 2019. Our boat safety scheme certificate expires 18 October 2019.

 

We would like to get a gold license for next year, so that we can traverse EA waterways. However I am aware that this license only runs by calendar year (January to December).

 

We also do need some work done in order to pass the boat safety examination (namely, our exhaust needs replacing). We are trying to get this done as urgently as possible but we are having difficulty finding anyone in our area with availability before say mid-September.

 

What I would like to do is:

1. Renew our CaRT canal and river license for 12 months on the strength of our current BSS certificate.

2. Get the work done as urgently as possible, hopefully before 18th October.

3. Get a new BSS cert immediately afterwards.
4. Get a gold license from January to December and get a refund on the 9 unused months of our license.

Are there any flaws with this plan?
 

What happens if your BSS cert expires during the course of your CaRT license? Are you uninsured from this point? Would CaRT take immediate steps to remove your boat from the waterways or other action against you?

In your responses please be so kind as to bear in mind I am NOT trying to circumvent the system. I am urgently trying to get the boat up to scratch and have been for ages - in fact I was even docked to get the work done a month ago (work which I had booked several months in advance) but the boatyard had overbooked and simply didn't have capacity to do it. Thanks!

[ditchcrawler]

That sounds the best plan

[Richard10002]

On the BSS you seem to be aware that it can be done up to a month before it expires and still be valid for 12 months from when it expires.... I hope I am right, and that this makes sense.

 

If it were me, and I was having trouble getting someone to sort the exhaust, I would get the BSS done and, when it failed due to the exhaust, i would hope/expect that the inspector would be able to help with finding someone to sort it, (and any other issues). If you find an inspector who works with a yard, there is more chance of this plan working.

 

I dont think it costs the full amount of an inspection for a revisit and pass, but you would obviously need to check with the particular inspector.

[jetzi]

8 minutes ago, Richard10002 said:

On the BSS you seem to be aware that it can be done up to a month before it expires and still be valid for 12 months from when it expires.... I hope I am right, and that this makes sense.

I believe it can be done up to two months before it expires, and the new certificate gets dated from the expiry date of the old one. From CaRT:
 

Quote

BSS examinations are best done two months before the expiry of the old certificate. If your boat passes first time, the examiner is able to forward-date (up to 2 months) your new certificate so that it runs for four years from the expiry of your current certificate. If your boat needs work to meet the requirements, you will have time to correct the issues and get your boat re-examined.

 

The inspector we want to use surveyed our boat a short while ago and helpfully pointed out the things that needed sorting for the BSS, including the exhaust. The yard we had the survey done at was the yard I had booked it in to do the work, and they did not (and do not) have availability. Given that I already know what needs sorting, I'd rather not go through the hassle of failing a BSS examination and rather pass first time.

[Chewbacka]

20 minutes ago, ivan&alice said:

Hi canalworldians, we've been the proud and happy owners of NB Butterfly for almost a year now, and that means the time has come to renew our CaRT license. There are some nuances to our situation that I'd be most grateful if someone could explain.

 

Our license expires 30th Sep 2019. Our boat safety scheme certificate expires 18 October 2019.

 

We would like to get a gold license for next year, so that we can traverse EA waterways. However I am aware that this license only runs by calendar year (January to December).

 

We also do need some work done in order to pass the boat safety examination (namely, our exhaust needs replacing). We are trying to get this done as urgently as possible but we are having difficulty finding anyone in our area with availability before say mid-September.

 

What I would like to do is:

1. Renew our CaRT canal and river license for 12 months on the strength of our current BSS certificate.

2. Get the work done as urgently as possible, hopefully before 18th October.

3. Get a new BSS cert immediately afterwards.
4. Get a gold license from January to December and get a refund on the 9 unused months of our license.

Are there any flaws with this plan?
 

What happens if your BSS cert expires during the course of your CaRT license? Are you uninsured from this point? Would CaRT take immediate steps to remove your boat from the waterways or other action against you?

In your responses please be so kind as to bear in mind I am NOT trying to circumvent the system. I am urgently trying to get the boat up to scratch and have been for ages - in fact I was even docked to get the work done a month ago (work which I had booked several months in advance) but the boatyard had overbooked and simply didn't have capacity to do it. Thanks!

Same as a vehicle mot, so long as you have a valid bss cert on the day your licence expires, you can renew you licence.

As to insurance it may or may not be a requirement to have a valid bss at all times, though it will depend on the insurance company.  That said, not all waters require a bss, so insurance companies may not mandate it.  You would have to check with them.  

 

However with or without a BSS cert, if you know your boat is unsafe and harm is caused as a direct consequence of the defect you are going to have problems claiming if the insurance company becomes aware.

[jetzi]

1 minute ago, Chewbacka said:

Same as a vehicle mot, so long as you have a valid bss cert on the day your licence expires, you can renew you licence.

As to insurance it may or may not be a requirement to have a valid bss at all times, though it will depend on the insurance company.  That said, not all waters require a bss, so insurance companies may not mandate it.  You would have to check with them.  

 

However with or without a BSS cert, if you know your boat is unsafe and harm is caused as a direct consequence of the defect you are going to have problems claiming if the insurance company becomes aware.

Thank you, that is what it seemed to be like from the CaRT website which allows me to enter the current cert number.

 

If worst case scenario I was without a BSS cert from 18 October to 1st January (when I'd need a new one anyway to apply for my gold license), assuming nothing bad happened as a result of our boat being unsafe, what would be the consequences, other than those laid out by my insurance company? Would CaRT give me trouble? Would it for example make it harder to get a license in the future?

[Chewbacka]

2 minutes ago, ivan&alice said:

Thank you, that is what it seemed to be like from the CaRT website which allows me to enter the current cert number.

 

If worst case scenario I was without a BSS cert from 18 October to 1st January (when I'd need a new one anyway to apply for my gold license), assuming nothing bad happened as a result of our boat being unsafe, what would be the consequences, other than those laid out by my insurance company? Would CaRT give me trouble? Would it for example make it harder to get a license in the future?

Honestly I don’t know, nor would I ask CRT (and I would hope they are not reading this) but I would be surprised if they have a bss expired alert system, other than when their ‘computer’ checks when renewing your licence.

[dmr]

Your plan sounds ok to me.

Don't worry too much if the BSS expires, CRT might send an email but will not take your boat out of the water, that sort of thing only happens after months/years of ignored warnings, just explain the situation to them. However you will likely not be able to go into Liverpool or use the Anderton lift etc.

Insurance is less clear and companies often use any excuse to wriggle out of paying claims. I don't think they could use an expired BSS to avoid paying, but if something was wrong with the boat and that was to blame for a loss you could be in trouble, like if the bad exhaust caused a fire.

 

The safest approach would be to get the BSS before it expires and a retest when the exhaust work is done so at least your gas/fuel and electrics etc should be declared safe. It is just possible that the BSS man might accept a photo of the repair eather than doing a re-visit.

 

............Dave

[Chewbacka]

2 minutes ago, dmr said:

Your plan sounds ok to me.

Don't worry too much if the BSS expires, CRT might send an email but will not take your boat out of the water, that sort of thing only happens after months/years of ignored warnings, just explain the situation to them. However you will likely not be able to go into Liverpool or use the Anderton lift etc.

Insurance is less clear and companies often use any excuse to wriggle out of paying claims. I don't think they could use an expired BSS to avoid paying, but if something was wrong with the boat and that was to blame for a loss you could be in trouble, like if the bad exhaust caused a fire.

 

The safest approach would be to get the BSS before it expires and a retest when the exhaust work is done so at least your gas/fuel and electrics etc should be declared safe. It is just possible that the BSS man might accept a photo of the repair eather than doing a re-visit.

 

............Dave

I have had a couple of bss examinations, and the examiner has never asked for the engine to be run, exhaust (which is lagged) was given a quick look and passed, no leak checks, can’t remember what the bss check list requires.

[jetzi]

9 minutes ago, Chewbacka said:

nor would I ask CRT (and I would hope they are not reading this)

I would not attempt to deceive CaRT, I have found them to be most accommodating as long as you are upfront and honest. I am really trying to find someone to do the work and it's just not possible as this time of year everyone wants the coatings applied in the nice weather. I'm hoping once it cools down a bit (November ish) the boat yards will free up a little.

 

4 minutes ago, Chewbacka said:

I have had a couple of bss examinations, and the examiner has never asked for the engine to be run, exhaust (which is lagged) was given a quick look and passed, no leak checks, can’t remember what the bss check list requires.

The problem with the exhaust is simply that it leaks into the weed hatch compartment. It doesn't make undue noise or anything. The compartment is full of sooty deposits and I believe this is the reason for the BSS failure, because it could catch fire. It has been this way for at least the year we have owned the boat though and it really doesn't seem like a serious danger to me. I could re-wrap the exhaust and clean out the compartment to reduce the likelihood, in fact I should make this the next item on my list.

 

14 minutes ago, Chewbacka said:

I would be surprised if they have a bss expired alert system

They sent me an automated email to let me know my BSS cert was expiring, so they are aware of it. They only mentioned it being an issue with the renewal of licenses though,  so I do have to wonder how they would feel about an expiry during the course of the license, if the boat had no BSS cert for a month or two.

Anyway, this is all a worst-case scenario thing. Hopefully all of this is a moot point and I'll be able to get the work done and the BSS certification before it expires.

[Alan de Enfield]

1 hour ago, ivan&alice said:

We also do need some work done in order to pass the boat safety examination (namely, our exhaust needs replacing).

 

 

As far as I am aware the BSS has nothing to do with the engine or exhaust.

(Remember that the BSS is about safety of the public passing the boat, and NOT the safety of the boat occupants)

 

The only mention of 'exhaust' in the BSS is in relation to 'appliances' (ie water heaters).

 

Is that your only BSS concern ?

Edited August 11, 2019 by Alan de Enfield

[Richard10002]

1 hour ago, Alan de Enfield said:

 

 

As far as I am aware the BSS has nothing to do with the engine or exhaust.

(Remember that the BSS is about safety of the public passing the boat, and NOT the safety of the boat occupants)

 

The only mention of 'exhaust' in the BSS is in relation to 'appliances' (ie water heaters).

 

Is that your only BSS concern ?

If that is the case, one would have to wonder about the surveyor who said that the exhaust needs sorting for the BSS... and he is also the BSS inspector of choice?

[Alan de Enfield]

28 minutes ago, Richard10002 said:

If that is the case, one would have to wonder about the surveyor who said that the exhaust needs sorting for the BSS... and he is also the BSS inspector of choice?

I have ceased 'wondering' about anything a surveyor or a BSS examiner says.

 

I would simply ask Ivan if he would kindly let me know which section of the BSS his surveyor claims covers the engine exhaust.

I cannot find one.

If I am wrong I shall of course 'hold my hands up'.

 

The 2017 BSS for commercial boats states :

 

To reduce the possibility of an exhaust hose fire, the exhaust system must be cooled effectively. For the same reason it's also advisable to cool your boat's engine cylinders wherever possible.

In air-cooled engines, or where water is not passed through the exhaust system, the exhaust pipe silencer and flanges must be well lagged or shielded. This will reduce the risk of a fuel source being ignited by contact with a hot surface and will also protect individuals from injuring themselves by touching a hot metal exhaust. [2.23]

 

The 2002 BSS states :

 

 

But this does not apply to private boats - maybe the examiner is getting confused. It can happen.

 

 

I have a 'library' of examples of Examiner 'failings', many of which I have reported to the BSS and non of which seem to have been actioned.

 

The BSS fee is now becoming an 'entry fee' for applying for a licence. The BSS itself is becoming of little value.

Edited August 11, 2019 by Alan de Enfield

[Richard10002]

31 minutes ago, Alan de Enfield said:

I have ceased 'wondering' about anything a surveyor or a BSS examiner says.

Yes... but the fact that the guy who has done the survey is coming back to do the BSS, means that Ivan has to convince him that the exhaust leak isn't part of the BSS, or fix it.

31 minutes ago, Alan de Enfield said:

 

I would simply ask Ivan if he would kindly let me know which section of the BSS his surveyor claims covers the engine exhaust.

I cannot find one.

If I am wrong I shall of course 'hold my hands up'.

I would hazard a guess that you are correct but, in Ivans position, that might not be worth much.

[Alan de Enfield]

29 minutes ago, Richard10002 said:

I would hazard a guess that you are correct but, in Ivans position, that might not be worth much.

I was in a similar position some years ago where the examiner wanted 'paying up front' because of previous bad experiences, so I did.

 

He came and examined the boat and failed it on not having an RCD (which is a BSS advisory - NOT - mandatory).

He simply said, "get one fitted and I'll pass it, or get someone else to come and give you a pass, I don't mind either way, I've been paid'.

 

So it was simply pay £5 for an RCD from toolstation, or pay another £150 for another examiner.

 

Yes I did complain to the BSS and was simply told 'we will investigate if our training needs improving'.

 

That, amongst other examples is why I have the jaundiced view of the BSS that I have.

 

If Ivan has not paid in advance I would still suggest he asks the question.

[Lily Rose]

4 hours ago, Alan de Enfield said:

 

 

As far as I am aware the BSS has nothing to do with the engine or exhaust.

(Remember that the BSS is about safety of the public passing the boat, and NOT the safety of the boat occupants)

 

The only mention of 'exhaust' in the BSS is in relation to 'appliances' (ie water heaters).

 

Is that your only BSS concern ?

My BSS was renewed a month ago (exactly 2 months before expiry) and the engine was not run. The engine boards were removed in order to be able to see the batteries but as far as I could tell he did not check anything else in the engine 'ole. 

[Richard10002]

1 hour ago, Alan de Enfield said:

 

If Ivan has not paid in advance I would still suggest he asks the question.

I would tend to agree.... "What is it about the exhaust that is going to make it fail the BSS?". "Are sure, Sec *.* says only...........".

 

of course, he might say that he will be failing it if not fixed, but they are welcome to find someone else who might pass it  

 

Having said all of that, if the exhaust is leaking, it ought to be fixed, and he's got until mid October to get it done, so shouldn't be an issue.

[jetzi]

I spoke to two different BSS inspectors who said they would fail the boat on the exhaust leak - not so much because the exhaust is leaking, but because the sooty deposits in the weed hatch compartment are liable to catch fire.

 

Yes, I suppose I could clean up the compartment, re-wrap the exhaust and find a none-the-wiser inspector who will hopefully not notice. But as I ought to fix it regardless, I am going to try for that as first prize.

[Alan de Enfield]

37 minutes ago, ivan&alice said:

I spoke to two different BSS inspectors who said they would fail the boat on the exhaust leak - not so much because the exhaust is leaking, but because the sooty deposits in the weed hatch compartment are liable to catch fire.

 

Yes, I suppose I could clean up the compartment, re-wrap the exhaust and find a none-the-wiser inspector who will hopefully not notice. But as I ought to fix it regardless, I am going to try for that as first prize.

 

I think this is important and potentially the thin end of the wedge.

 

How does soot get into the "weed-hatch compartment" ?

 

Please would you ask them under what section of the BSS they are failing the boat ?

 

This is becoming more and more typical of the BSS, the examiners are putting their own interpretation and intentions and thoughts as to 'what should be covered' into their 'examination' instead of just applying what is actually written.

 

It really gets me wound up and hence me compiling a dossier of examples.

I don't require the examiners name as no action will be taken against them anyway.

[jetzi]

 

4 minutes ago, Alan de Enfield said:

How does soot get into the "weed-hatch compartment" ?

 

Please would you ask them under what section of the BSS they are failing the boat ?

Quite simple, the exhaust silencer runs through a compartment at the very rear of the stern deck. This compartment is about 18 inches deep and you can access the weed hatch at the bottom of this compartment.

 

The exhaust is leaking into this compartment and depositing soot on the inside. This means I cannot use it as a locker and it makes me filthy every time I access it to clear the prop or tighten the stern gland greaser. So it is something I really do want to fix, even though the exhaust does not sound bad. If it needs replacing I'm also considering installing a hospital silencer.

 

The surveyor helpfully listed the things that would fail the boat - namely, the soot in the weed hatch, use of household, single strand twin and earth wiring for the 240V system (not multistranded), rust in the gas locker and gas bottles not chained down. I have sorted everything except the soot.

 

Note that I have not paid the surveyor to do the BSS. I am under no obligation to use him. I simply trust him and I found his survey very good, so I want to use him because I trust that he will do a good job. The BSS is more than just a box ticking exercise for me, I do actually want to ensure my boat is as safe as possible.

[Alan de Enfield]

2 minutes ago, ivan&alice said:

The exhaust is leaking into this compartment and depositing soot on the inside. This means I cannot use it as a locker and it makes me filthy every time I access it to clear the prop or tighten the stern gland greaser. So it is something I really do want to fix, even though the exhaust does not sound bad. If it needs replacing I'm also considering installing a hospital silencer.

 

Agreed it should be fixed, but it is not a BSS failure.

 

2 minutes ago, ivan&alice said:

use of household, single strand twin and earth wiring for the 240V system (not multistranded)

 

It is not best practice but it is not a BSS fail (It does not comply with the RCD requirements) but the BSS does not require flexible cable.

 

4 minutes ago, ivan&alice said:

rust in the gas locker

 

Rust 'per-se' is not a BSS failure - severe corrosion and possibility of penetration of the floor is a failure.

 

5 minutes ago, ivan&alice said:

gas bottles not chained down

 

This is covered in the BSS and not chained (or secured by other means - mine has a ratchet-strap) is a BSS failure.

[MHS]

Hi Ivan & Alice

 

I’ve not replaced an exhaust on our boat(s), but have done so on various 1950’s/70’s/80’s cars and it’s not exactly rocket science. Have you researched what parts you might need? You may well find they are readily available or you can buy a few bits to sort it. Have a look, you will feel great if you can fix it yourselves. 

[ditchcrawler]

26 minutes ago, MHS said:

Hi Ivan & Alice

 

I’ve not replaced an exhaust on our boat(s), but have done so on various 1950’s/70’s/80’s cars and it’s not exactly rocket science. Have you researched what parts you might need? You may well find they are readily available or you can buy a few bits to sort it. Have a look, you will feel great if you can fix it yourselves. 

All the connections on mine are 2" screwed apart from the flange onto the manifold

 

[WotEver]

1 hour ago, ivan&alice said:

The surveyor helpfully listed the things that would fail the boat <snip> use of household, single strand twin and earth wiring for the 240V system (not multistranded)

Oh not this again!  That is NOT a BSS failure. Just as with the leaking exhaust, ask him to show you the clause in the BSS checklist that covers it. He won’t be able to because it’s not in there. 

 

Using solid cable is poor practice and is very likely to result in failures in the future but it is NOT mentioned in the BSS. 

[jetzi]

10 hours ago, Alan de Enfield said:

Agreed it should be fixed, but it is not a BSS failure.

OK I see what you're saying. Not having done a BSS before I wasn't aware of the politics involved - it seems like quite a few BSS examiners have taken it upon themselves to go above and beyond what is stated in the requirements.

 

9 hours ago, WotEver said:

Oh not this again!  That is NOT a BSS failure. Just as with the leaking exhaust, ask him to show you the clause in the BSS checklist that covers it. He won’t be able to because it’s not in there. 

 

Using solid cable is poor practice and is very likely to result in failures in the future but it is NOT mentioned in the BSS. 

10 hours ago, Alan de Enfield said:

It is not best practice but it is not a BSS fail (It does not comply with the RCD requirements) but the BSS does not require flexible cable.

What is the RCD? I searched and all I found was this: An RCD, or residual current device, is a life-saving device which is designed to prevent you from getting a fatal electric shock if you touch something live, such as a bare wire. It can also provide some protection against electrical fires. RCDs offer a level of personal protection that ordinary fuses and circuit-breakers cannot provide.

 

I don't use the 240V system anyway so I just disconnected it, leaving one pair of sockets connected (with flexible cable) to the shore line input. The non-flexible wiring is still lying dormant in the walls (but a good few metres away from the input, so it's clearly disconnected). I wanted to leave it in so I could use it to pull through flexible cable when I install the proper 240V system.

 

10 hours ago, Alan de Enfield said:

Rust 'per-se' is not a BSS failure - severe corrosion and possibility of penetration of the floor is a failure.

The rust was pretty bad. The engineer who replaced our gas regulator and connection put the fear of God into me about gas leaking into my bilge (apart from the BSS requirements) and I immediately that day removed the rust and gave it a good three coats of Danboline. The floor was actually still very solid but I feel much better having done it.

 

10 hours ago, Alan de Enfield said:

This is covered in the BSS and not chained (or secured by other means - mine has a ratchet-strap) is a BSS failure.

Interesting addition to this - the reason my boat does not have her gas bottles chained is because on Black Prince boats (at least of this era) the gas locker has a plate with a wooden shelf half way up that the bottles slot into, which BP claimed was sufficient to secure the bottles. The inspector actually said that he'd had arguments with BP owners as to whether this was sufficient and insisted on having the bottles chained as well!

 

10 hours ago, MHS said:

I’ve not replaced an exhaust on our boat(s), but have done so on various 1950’s/70’s/80’s cars and it’s not exactly rocket science. Have you researched what parts you might need? You may well find they are readily available or you can buy a few bits to sort it. Have a look, you will feel great if you can fix it yourselves. 

I'd actually discounted the possibility of replacing it myself because it looks to require welding, at the points where the silencer penetrates into and out of the "weed hatch compartment" and also in the engine bay where there is a rod holding it in place. Also, since the exhaust is for a boat and entirely internal, I presumed that it would require quite a bit of fabrication as not all boats are going to be shaped such that they could use one off the shelf. It seems like a big job but if I could get by without welding then perhaps it would be possible? I could just cut out the existing silencer, make sure the hole is the right size for the new one, and slot it back in. And after all the exhaust is just three pipes and two elbows - if they are the correct size then surely this shouldn't be hard to fabricate... perhaps I should look more into this?