New RCD, Old engine

[Simondrains]

Hi all.

 

Is it possible to fit an old engine on a new boat and still conform to the RCD?

I've been searching and have found some vague reference to vintage engines, but not enough to go on, and nothing official.

The engine in question is a Perkins 4236.

 

Thanks

Si

[Maverick]

Hi all.

 

Is it possible to fit an old engine on a new boat and still conform to the RCD?

I've been searching and have found some vague reference to vintage engines, but not enough to go on, and nothing official.

The engine in question is a Perkins 4236.

 

Thanks

Si

 

With you saying a new boat I assume you meen a sailaway? Most folk go for the sailaway with engine fitted I would have thought.

 

Getting an old engine , gearbox and stern gear to fit and line up on the mountings would be a nightmare.

[Simondrains]

With you saying a new boat I assume you meen a sailaway? Most folk go for the sailaway with engine fitted I would have thought.

 

Getting an old engine , gearbox and stern gear to fit and line up on the mountings would be a nightmare.

 

No, its a self build 50ft Branson barge. The engine is fitted, all fine and dandy. (I'm an engineer to trade).

But my original plan to live on the boat has changed, 5 years on from laying the keel, so the accompanying plan to get a BSC isn't as good an option as a self certified RCD cat D. The only sticking point is the engine. Everything else is sorted.

 

I will get in touch with Perkins Sabre to see if they can furnish me with appropriate certs, but it seems unlikely. The other option is an independent assessment of emissions/noise, and for the cost, I might as well buy a new engine! (slight hyperbole there, but not much).

 

So... any loopholes anyone's aware of which I can turn to my advantage?

 

Otherwise it's the BSC, and a lovely water borne property to let!

Edited September 16, 2007 by Simondrains

[John Orentas]

Haven't a clue about the RCD but fitting an engine is no where near as tricky as people may think. Anybody who can use a rule in a confident manner can do it, one of the problems is that it is very long winded writing the detailed method which is why I won't embark on it now. It is though one of those jobs that is easier to 'do' than to describe.

 

There are one or two little pitfalls which I could go into but most is very straight forward.

[ChrisPy]

I guess the problem is knowing where to start.

 

If the stern tube is already in place then you will run a stringline (wire) fixed concentrically through the tube, and it just kind of follows on automatically from there.

 

It is unlikely that an old engine complies with the RDC requirements for noise and exhaust emissions, so it may compromise your freedom to sell the boat within 5 years.

 

An interesting angle I recall from earlier discussions. The RCD is needed for boats that are 'put on the market'. It was suggested that if you do not actually offer the boat for sale, but are fortunate enough that someone persuades you to let him buy it from you, then you may be outside the terms of the regulations.

Edited September 16, 2007 by chris polley

[GUMPY]

Hi all.

 

Is it possible to fit an old engine on a new boat and still conform to the RCD?

I've been searching and have found some vague reference to vintage engines, but not enough to go on, and nothing official.

The engine in question is a Perkins 4236.

 

Yes

Have a look here and scroll down to the relavent bit:

http://users.skynet.be/sky34301/cert.html

 

I quote:

Engine Exhaust Emission - Old Engine

Text from DIRECTIVE 2003/44/EC AMENDING THE RECREATIONAL CRAFT DIRECTIVE AND COMMENTS TO THE DIRECTIVE COMBINED

 

(d) for products falling under (a)(ii), ( and ©, the provisions of this Directive shall only apply from the first placing on the market and/or putting into service after the date of entry into force of this Directive.

 

This paragraph specifies that the new requirements for products falling under (a)(ii) (personal watercraft), ( (with regard to exhaust emissions) and © (with regard to noise emissions) apply only to these products from their first placing on the Community market or first putting into service after the date of entry into force of this Directive. The dates by which all products must comply with the provisions of the Directive are stated in Article 3. ......

 

...... Propulsion engines with regard to exhaust emission requirements Propulsion engines installed or intended for installation on or in recreational craft or personal watercraft that are first placed on the Community market or put into service prior to 1st January 2005 (date of entry into application of the provisions of Directive 2003/44/EC) or, ultimately either until the 31st December 2005 (end of the transitional period specified in Article 3.2( of Directive 2003/44/EC) for compression ignition and four-stroke spark ignition engines or the 31st December 2006 (end of the transitional period specified in Article 3.2© of Directive 2003/44/EC) for two-stroke spark ignition engines are not required to comply with the exhaust gas emission requirements, even if subsequently placed on the market again as second hand products or subject to a ‘major engine modification’ after the relevant date.

 

Propulsion engines imported into the Community market from third countries after either the 31st December 2005 (end of the transitional period specified in Article 3.2( of Directive 2003/44/EC) for compression ignition and four-stroke spark ignition engines or the 31st December 2006 (end of the transitional period specified in Article 3.2© of Directive 2003/44/EC) for two-stroke spark ignition engines are required to comply with the exhaust gas emission requirements, even if they are second hand products that were first used prior to these dates, unless they have been previously placed on the market or put in service in the EEA.*

 

 

--------------------------------------------------------------------------------

 

Note :- In other words, any engine already in existence before the dates specified above can be used or even fitted into a new craft and not have to meet the exhaust emission requirements.

 

The Declaration of Exemption in Word .doc format can be downloaded from here:

http://users.skynet.be/sky34301/uploads/De...ld%20Engine.doc

 

Julian

Edited September 16, 2007 by idleness

[ChrisPy]

Note :- In other words, any engine already in existence before the dates specified above can be used or even fitted into a new craft and not have to meet the exhaust emission requirements.

well that's one way to read it.

 

I understand that a new boat is a complete entity and everything needs to comply. I would be glad to be proved wrong.

[Gary Peacock]

well that's one way to read it.

 

I understand that a new boat is a complete entity and everything needs to comply. I would be glad to be proved wrong.

 

The above along with self declared exemption certificates is a bit of legal excuse me note and since the engine doesn't conform strictly speaking the boat shouldn't conform either.

 

I have never know of any provision for partial conformity, if you think about it you could write that kind of declaration for most things on the boat.

 

I suspect that the advice to do this came from the BMF or RYA who in circumstances like this have far more experience then the DTI or whatever it is called now and would seen by them to be the most honest way of bending the rules to allow for an historic engine to be fitted to a narrowboat.

 

There are a few areas where the Europeans and there rules just don't fit the UK inland waterways market and common sense says things need at be "adjusted" unfortunately if it comes to the crunch the law might see it differently.

 

I would sell it without the engine installed on a Annex IIIa declaration for a part completed boat if you provide all that you are in the clear and you can even sell them the engine too separately!

Edited September 16, 2007 by Gary Peacock

[GUMPY]

well that's one way to read it.

 

I understand that a new boat is a complete entity and everything needs to comply. I would be glad to be proved wrong.

 

Mike Clarke who owns the site from which I quoted in my previous post was very heavily involved in the RCD legislation and fought long and hard to get that exemption. He is probarbly one of the most knowledable people on our side.

 

At present he is looking into TRIWV which looks like all boats over 20m will have to conform to unless the MCA get an exemption which it looks like they will not bother. These rules are retrospective so that could cause some great hedaches for owners of boats over 20m (65ft) some of the rules will just not be possible on a narrowboat.

 

Ireland has a complete exemption but not the good old UK.

 

Details here

Via the MCA

http://www.mcga.gov.uk/c4mca/mcga-guidance...cdirective2.htm

 

Includes some UK proposed amendments.

 

Direct to EU

http://eur-lex.europa.eu/LexUriServ/LexUri...001:0260:EN:PDF

 

Julian

Edited September 16, 2007 by idleness

[Gary Peacock]

If you fancy a very boring read I think this might give more clues HERE

 

Saying that on reading it there is a bit on historic but can't really see much else that is useful.

 

It sounds like one of those numerous things in the RCD that doesn't make a lot of sense in the real world.

Edited September 16, 2007 by Gary Peacock

[Simondrains]

Thanks for the replys folks. Julian, i'm going to follow the stuff you posted to the letter and keep me fingers crossed. It's amazing how far (up the creek) wishful thinking can get you.

 

The rest of you, thanks... but TBH it all left me none the wiser (not much, anyway)

 

Regards all

 

Si

[Gary Peacock]

Thanks for the replys folks. Julian, i'm going to follow the stuff you posted to the letter and keep me fingers crossed. It's amazing how far (up the creek) wishful thinking can get you.

 

The rest of you, thanks... but TBH it all left me none the wiser (not much, anyway)

 

Regards all

 

Si

 

I doubt you will have any problems with an individual build, the RCD is all about producing production boats and even in that sector it's a shambles.

Edited September 18, 2007 by Gary Peacock