Water Heater BSS Clarification Wanted

[OZEY]

Hi All,

I have a question of which I cannot find a definate legal BSS answer perhaps someone could 100% clarify it.

I have a Buckingham 25, My mate has a Atlanta 24.

Both have the same Paloma water heater specification and they are also fixed in the same position on the boats.

These heaters were installed when the boats were built.

My boat failed the BSS because of the postion of the flue outlet, My mates boat passed the BSS with a no action advisory..

Mine failed as,  " possible hazzard of fumes "  and,  "potentional to touch the hot FLUE OUTLET with hands, etc".

My mates passed with an advisory because it was installed when the boat was built.

I had to reemove the heater to get a pass.

The outlet of the flue in both cases are postioned under the canopy/hood on the shelf/ceiling by the windscreen.

I understand the failure to be safe,  neither my mate or myself has never had a problem as care is always taken.

We had different BSS inspectors, but who is right???? My mate hasinstant lovely hot water I have to boil water on the gas ring.   

 

Ok now for another request as I cannot have the flue in its old position,

would it be acceptable and legal to reinstall the heater and use a doglegged flue as per attached diagram?.  

 

Thank you for your interest               

[David Mack]

BSS inspectors vary. Easiest thing would be to get your mate's inspector to do your boat.

[OZEY]

Thanks for the reply,

I had thought about that as a way round it, I understand the safety aspect,

but if you take say take  a vintage built car as a guide to a regulated and legal position seat belts or MOTs are not required.

Bearing this in mind should allowances be applied to older boats, But accepting that safety is the utmost reason to remove the boat heater

then it should be written in boat law, because it is leaving some boaters disadvantaged and other owners and their family/friends at risk.

                                   

 

[Alan de Enfield]

One inspector was wrong and one was correct. Suggest you ask the BSS office for a ruling on which is which.

 

Thats is what they are there for, they won't bite and you may not need to remove (or re-route) your heater.

 

No, you cannot do as propsed in your drawing you need 'gradual' bends (45 degrees ?) A right angle bend will not let the flue gasses esacape properly.

Edited October 30, 2020 by Alan de Enfield

[dor]

Can't believe that the flue would be allowed to exit inside a fully enclosed canopy, whether it was permitted when the boat was built or not.

Just think about it; someone having a shower while you are sat under the cover ...

[BEngo]

Can you not extend the flue so that it passes through the canopy? I can see the windscreen might be in the way but a gentle bend in the flue might clear it and be easier than making the flue come out in front of the screen.

 

You will need the canopy to be modified, and the flue and pass through hole to be properly arranged so the canopy does not burn.

 

N

[Tracy D'arth]

Your 2 right angles dog leg would not be allowed.  Too severely restricted, not complying with the makers installation instructions.

I agree with your inspector, terminal inside the cover is very dangerous, fumes well enter the boat if the heater is used with the canopy erected.

 

Can you reposition the heater so that the terminal is forward of the cover?

 

BSS inspectors are like liquorish allsorts, come in many flavours.

[Sea Dog]

15 minutes ago, Tracy D'arth said:

BSS inspectors are like liquorish allsorts, come in many flavours.

True dat. If I'm reading the diagram correctly, this particular "Bertie Bassett", rather than being the picky and wrong, may have saved the OP from Carbon Monoxide poisoning.

[OZEY]

Thank you all for your replies, I have read and acknowledge your points.

I have as suggested contacted the CRT BSS to clarify things, 

I have been informed that I should get a reply in a couple of days,

I would expect my Examiner was totally right,

I will check if the flue can be adjusted to be efficient.

Taking the flue through the canopy I think would be awkward for many reasons.

Moving the heater is an option but would mean a major redesign of boat interior.

So for the moment things have not changed.

I will post CRTs reply.

[saxplayer]

Until last year I have been gas safe registered and can say without fear of contradiction , your installation is classed as immediately dangerous. True we can class historic minor faults as does not conform to today’s standards. However where there is a real risk to life we cannot.

Installing a flue taking the emissions outside, as long as it passed a smoke test, spillage test would be such a case 

shaun 

 

[Momac]

On 30/10/2020 at 13:54, OZEY said:

Thanks for the reply,

I had thought about that as a way round it, I understand the safety aspect,

but if you take say take  a vintage built car as a guide to a regulated and legal position seat belts or MOTs are not required.

Bearing this in mind should allowances be applied to older boats, But accepting that safety is the utmost reason to remove the boat heater

then it should be written in boat law, because it is leaving some boaters disadvantaged and other owners and their family/friends at risk.

                                  

The BSS is not like an MOT. 

The BSS  requires boats to comply regardless of their age .

While I believe the MOT test requires compliance with the standards of the time when the car was new .

[Quattrodave]

44 minutes ago, MartynG said:

The BSS is not like an MOT. 

The BSS  requires boats to comply regardless of their age .

While I believe the MOT test requires compliance with the standards of the time when the car was new .

My old series 2 landrover didn't have any seat belts or IIRC a reverting light.... passed MOT every time...

[Momac]

Just now, Quattrodave said:

My old series 2 landrover didn't have any seat belts or IIRC a reverting light.... passed MOT every time...

I had a sprite that one MOT tester wanted to fail because  it had no seat belts , the combined  front sidelight indicator / glasses and dual filament bulbs were white , the hinged seat backs did not lock in position and the spring mounted headlights moved when pressed  .  It was  restored exactly to the  condition when new .

I threatened to take the matter further and received a pass after correcting a  handbrake fault that I did agree was not quite right.

 

[OZEY]

Quattrodave The BSS is not like an MOT. 

The BSS  requires boats to comply regardless of their age .

While I believe the MOT test requires compliance with the standards of the time when the car was new .

__________________________________________________________________________________________________________

Just to rejoin the conversation while I wait for the BSSs Reply.

Could you for my boat and other boaters who find themselves in a similar quandry

let us know where the rule, "  The BSS  requires boats to comply regardless of their age ",

is in the BSS reulations so we can join the dots on a serious question. as I doubt the

insurance companies will jump on any loophole not to pay out should an accident happen.

[ditchcrawler]

3 minutes ago, OZEY said:

Quattrodave The BSS is not like an MOT. 

The BSS  requires boats to comply regardless of their age .

While I believe the MOT test requires compliance with the standards of the time when the car was new .

__________________________________________________________________________________________________________

 , "  The BSS  requires boats to comply regardless of their age ",

is in the BSS reulations 

Isnt it the other way round

[Alan de Enfield]

10 minutes ago, OZEY said:

Quattrodave The BSS is not like an MOT. 

The BSS  requires boats to comply regardless of their age .

While I believe the MOT test requires compliance with the standards of the time when the car was new .

__________________________________________________________________________________________________________

Just to rejoin the conversation while I wait for the BSSs Reply.

Could you for my boat and other boaters who find themselves in a similar quandry

let us know where the rule, "  The BSS  requires boats to comply regardless of their age ",

is in the BSS reulations so we can join the dots on a serious question. as I doubt the

insurance companies will jump on any loophole not to pay out should an accident happen.

 

I believe that all boats are required to comply with the BSS that is in force at the time of examination.

Otherwise there would have been no requirement for all boats to go out and buy CO alarms.

 

Different 'types' of boats have to conform with differing 'versions' of the BSS requirements.

 

Eg,

Boats with a commercial licence have to comply with the 2002 BSS,

Leisure boats have to comply with the 2015 + additions

Hire boats have to comply with the 2017 version

 

Edit for spooling mistooks

Edited November 2, 2020 by Alan de Enfield

[BEngo]

The requirement for all boats regardless of age to pass a usage related relevant version of the BSS examination is not set out in the BSS standards, nor in  the examination  requirements.  Rather it is imposed by the licensing authorities that sponsor the BSS- CRT, The EA and The Broads Authority.   Other Navigation Authorities like ANT also require  BSC for licensing. No doubt the MLC will join in too.  

 

N

[Momac]

1 hour ago, Alan de Enfield said:

 

I believe that all boats are required to comply with the BSS that is in force at the time of examination.

Otherwise there would have been no requirement for all boats to go out and buy CO alarms.

 

I agree ...........the CO alarm requirement is  a good example .

 

 

 

 

[Momac]

1 hour ago, OZEY said:

 

insurance companies will jump on any loophole not to pay out should an accident happen.

Insurers  would take an interest  if  if a  defect was relevant to the loss.  eg if some one on the boat is killed due to CO poisoning cause by a non compliant gas installation.

 

I believe we  are required  under the terms of the C&RT  canal/river license to maintain our boats in compliance with BSS requirements at all times.  

In that the  BSS includes no reference to the age of the boat the  BSS  requirements are  certainly not frozen in time at the date the boat was built. 

 

 

 

[Alan de Enfield]

12 minutes ago, MartynG said:

Insurers  would take an interest  if  if a  defect was relevant to the loss.  eg if some one on the boat is killed due to CO poisoning cause by a non compliant gas installation.

 

I believe we  are required  under the terms of the C&RT  canal/river license to maintain our boats in compliance with BSS requirements at all times.  

In that the  BSS includes no reference to the age of the boat the  BSS  requirements are  certainly not frozen in time at the date the boat was built. 

 

 

 

 

Indeed, the BSS states that any changes to boat systems which no longer meet the requirements result in the BSSC being invalidated. As most inland insurance policies state the boat must hold a BSSC, tour insurance is invalidated, as C&RT require a BSSC for a licence no doubt the licence would be rescinded as well.

 

 

The  BSS T&Cs

 

The owner’s on-going responsibility: it is crucial to maintain the vessel in good condition in accordance with the safety requirements; and, any other licensing, registration or mooring conditions of the relevant navigation or harbour authority. The validity of a BSS pass result may be affected and can be cancelled if the vessel is not properly maintained; and/or non-compliant alterations are made....

[OZEY]

BSS Examination Checking procedures for Private Boats

There are two types of checks.

Those marked with an 'R' are Requirements, they must be complied with if a certification of boat is to be made.

Those marked with an 'A' are Advice Checks i.e. good advice that will help you meet your responsibilities as a boat owner for the safety of people aboard your boat.

Although privately-owned boats do not have to comply with advice checks to achieve BSS certification, each one represents best-safety practice and meeting them all is highly recommended.

Any listed in the Examiners report may be material to the vessel's insurance and the boat owner's duties under the law of occupier's liability.

As such, we recommend that your boat meets all BSS Advice checks. You can then be confident that as an owner, you have achieved a higher standard of safety.

 

The above taken from BSS safety scheme web page, I underlined the insurance part as a warning to those who have advisorioes.

Now I understand because it's written in the BSS that the Advisory policy could affect the safety of the crewe and boat also the insurance .

BUT where is it writtten that different BSS examiners have the right to refuse to give one craft a pass and not another for the same condition/position of a water heater?.

My mate was given an advisory, mine and was a fail, I have whole heartedly accepted the failure as a safety aspect with no sour grapes,

So where is it written that BSS examiners can pass water heaters  when there is an obvious safety concern due to fumes and exposed hot surfaces to flue outlets in cabins or hooded areas?,

Surely if BSS rules are to be followed to have a pass certificate how can they be effective if examiners are not working to the same hymn sheet? ,   PHEW!!!

[BEngo]

The BSS is an ill-managed heap of s**t.

It has neither quality control nor quality assurance measures.

Anybody with the time and money to spare can do the courses, pay the fees and become a BSS examiner.  No boat or engineering  experience or other qualification is needed. 

 

The result is inconsistency among examiners which is widely recognised among boat owners.  "If it has a BSC get the same examiner back next time" is common advice, as is "Talk to your BSS examiner" before modifying or adding anything novel in your boat.

 

The problems were obvious in 1994, but neither IWA nor RYA were prepared to oppose  the BSS to get the necessary changes. 

 

Hence we are here today.

 

N

[Alan de Enfield]

4 minutes ago, OZEY said:

Surely if BSS rules are to be followed to have a pass certificate how can they be effective if examiners are not working to the same hymn sheet? , 

Examiners are 'free spirits' paying the BSS to be able to use their scheme and issue documents.

They are not employed by the BSS but the do have 'training'. Unfortunately there appears to be no method of monitoring performance within the system.

 

Over the years I have complained to the BSS on a number of occasions about examiners 'inventing their own rules'. Each time I have received the 'stock reply'

 

"We will speak with the examiner and see if he needs any further training"

 

Surely the fact there are complaints such as :

 

"My BSSC was issued as a failure because I didn't have an RCD", and

"My BSSC was issued as a pass with fire extinguishers 5 years out of date"

 

Are strong indicators that "additional tranining" is required.

 

I even got to the stage where I'd set up half-a-dozen failures just to see how many were found.

 

On my last BSC examination, it took about 15 minutes from arrival in the marina car park to me opening the gates for him to leave.

He sat in the Saloon, said "I see you have CO alarms, &, as it passed last time (it was a different surveyor) It'll pass again"

 

Wrote out the pass, and left without even looking at the boat.

[Jerra]

I have seen it stated regularly in posts that the BSC was for the safety of others.   This case would suggest it isn't just about others rather than the boat crew.

[Alan de Enfield]

6 minutes ago, Jerra said:

I have seen it stated regularly in posts that the BSC was for the safety of others.   This case would suggest it isn't just about others rather than the boat crew.

Yes, before they could demand boats are fitted  with CO alarms they had to prove that having CO alarms would prevent passers-by and other boaters being affected by CO.

They cannot introduce laws / rules protecting you from yourself.

 

The Boat Safety Scheme, or BSS, is a public safety initiative owned equally by the Canal & River Trust and the Environment Agency. Its purpose is to help minimise the risk of boat fires, explosions, or pollution harming visitors to the inland waterways, the waterways' workforce and any other users.

Edited November 2, 2020 by Alan de Enfield