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Registering a sail away on Anglian EA waters


Telstar

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Hi All,

Thanks to everyone for the great welcome a couple of weeks ago.

 

I'm in the final stages of signing up for a new sail-away narrowboat build but can't seem to get to the bottom of registration on the Anglia Environment Agency controlled waters, the Great Ouse and the River Nene.

 

The canal trust clearly state that they give 1 years grace regarding the BSC on new sail-away's and after that year you must get a BSC regardless of what stage the fit out is at.

 

The EA website doesn't discuss sail-away's at all and after ringing the EA, nobody seems to know for sure.

They said that an RCD Annex IIIA may not be sufficient.

 

I've done some searching on this matter and I can't see any threads specific to the EA controlled waters.

Does anyone have any experience?

 

Regards, Andy.

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8 minutes ago, Telstar said:

the EA website doesn't discuss sail-away's at all and after ringing the EA, nobody seems to know for sure.

They said that an RCD Annex IIIA may not be sufficient.

I am not surprised that Annexe IIIa is not sufficient - it was deleted from the RCD in 2017, all boats, at any stage of manufacture must now have a FULL RCD,

 

There are a host of new restrictions, and a 'part built to the RCD sailaway' is now a pretty much obsolete concept.

 

I would have hoped than any commercial builder would be aware of the changes - it was introduced 3 years ago - otherwise both you and he may end up breaking the law.

Is there anything else he doesn't know ?

 

The new Directive has effectively put an end to Sailaway boats (completed to all variety of levels) being supplied with an Annex lll(a) Declaration as was previously possible under Directive 94/25/EU. Under the new Directive (2013/53/EU) Sailaways (including hull only) would need to be supplied as completed craft.

Therefore for anyone purchasing a narrow boat sailaway from 18th January 2017 must ensure you have the necessary paperwork from your boat builder that is required of a ‘completed’ craft up to the current point of completion, this includes:

  • A builders plate – makers details and technical information
  • A CE mark
  • A Craft or Hull Identification Number (CIN or HIN) – it is carried in two places on the boat; one should be hidden for security.
  • An owners manual with information needed to use and maintain the boat safety
  • A declaration of conformity (DoC)

A CE marked craft shows the craft is compliant when it was placed on the market for the first time. It remains valid unless a major alteration to the craft takes place which would require a re-assessment of the craft.

‘Major Craft Conversion’ would be applicable to the fit out of the majority of sailaway boats, and needs to be factored in when planning your fit out. Once you have completed the fit out of your sailway boat, the boat would require a Post Construction Assessment and the documentation, builders plate and CE markings all need to be updated. Although a self assessment is possible, it is not recommended as the fitter would resume all responsibility as the manufacturer and it is also a lengthy and involved process. In the worse case scenario, it could mean you are held criminally responsible if the boat sank and there was loss of life. It is recommended that you appoint a professional to complete the post construction assessment, this would be at of cost of around £2000.

 

 

Edited by Alan de Enfield
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8 minutes ago, Alan de Enfield said:

Therefore for anyone purchasing a narrow boat sailaway from 18th January 2017 must ensure you have the necessary paperwork...............

  • A declaration of conformity (DoC)

Thanks Alan,

 

EA say a DoC would give me 4 years grace to complete the boat.

My builder told me that a DoC cannot be issued to a part built boat. It must be finished to receive a DoC.

 

Sorry, I am aware that some of this content has been discussed before but I do appreciate your knowledge specific to this thread.

 

Andy.

 

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1 minute ago, Telstar said:

Thanks Alan,

 

EA say a DoC would give me 4 years grace to complete the boat.

My builder told me that a DoC cannot be issued to a part built boat. It must be finished to receive a DoC.

 

Sorry, I am aware that some of this content has been discussed before but I do appreciate your knowledge specific to this thread.

 

Andy.

 

 

I'd suggest that you may not have picked a very savvy builder, and he may just be one who wants to shift boats without complying with the RCD (that's maybe unfair, but he certainly is telling you 'porkies') A boat must have a full RCD to the stage he is selling it (and have all the 'stuff' I listed in the above post)

 

Maybe ask your builder how is handing the RCD paperwork and requirements since Annexe IIIa was abolished in January 2017.

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18 minutes ago, Alan de Enfield said:

A boat must have a full RCD to the stage he is selling it (and have all the 'stuff' I listed in the above post)

Thanks Alan,

I'll give them a ring tomorrow and report back my findings.

 

Andy.

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1 hour ago, Telstar said:

I'm in the final stages of signing up for a new sail-away narrowboat build

 

Keep your pen away from the dotted line until it's clarified. 

 

As Alan points out above, any boat builder who doesn't know they are breaking the law is one who I'd be very wary of handing any payments to!

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Just now, TheBiscuits said:

 

Keep your pen away from the dotted line until it's clarified. 

 

As Alan points out above, any boat builder who doesn't know they are breaking the law is one who I'd be very wary of handing any payments to!

 

I can only assume that there maybe some misunderstanding on terminology, but it does need to be clarified as to what is being provided and what isn't.

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Hmmmm, not quite out of the woods yet.

I emailed the builder to confirm that the boat comes with a DoC.

They have emailed me back stating the build will come with "all the correct paperwork."

I was hoping for a more definitive answer so have asked again for specific confirmation.

Just to provide the forum members with some clarity, I am dealing with one of the larger narrowboat boat builders in the country so I do have hopes that all relevant paperwork will likely be included. Just need to hear it I guess.

 

Andy.

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Wouldn't it be easier - a lot less hassle - to find a 'friendly' BSS to inspect the boat and issue a certificate on the boat with whatever there is installed at that time.

 

That's what I did - but it was many years ago and the concept of inspections was new...

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47 minutes ago, Telstar said:

Hmmmm, not quite out of the woods yet.

I emailed the builder to confirm that the boat comes with a DoC.

They have emailed me back stating the build will come with "all the correct paperwork."

I was hoping for a more definitive answer so have asked again for specific confirmation.

Just to provide the forum members with some clarity, I am dealing with one of the larger narrowboat boat builders in the country so I do have hopes that all relevant paperwork will likely be included. Just need to hear it I guess.

 

Andy.

 

If you are spending £X,000 's  surely it is not unreasonable to ask for detail on what 'correct' paperwork is supplied

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There comes a time when 'one' has to be pragmatic - rather than 'correct'.

There are far too many instances where the 'legislation' is clearly not joined up (that's where the legal mind and experiences join to get a solution - at considerable expense to those who tilt at perceived windmills).

Better it is to work your way around the mess to get a solution that works - but with minimum hassle and expense....

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11 minutes ago, OldGoat said:

at considerable expense to those who tilt at perceived windmills

Quality stuff OG. I guess I am Don and you are Sancho. Like it...

6 minutes ago, ditchcrawler said:

And the BSS gives you 4 years trouble free. Just think after 12 months the gas system is not quite complete

Thanks DC. Understood.

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47 minutes ago, ditchcrawler said:

And the BSS gives you 4 years trouble free. Just think after 12 months the gas system is not quite complete

 

37 minutes ago, Telstar said:

Thanks DC. Understood.

 

But also remember that the BSSC is issued for the level the boat is at time of test.

You add a gas system and you then need a new BSSC as the boat is different to when it was tested.

You add an electrical system ......................................

You add an engine ................................................

 

From 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....

 

Having it built to the RCD by both the hull supplier, and your fitting out, means that it will not fail the BSS.

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Just now, Alan de Enfield said:

 

 

But also remember that the BSSC is issued for the level the boat is at time of test.

You add a gas system and you then need a new BSSC as the boat is different to when it was tested.

You add an electrical system ......................................

You add an engine ................................................

 

From 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....

 

Having it built to the RCD by both the hull supplier, and your fitting out, means that it will not fail the BSS.

But if you can't get it done it the first year that is still true but you dont have that deadline after 12 months

If you install the gas electrics and fire simultaneously job done

 

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13 hours ago, Alan de Enfield said:

 

 

But also remember that the BSSC is issued for the level the boat is at time of test.

You add a gas system and you then need a new BSSC as the boat is different to when it was tested.

You add an electrical system ......................................

You add an engine ................................................

 

From 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....

 

Having it built to the RCD by both the hull supplier, and your fitting out, means that it will not fail the BSS.

I had been led to believe by that well-known source of expertise, CWDF, that that statement is not true as there are some non-overlaps. In particular, they have different aims and objectives as the BSSC is said to be about the safety of those not on the boat whilst RCD is.

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Just now, Mike Todd said:

I had been led to believe by that well-known source of expertise, CWDF, that that statement is not true as there are some non-overlaps. In particular, they have different aims and objectives as the BSSC is said to be about the safety of those not on the boat whilst RCD is.

And I believe that a boat built to the RCD will far exceed the BSS requirements.

 

Yes they have different aims and objectives but the BSS 'cherry picks' the parts it wants from the RCD, so an RCD compliant boat will pass the BSS.

 

It it not likely that the BSS would require anything 'more', or 'higher spec' than the  RCD, and C&RT (as the 'owners' of the BSS) accept the RCD for the first 4 years.

 

From the BSS website :

 

RCD Examiners Guide – The BSS & The RCRs

Almost without exception relevant clauses of 'harmonised' standards are already published compliance options under BSS requirements.  Alternative methods to 'harmonised' standards which a boat builder might use to achieve compliance with the Essential Requirements of the RCRs can be acceptable under BSS requirements.

The BSS compliments the requirements of the RCRs in carrying forward a safety regime for vessels used on inland waterways after first sale and/or first use.

In support of this concept, a BSS Examination and certification of fully complete CE marked vessels is required once four years from first sale/use has elapsed.

 

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  • 4 weeks later...

Hi All,

 

Just to conclude this thread, I have had to abandon the idea of a self fit-out sail-away for now.

My chosen builder has been such PITA with their inability to respond to emails and answer phone calls, I can't go into financial contract with them.

They seemingly couldn't confirm that I would actually receive a DoC on delivery of the sail-away.

As I said previously, they are one of the biggest builders in the country so I'm sure I probably would receive a DoC along with everything else that it legally required.

But their inability to give a straight answer to this simple question, along with many others, has deterred me from their build and I have now put a deposit on a used boat from a well known broker in the midlands.

I'll keep you posted with my experiences. Hopefully I am back on track for some boating this year.

Thanks for everyone's advice so far.

 

Andy.

 

 

 

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On 08/01/2021 at 10:39, Alan de Enfield said:

And I believe that a boat built to the RCD will far exceed the BSS requirements.

 

Yes they have different aims and objectives but the BSS 'cherry picks' the parts it wants from the RCD, so an RCD compliant boat will pass the BSS.

 

It it not likely that the BSS would require anything 'more', or 'higher spec' than the  RCD, and C&RT (as the 'owners' of the BSS) accept the RCD for the first 4 years.

 

From the BSS website :

 

RCD Examiners Guide – The BSS & The RCRs

Almost without exception relevant clauses of 'harmonised' standards are already published compliance options under BSS requirements.  Alternative methods to 'harmonised' standards which a boat builder might use to achieve compliance with the Essential Requirements of the RCRs can be acceptable under BSS requirements.

The BSS compliments the requirements of the RCRs in carrying forward a safety regime for vessels used on inland waterways after first sale and/or first use.

In support of this concept, a BSS Examination and certification of fully complete CE marked vessels is required once four years from first sale/use has elapsed.

 

We are about to put that to the test . . .  I'll let you know if anything comes up!

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2 minutes ago, Mike Todd said:

We are about to put that to the test . . .  I'll let you know if anything comes up!

 

 

Good luck - hopefully you dont get an examiner that makes up his own rules.

 

Hopefully you get an examiner that actually examines the boat (unlike the last one I had, who sat in the saloon and said "It passed last time and I can see you have CO detectors so its a pass")

 

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41 minutes ago, Alan de Enfield said:

 

 

Good luck - hopefully you dont get an examiner that makes up his own rules.

 

Hopefully you get an examiner that actually examines the boat (unlike the last one I had, who sat in the saloon and said "It passed last time and I can see you have CO detectors so its a pass")

 

As I have posted previously, my examiner said that he could see that the boat would pass as soon as he had parked his car. Admittedly he had been able to park right by the boat but the boat was moored end on from his viewpoint.

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