Tacet Posted December 3, 2023 Report Share Posted December 3, 2023 14 hours ago, MartynG said: I tend to lose confidence in the interpretation of the BMF and RYA when they unhelpfully provide interpretations of "self-built" and "home build" neither of which are terms found within the RCR. Either they are talking about something else altogether or they are starting from the wrong point. 1 Link to comment Share on other sites More sharing options...
David Mack Posted December 3, 2023 Report Share Posted December 3, 2023 15 hours ago, Alan de Enfield said: Question: What happens when the owner finishes fitting out the narrow boat but does not intend placing it on the market for 5 years: “does the completed boat need to comply with the RCD or just to the stage of hand over from boat builder to owner”? The answer from the EU Commission was : The boat is exempted, as long as it is not placed on the market. If the owner ever decides to place it on the market, then the completed boat needs to comply with the RCD That is not the whole story. The regulations are clear. The boat is exempt from the design and construction requirements. However if placed on the market within 5 years it is required to have a PCA and thus comply with all the RCR requirements. However if placed on the market after 5 years, then there is no requirement for a PCA, and thus RCD compliance never needs to be tested. 2 Link to comment Share on other sites More sharing options...
ditchcrawler Posted December 3, 2023 Report Share Posted December 3, 2023 4 hours ago, Tacet said: I tend to lose confidence in the interpretation of the BMF and RYA when they unhelpfully provide interpretations of "self-built" and "home build" neither of which are terms found within the RCR. Either they are talking about something else altogether or they are starting from the wrong point. And maybe both have a vested interest in this interpretation Link to comment Share on other sites More sharing options...
Peanut Posted December 3, 2023 Report Share Posted December 3, 2023 9 hours ago, ditchcrawler said: And maybe both have a vested interest in this interpretation That was my conclusion too, they are not disinterested, the BMF are there to represent the interest of their members. Link to comment Share on other sites More sharing options...
Alan de Enfield Posted December 4, 2023 Report Share Posted December 4, 2023 8 hours ago, Peanut said: That was my conclusion too, they are not disinterested, the BMF are there to represent the interest of their members. They re also the government appointed 'agent' with the resposibility for the RCD / RCR It was the RYA but they handed back the 'poisoned chalice' Link to comment Share on other sites More sharing options...
ditchcrawler Posted December 4, 2023 Report Share Posted December 4, 2023 2 hours ago, Alan de Enfield said: They re also the government appointed 'agent' with the resposibility for the RCD / RCR It was the RYA but they handed back the 'poisoned chalice' I didn't know that Link to comment Share on other sites More sharing options...
Alan de Enfield Posted December 4, 2023 Report Share Posted December 4, 2023 2 hours ago, ditchcrawler said: I didn't know that The screen shot of the HIN format (posted earlier in the thread) explains that a builder must apply to them for a builders reference. Link to comment Share on other sites More sharing options...
ditchcrawler Posted December 4, 2023 Report Share Posted December 4, 2023 6 hours ago, Alan de Enfield said: The screen shot of the HIN format (posted earlier in the thread) explains that a builder must apply to them for a builders reference. Which builder is which, does the hull builder put it on with the fitter outs reference or his reference?, when is it manufactured, when the first steel is laid or when the boat is completed and passed to the owner, could be years apart Link to comment Share on other sites More sharing options...
Alan de Enfield Posted December 4, 2023 Report Share Posted December 4, 2023 24 minutes ago, ditchcrawler said: Which builder is which, does the hull builder put it on with the fitter outs reference or his reference?, when is it manufactured, when the first steel is laid or when the boat is completed and passed to the owner, could be years apart This was discussed earlier in the thread - since the changes in the latest issue of the RCD / RCR a sailaway is now classed as a complete boat (as complete as the hull builder is going to make it) and it now has to have a HIN, all of the paperwork etc (I posted a list of requirements about 1/3rd of the way down page 3). As I said previously I do not know whever it retains that HIN, or if the 'person fitting out' (who now becomes the builder) has to apply for a 'builders ID' and if he has to give the finished vessel a new HIN. I suggested that if anyone thought they would be affected by this that they should call British Marine, & not rely on some strange fella on the internet that happens to have read a bit about it. Link to comment Share on other sites More sharing options...
Tonka Posted December 4, 2023 Report Share Posted December 4, 2023 2 minutes ago, Alan de Enfield said: This was discussed earlier in the thread - since the changes in the latest issue of the RCD / RCR a sailaway is now classed as a complete boat (as complete as the hull builder is going to make it) and it now has to have a HIN, all of the paperwork etc (I posted a list of requirements about 1/3rd of the way down page 3). As I said previously I do not know whever it retains that HIN, or if the 'person fitting out' (who now becomes the builder) has to apply for a 'builders ID' and if he has to give the finished vessel a new HIN. I suggested that if anyone thought they would be affected by this that they should call British Marine, & not rely on some strange fella on the internet that happens to have read a bit about it. Who would be the strange fella we need to ask ? 1 Link to comment Share on other sites More sharing options...
Alan de Enfield Posted December 4, 2023 Report Share Posted December 4, 2023 1 hour ago, Tonka said: Who would be the strange fella we need to ask ? I think there are a few lurking around here. Link to comment Share on other sites More sharing options...
David Mack Posted December 5, 2023 Report Share Posted December 5, 2023 13 hours ago, Alan de Enfield said: This was discussed earlier in the thread - since the changes in the latest issue of the RCD / RCR a sailaway is now classed as a complete boat (as complete as the hull builder is going to make it) and it now has to have a HIN, all of the paperwork etc (I posted a list of requirements about 1/3rd of the way down page 3). As I said previously I do not know whever it retains that HIN, or if the 'person fitting out' (who now becomes the builder) has to apply for a 'builders ID' and if he has to give the finished vessel a new HIN. Under the regs, the manufacturer or importer of a partly completed craft has to fully comply with the RCR. They also have to state that the craft will be completed by others in accordance with the regs! How on earth can they know that? Link to comment Share on other sites More sharing options...
pearley Posted December 5, 2023 Report Share Posted December 5, 2023 On 02/12/2023 at 10:22, MtB said: Mine doesn't even have a HIN as far as I know. Mine has a HIN, it just doesn't appear on the outside of the hull. Link to comment Share on other sites More sharing options...
Alan de Enfield Posted December 5, 2023 Report Share Posted December 5, 2023 1 hour ago, pearley said: Mine has a HIN, it just doesn't appear on the outside of the hull. As noted previously, some are on 'inside' the hull, often in the engine hole. Link to comment Share on other sites More sharing options...
Momac Posted December 5, 2023 Report Share Posted December 5, 2023 8 hours ago, David Mack said: Under the regs, the manufacturer or importer of a partly completed craft has to fully comply with the RCR. They also have to state that the craft will be completed by others in accordance with the regs! How on earth can they know that? Could you direct me to the part of the regulations that says this please? Link to comment Share on other sites More sharing options...
pearley Posted December 5, 2023 Report Share Posted December 5, 2023 (edited) 1 hour ago, Alan de Enfield said: As noted previously, some are on 'inside' the hull, often in the engine hole. I have a number under the engine but it's not the HIN. I have the HIN on a plate screwed to the wall inside the engine room. Edited December 5, 2023 by pearley Link to comment Share on other sites More sharing options...
David Mack Posted December 5, 2023 Report Share Posted December 5, 2023 1 hour ago, MartynG said: Could you direct me to the part of the regulations that says this please? Regulation 7 (3), last line: 1 Link to comment Share on other sites More sharing options...
Momac Posted December 5, 2023 Report Share Posted December 5, 2023 31 minutes ago, David Mack said: Regulation 7 (3), last line: I see. And agree that it completely ridiculous to expect anyone to declare that some future work will be completed by others. Link to comment Share on other sites More sharing options...
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