RCD

[Bod]

3 hours ago, jddevel said:

I will confess that my case my gas engineer used a product which I believe comes originally from Germany. It is a continuous 5 core sheathed pipe which having no memory can be "manipulated " into corners bends etc without requiring joints but specialist tooling and fittings. I had to get the CRT to investigate and acknowledge its use. The engineer was specially trained in the products use. For the electrics Loomtec supplied the loom. Water was using Uponor pipe work. Again specialist tooling, fittings and trained at Uponors UK training center. 

I would add that the hull was constructed by Bourne Boats to a sailaway level.

To my mind, the gas engineer, was he  Gas Safe qualified, with tickets for LPG and boats.

If not then anything he has done or used cannot be BSSC passed, if he was paid for the work.(unpaid becomes "competent person" and a whole new set of problems)

Does the pipe meet the BSSC standard?

 

Bod

BSSC = Boat Safety Scheme Certificate

Edited April 19 by Bod

[MtB]

4 minutes ago, Bod said:

Does the pipe meet the BSSC standard?

 

Bod

BSSC = Boat Safety Scheme Certificate

 

 

Don't confuse things. This is nothing to do with the BSSC!

 

 

[Bod]

1 minute ago, MtB said:

 

 

Don't confuse things. This is nothing to do with the BSSC!

 

 

The boat whether sold or not will have to pass the BSSC at some time to be licenced.

 

Bod

[blackrose]

When I bought my sailaway in 2005 things were obviously much simpler. My boat came with a RCD Annexe 3 Declaration of Conformity which covered me for a year, but knowing I would be keeping my boat for more than 5 years I decided to fit it out in compliance with the BSS and ignore the RCD which was permitted at the time. Is that what changed in 2017? Are self-builders no longer allowed to do that?

3 minutes ago, Bod said:

The boat whether sold or not will have to pass the BSSC at some time to be licenced.

 

Bod

 

Not if it's being inspected to RCD standards surely?

[MtB]

4 minutes ago, Bod said:

The boat whether sold or not will have to pass the BSSC at some time to be licenced.

 

Bod

 

 

So what? The thread is asking about passing the RCD. 

 

 

[Tacet]

1 hour ago, Alan de Enfield said:

 

But is slightly broader than that in that it it includes anything that can affect safety (eg new gas fitted) or stability.

 

 

 

For new boats, I agree, but we are generally talking about boats from the 90's into the 2010's. which were built to the RCD

 

We voted out of the EU in 2016, but also adopted the 'new regulations' in 2017 which is where much of these new requirements came from and went thru Parliament as "The Recreational Craft Regulations 2017" then amended by the "Product Safety and Metrology. (Amendment) (EU Exit) Regulations 2019".

 

Then a UK Government Guidance document was issued in January 2021

 

"Recreational Craft Regulations 2017 As they apply to craft being supplied in or into Great Britain from 1 January 2021"

 

 

 

It is not only the boat that must be compliant, the problem comes when the 'list' of what a distributor (broker) MUST see / have is not available :

 

. Before making a product available on the market, the distributor must verify that:

• The product bears the CE marking as required in Article 17

• It is accompanied by the following documents:

   EU Declaration of Conformity,

   instructions and safety information,

   the owner’s manual in the appropriate language for the craft and the engines if installed 

• It meets the product identification and traceability requirements, the manufacturer’s identification or the importer’s identification if applicable

 

So, if there is, for example', no certificate of compliance the broker cannot sell the boat.

That list does not include a certificate of compliance - so not sure why one is required by the broker. 

[Alan de Enfield]

2 hours ago, Tacet said:

I can't see that, as such; do you have chapter and verse? 

 

 

Things that can affect the safety if not installed to the requirement are now covered (could be a toilet that pumps directly overboard with no divert valve, a change in gas installation, etc etc .

 

 

The new Directive has also clarified the definition of Major Craft Conversion, which is now also included in the new Directive. Major Craft Conversion means ” … a conversion of a watercraft which changes the means of propulsion of the watercraft, involves a major engine modification, or alters the watercraft to such an extent that it may not meet the applicable essential safety and environmental requirements laid down in this Directive”.

 

In that regard it is like the BSS - if a boat is not fitted with a gas cooker when it has its BSS survey, and it subsequently has a gas stove fitted the BSS certificate does not correctly represent the boat and could be cancelled / withdrawn until confirmation that the boat and the new installation complies with the BSS requirements.

 

1 hour ago, Tacet said:

That list does not include a certificate of compliance - so not sure why one is required by the broker. 

 

 

Yes it does : The "Declaration of Conformity"  (that is on the list that a distributor must have) is the certificate saying that the boat is compliant.

 

Part of the certificate of compliance for my 'Cat'

 

In English "Written Statement of Compliance" (top left of picture)

In French " Declaration Ecrite De Conformite" (Top centre of picture)

 

 

 

 

 

'Europe' has always fully enforced the RCD requirements.

 

This is one of the pieces of paper that was 'missing' and meant that the boat could not be sold (the other was the VAT Paid certificate) which allowed me to offer such a 'ridiculous' price for the boat.

 

My offer was accepted and I contacted the manufacturer and obtained a copy of the CoC. 1st step on getting the boat out of Europe .

Then the battle with customs started - but you know the story.

Edited April 19 by Alan de Enfield

[David Mack]

55 minutes ago, Alan de Enfield said:

Major Craft Conversion means ” … a conversion of a watercraft which changes the means of propulsion of the watercraft, involves a major engine modification, or alters the watercraft to such an extent that it may not meet the applicable essential safety and environmental requirements laid down in this Directive”.

And that is such a generic and vague description  that could prompt arguments for years about what is or is not a Major Craft Conversion!

2 hours ago, Bod said:

The boat whether sold or not will have to pass the BSSC at some time to be licenced.

 

Bod

To be licenced the boat needs a BSC. To be sold by a broker the boat now apparently needs paperwork to demonstrate RCR compliance. Two completely different sets of standards. And scope for much confusion amongst boat owners and prospective boat owners who are not immersed in the minutiae of such matters!

[Col_T]

Perhaps brokers will alter their stance when they find more and more boats being sold privately, rather than through their businesses?

[Alan de Enfield]

12 minutes ago, Col_T said:

Perhaps brokers will alter their stance when they find more and more boats being sold privately, rather than through their businesses?

 

Or, after a broker or two have been fined for selling boats without an RCD ..................................

Or, British buyers become as aware of the legal requirements as our continental cousins.

 

As written, the law includes not only business sales (a legal person) but a private individual (a natural person) as well and prevents them from selling a boat without the correct paperwork.

(But good luck trying to enforce that one).

 

3.4 Distributor’s obligations The distributor is any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes the product available on the market......................

[jddevel]

There are those on here -like most forums I read, who take a delight in pointing out to those less informed retrospectively the error of their ways ( Watch youtube song " Oh God it`s hard to be humble when your perfect in every way). I realize having many years ago having a "short" tutorial in English Law - Caveat Emptor. However I will quote from the broker potentially being used " Are you aware if the boat had any major modifications since it was built-if so what and when?  e.g. Alterations to electrical systems like solar panels, new larger inverter, installation of solid fuel stove ,installation of diesel heating. IF YES HAS IT GOT A POST CONSTRUCTION ASSESSMENT. If NO this may effect the sale of the boat

 This I might suggest covers many contributors on this forum INCLUDING those "experts" who have decided they know how to add internet upgrade equipment and the necessary upgraded electrical equipment ( more solar bigger batteries etc). We can all produce pages of information gained from the internet as to what is required for this and that but I live in the real world. Heaven forbid what is going to happen with the advancement of A.I. I don`t consider myself a total idiot just a human who makes mistakes and in this case will financially have to pay for it. Such is life and even nearing 80 I`m still like the game of chess still learning.

Incidentally none of those contributing on here have told of their personal experience or given advice of a course of action other than I seem to have been presented with namely bite the bullet and shell out £4000 plus for an "expert" to prod and poke the boat.  

[Paul C]

29 minutes ago, Col_T said:

Perhaps brokers will alter their stance when they find more and more boats being sold privately, rather than through their businesses?

 

There's going to be a lot (I'd say, a majority) of boats which do have a valid RCD and haven't been sufficiently modified to need a PCA - you know, the "standard" boats which have been built by a reasonable builder and the owner(s) haven't been the DIY tinkering type. Brokers will be happy to sell those kind of boats.

 

I don't think there will be enough modified and DIY-built sailaways to worry brokers into altering their stance.

[Alan de Enfield]

8 hours ago, David Mack said:

And that is such a generic and vague description  that could prompt arguments for years about what is or is not a Major Craft Conversion!

 

 

Is it ?

 

The definition :-

.........or alters the watercraft to such an extent that it may not meet the applicable essential safety and environmental requirements laid down in this Directive”.

 

A boat is built without a gas system, it has its CoC 'as built'

The owner then decides it'd be nice to be able to boil a kettle so does a DIY gas installation which is a bodge and totally non compliant with the RCD / RCR requirements.

As it does not "meet the applicable essential safety and environmental requirements laid down in this Directive”. it requires a PCA

 

(The question will always be "how will anyone know, and who cares anyway" but that is not what we are discussing.)

[jddevel]

Yes incidentally the hull came with a 111A certificate of conformity.

[Alan de Enfield]

10 minutes ago, jddevel said:

Incidentally none of those contributing on here have told of their personal experience or given advice of a course of action other than I seem to have been presented with namely bite the bullet and shell out £4000 plus for an "expert" to prod and poke the boat.  

 

That is hardly fair - you have twice been asked for information about when and where and from whom you bought the boat and what exact age is the boat, and what paperwork did you get with the boat.

 

Reason is that depending on your answers the issue may be irellevant.

 

So far you have not answered.

Your choice,

[MtB]

20 hours ago, jddevel said:

So the thorny subject of RCDs. Have members had experience of retrospective issue of RCD on a sailaway craft please. Apparently the original belief on my part that a craft owned (from new) for more than 5 years is not now necessarily applicable. The bureaucrats are on the case with their red tape and interference!!

 

A hypthetical question.

 

If your memory told you your sailaway was built in 1997 or earlier, and by some unfortunate chance all the paperwork was missing or lost, how might a broker or anyone else prove otherwise?

 

 

[BoatinglifeupNorth]

14 minutes ago, Alan de Enfield said:

 

That is hardly fair - you have twice been asked for information about when and where and from whom you bought the boat and what exact age is the boat, and what paperwork did you get with the boat.

 

Reason is that depending on your answers the issue may be irellevant.

 

So far you have not answered.

Your choice,

Read his previous posts he basically says what he has done and from whom he bought the shell from.He bought a sailaway from Bourne Boats and self fitted using people from the house building trade.

 

 

[MrsM]

17 minutes ago, MtB said:

 

A hypthetical question.

 

If your memory told you your sailaway was built in 1997 or earlier, and by some unfortunate chance all the paperwork was missing or lost, how might a broker or anyone else prove otherwise?

 

 

I am probably wrong but I thought the hull number that is permanently built/pressed/welded into the steel includes the year that the hull was built? 

[MtB]

Just now, MrsM said:

I am probably wrong but I thought the hull number that is permanently built/pressed/welded into the steel includes the year that the hull was built? 

 

That's a good point. I had a 1998 boat with no hull number many years ago.

 

And my current boat was supposedly built in 2000 and purchased with no accompanying paperwork or RCD has no HIN either. Not that I've ever found anyway leading me to wonder when it was really built. The shell builder closed down many years ago so no chance of accessing their records.

 

 

[MrsM]

From AdE on 29/11/23:-

If you bought it as a sailaway, did you get the RCD approval to the stage it was sold at ?

 

 

A boat (built to RCD compliance) must have the HIN / CIN marked in two places, the RCD specifies the 'public place' and the other should be in a hidden location only known to the hull builder.

From memory the 'public' HIN / CIN must be made so it is incapable of being removed (ie stamped into the hull) at the stern on the starboard side. Typically it should be on the 'outside' of the boat, but I have known of them 'inside' the transom.

 

The builder should be able to provide you with the HIN from their records (I don't think they are supposed to divulge the hidden location as you could have stolen the boat and tamper with the marking).

 

 

The HIN should also be specified on the Bill of Sale, the Declaration of Compliance and in the Owners manual.

 

Example of the HIN on the Declaration of Compliance (under technical data)

 

 

 

 

The format should be :

 

 

 

 

[BoatinglifeupNorth]

@jddevel who was the broker? 
If he is asking for a POC to be done on Narrowboats that have recently had solar panels self fitted by the owner he will struggle to get boats on brokerages.

 Seems a Jobsworth with no common dog, a bit like some on here🐕

“Stability Test” I moor where some, if not the most expensive Narrowboats are built in the Country. I have never seen them or know of any builder that have put 6/8/12 75kg people on the boat or the equivalent weight and done Stability testing and shown the test results. 
 Try different brokers, there are brokers that will sell it and there are brokers that will not want it.

[MrsM]

Just now, MrsM said:

From AdE on 29/11/23:-

If you bought it as a sailaway, did you get the RCD approval to the stage it was sold at ?

 

 

A boat (built to RCD compliance) must have the HIN / CIN marked in two places, the RCD specifies the 'public place' and the other should be in a hidden location only known to the hull builder.

From memory the 'public' HIN / CIN must be made so it is incapable of being removed (ie stamped into the hull) at the stern on the starboard side. Typically it should be on the 'outside' of the boat, but I have known of them 'inside' the transom.

 

The builder should be able to provide you with the HIN from their records (I don't think they are supposed to divulge the hidden location as you could have stolen the boat and tamper with the marking).

 

 

The HIN should also be specified on the Bill of Sale, the Declaration of Compliance and in the Owners manual.

 

Example of the HIN on the Declaration of Compliance (under technical data)

 

 

 

 

The format should be :

 

 

 

 

So the last 2 letters of the HIN should date the hull. In the OP's case if this is 97 or earlier does this mean the lack of a RCD/R is no longer an issue?

[Tony Brooks]

51 minutes ago, jddevel said:

ncidentally none of those contributing on here have told of their personal experience or given advice of a course of action other than I seem to have been presented with namely bite the bullet and shell out £4000 plus for an "expert" to prod and poke the boat. 

 

In my case because I specifically avoided the problems by buying a 1991 boat that was and would now, not be in scope of the RCD/RCR. Then, I am not so concerned about shin, dent free paintworks and fancy interior fit out. I think I knew the law as it applied, so avoided any complications.

[BoatinglifeupNorth]

2 minutes ago, MrsM said:

From AdE on 29/11/23:-

If you bought it as a sailaway, did you get the RCD approval to the stage it was sold at ?

 

 

A boat (built to RCD compliance) must have the HIN / CIN marked in two places, the RCD specifies the 'public place' and the other should be in a hidden location only known to the hull builder.

From memory the 'public' HIN / CIN must be made so it is incapable of being removed (ie stamped into the hull) at the stern on the starboard side. Typically it should be on the 'outside' of the boat, but I have known of them 'inside' the transom.

 

The builder should be able to provide you with the HIN from their records (I don't think they are supposed to divulge the hidden location as you could have stolen the boat and tamper with the marking).

 

 

The HIN should also be specified on the Bill of Sale, the Declaration of Compliance and in the Owners manual.

 

Example of the HIN on the Declaration of Compliance (under technical data)

 

 

 

 

The format should be :

 

 

 

 

Lots of older boats haven’t got a welded in HIN. The post isn’t about this it’s about a specific boat and the RCD at the end of the finished build, so makes no difference the finished completed boat is a totally different and more complexed RCD than from the shell.

[Tacet]

10 hours ago, Alan de Enfield said:

 

Things that can affect the safety if not installed to the requirement are now covered (could be a toilet that pumps directly overboard with no divert valve, a change in gas installation, etc etc .

 

 

The new Directive has also clarified the definition of Major Craft Conversion, which is now also included in the new Directive. Major Craft Conversion means ” … a conversion of a watercraft which changes the means of propulsion of the watercraft, involves a major engine modification, or alters the watercraft to such an extent that it may not meet the applicable essential safety and environmental requirements laid down in this Directive”.

 

In that regard it is like the BSS - if a boat is not fitted with a gas cooker when it has its BSS survey, and it subsequently has a gas stove fitted the BSS certificate does not correctly represent the boat and could be cancelled / withdrawn until confirmation that the boat and the new installation complies with the BSS requirements.

 

 

Your quoting something other than the RCR/RCD but even so, if one makes a gas installation that undoubtedly meets the Essential Requirements - it's not a Major Craft Conversion, so no need for the PCA

10 hours ago, Alan de Enfield said:

 

 

Yes it does : The "Declaration of Conformity"  (that is on the list that a distributor must have) is the certificate saying that the boat is compliant.

 

Part of the certificate of compliance for my 'Cat'

 

In English "Written Statement of Compliance" (top left of picture)

In French " Declaration Ecrite De Conformite" (Top centre of picture)

 

 

 

 

 

The various terms are being muddled by you.  And none you mention refer to a Certificate of Compliance as you earlier said was required.  If you mean Declaration of Conformity (as per RCR) then best to say so