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Is a closed, i.e impassable, bulkhead positioned between the engine space and the living quarters, a non compliance to the RCD ?

 

My surveyor thinks that there should be a means of entry between the two parts of the vessel.

 

Section 5.1.1 of the RCD "suggests" that they should be separated, so to minimise the risk of fire, toxic fumes, noise etc.

 

Please, what is the considered opinion on the forum. The boat fit-out has stopped until this can be resolved.

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Many conversions of former working narrow-boats built accommodating space straight on to the front of the original engine room bulkhead, leaving it solid, with no way through.

 

I'm not aware of any exemption because the boats are old, so I think it cannot be disallowed.

 

However, I hope there will be adequate fire exits at what would otherwise be the closed end of the cabin, (which can always be used, however you are moored, and even in a narrow lock). In my view anyone who has a layout where you can't escape quickly (from anywhere) in an emergency probably has some kind of death wish. Boat fires go from almost nothing to total infernos in a very short time, if conditions support it.

 

(And yes, that extends to those who have a perfectly good set of cabin doors, but choose to be in the accommodation whilst they are securely locked from the outside by a hefty padlock - madness, in my view, unless there is an alternate exit right nearby.)

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I believe the requirements are similar to a building, where there needs to be a choice of alternative escape routes, but from any point in the vessel there can be a short route which is unique. e.g. from a bathroom to the corridor.

 

When I checked if I needed a central side hatch I found that windows or Houdini hatches are an acceptable alternative escape route, provided they are easily broken or pushed out. I believe that portholes would not normally be sufficient unless they are very large.

 

The relevant ISO is clear about this, but I don't have it with me just now.

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Our 3 boats all have a solid bulkhead between the engine room and the cabin. We have a side door in the back bedroom which complies as this is the means of escape. On my brother's boat, he didn't want a side door in the bedroom so we put an escape hatch in the roof, again this passes no problems. :lol:

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Our 3 boats all have a solid bulkhead between the engine room and the cabin. We have a side door in the back bedroom which complies as this is the means of escape. On my brother's boat, he didn't want a side door in the bedroom so we put an escape hatch in the roof, again this passes no problems. :lol:

 

Ditto. for my new build, there are side doors and roof hatch in, or within 2mtrs of the bedroom, but there are no means to have access from the bedroom to the engine spaces, This was in my perceived compliance with 5.1.1 of the RCD. Now the surveyor finds it "inconvenient and impracticable".

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Ditto. for my new build, there are side doors and roof hatch in, or within 2mtrs of the bedroom, but there are no means to have access from the bedroom to the engine spaces, This was in my perceived compliance with 5.1.1 of the RCD. Now the surveyor finds it "inconvenient and impracticable".

You need to find another examiner who will simply check compliance and not quote his opinion. My boat is 10 years old, my dad's 27 years old both set up like this and both in full compiance.

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Is this a surveyor assessing RCD compliance, or a BSS examiner? In either case, they should only check for compliance against the established guides, regulations and standards.

 

Of course a surveyor making a report on behalf of a potential purchaser may make subjective observations which unreasonably criticise the arrangements, but I that is outside the vendor's control.

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Is this a surveyor assessing RCD compliance, or a BSS examiner? In either case, they should only check for compliance against the established guides, regulations and standards.

 

Seemingly he's checking for both against scale drawings supplied to the boat fitter, his comments are that he will "insist on a door" into the engine room. As the design calls for a permanent cross bed, his insistence will mean a whole revamp of the bedroom.

Section 5.1.1 of the RCD states that any bulkhead should be capable to minimising the risk of fire, toxic fumes, noise etc from entering the living space.

 

Does a bulkhead without openings meets this requirement ??

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Choogh

 

You seem un happy with an "experts" advice, and from inference are dealing with a boat fitter/yard re a build also,

 

It would seem (over obvious?) that the builder must build a new boat that meets current legislative requirements.

 

a surveyour should be yr expert to review confirm that the vessel does comply - is safe / insureable.

 

Can we assume this is a narrow boat or??

 

As stated already there boats with exits forward from the engine room and those without.

 

Boat man cabins that habe no entry to the engine hole have like many small spaces always been that way - a short direct entry exit route,

 

Engine holes often have side doors on each side to allo access / exit

Rest of teh boat depening on size will need to compy - that from my understanding means doors and one other exit... but style/size and whats fitted all have a bearing... eg no stoves, gas etc may change the requirements as the risks change

 

suggest that you ask the hard questions of your experts and get them to demonstrate that their work is compliant - thats what yr paying for!

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Choogh

 

You seem un happy with an "experts" advice, and from inference are dealing with a boat fitter/yard re a build also,

 

It would seem (over obvious?) that the builder must build a new boat that meets current legislative requirements.

 

a surveyour should be yr expert to review confirm that the vessel does comply - is safe / insureable.

 

Can we assume this is a narrow boat or??

 

As stated already there boats with exits forward from the engine room and those without.

 

Boat man cabins that habe no entry to the engine hole have like many small spaces always been that way - a short direct entry exit route,

 

Engine holes often have side doors on each side to allo access / exit

Rest of teh boat depening on size will need to compy - that from my understanding means doors and one other exit... but style/size and whats fitted all have a bearing... eg no stoves, gas etc may change the requirements as the risks change

 

suggest that you ask the hard questions of your experts and get them to demonstrate that their work is compliant - thats what yr paying for!

 

As in most walks of life, it's a matter of interpretation, the hull was built to meet the requirements of RCD and the drawings of the interior reflected the demands of the RCD.

 

If you read the RCD, you will find, along with most "directives" that they are not a detailed, as in prescriptive, set of recommendations, rather a broad brush of major demands, leaving the specifics up to the builder, I'm having difficulties with one item, I read the directive in one way (along with most of the posters here) and my "expert" reads it another way. I was simply asking for advice, nothing else.

Oh, for what it's worth, it's a narrowboat. Not that I can see it's makes any difference to the RCD.

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I suppose a difference with us is that we built our 3 boats ourselves and did not worry about passing the RCD, which I feel is worthless anyway but that's another matter. Our boats have passed the BSS with this set up with no problem. I still say you need to find another surveyor. My boat was surveyed after being finished for insurance purposes and it passed that too.

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ISO 9094 says:

 

The distance to the nearest exit to the open air shall not exceed 5 m.

Where living or sleeping accommodation is separated from the nearest exit by a solid partition (e.g. a door) and

leads directly past a cooker or engine space, an alternative exit shall be provided.

 

Any exit from an accommodation space shall have the following minimum clear openings:

e.g. circular shape: diameter 450 mm;

 

Exits shall be readily accessible and shall be capable of being opened from the inside and the outside

when secured and unlocked.

 

Where deck hatches are designated as exits, footholds, ladders, steps or other means shall be provided.

These aids shall be permanently installed and non-removable. The vertical distance between the upper foothold

and the exit shall not exceed 1,2 m.

 

 

so why will your design not comply?

 

 

.............. oh, and that is highly prescriptive in my view.

Edited by ChrisPy
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ISO 9094 says:

 

The distance to the nearest exit to the open air shall not exceed 5 m.

Where living or sleeping accommodation is separated from the nearest exit by a solid partition (e.g. a door) and

leads directly past a cooker or engine space, an alternative exit shall be provided.

 

Any exit from an accommodation space shall have the following minimum clear openings:

e.g. circular shape: diameter 450 mm;

 

Exits shall be readily accessible and shall be capable of being opened from the inside and the outside

when secured and unlocked.

 

Where deck hatches are designated as exits, footholds, ladders, steps or other means shall be provided.

These aids shall be permanently installed and non-removable. The vertical distance between the upper foothold

and the exit shall not exceed 1,2 m.

 

 

so why will your design not comply?

 

 

 

T

 

.............. oh, and that is highly prescriptive in my view.

 

Yes it is.

My statement..

...."If you read the RCD, you will find, along with most "directives" that they are not a detailed, as in prescriptive, set of recommendations, rather a broad brush of major demands, leaving the specifics up to the builder". This was after reading the RCD as published by the BMF . "Boat Builders Guide".

 

Obviously the ISO is prescriptive, the RCD (BMF publication) in my opinion, less so...

 

To whom do I appeal this ruling, is there an body set up to hear these type of disputes ?

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My old narrowboat (trad stern), had a full bulkhead between the engine room and bedroom with a small escape hatch (the bottom was about 4ft off the floor). I could get through it by standing on the bed.

 

Perhaps this might be a solution?

Edited by blackrose
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Yes it is.

My statement..

...."If you read the RCD, you will find, along with most "directives" that they are not a detailed, as in prescriptive, set of recommendations, rather a broad brush of major demands, leaving the specifics up to the builder". This was after reading the RCD as published by the BMF . "Boat Builders Guide".

 

Obviously the ISO is prescriptive, the RCD (BMF publication) in my opinion, less so...

 

To whom do I appeal this ruling, is there an body set up to hear these type of disputes ?

 

Why do you need to "appeal" this.

 

If you have a surveyor who doesn't know his stuff, and is brass-plating the rules with his opinions, simply sack him, and find another surveyor.

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Yes it is.

My statement..

...."If you read the RCD, you will find, along with most "directives" that they are not a detailed, as in prescriptive, set of recommendations, rather a broad brush of major demands, leaving the specifics up to the builder". This was after reading the RCD as published by the BMF . "Boat Builders Guide".

 

Obviously the ISO is prescriptive, the RCD (BMF publication) in my opinion, less so...

 

To whom do I appeal this ruling, is there an body set up to hear these type of disputes ?

RCD is a directive. it is not a BMF publication, it is European Law, although you may be able to buy it in a published version from BMF.

it directs you to the ISOs. the ISOs are prescriptive.

 

if your surveyor uses some other standards, like his own subjective interpretation of what is safe, and ignores the ISO, then he is not worth his salt.

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Why do you need to "appeal" this.

 

If you have a surveyor who doesn't know his stuff, and is brass-plating the rules with his opinions, simply sack him, and find another surveyor.

 

Isn't that rather like trying to sue a solicitor.. Kick one and they all limp ?

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he who pays the piper ...............

 

if he doesn't accept the ISO it seems like he's wasting your and your builder's time and money.

 

in the oil industry we employ third party inspectors to survey and check everything.

if they find fault with something that is allowed by the codes, standards and specifications they are immediately removed.

 

of course if you want a project manager and 'architect' instead of a surveyor, expect to have lots of changes and to have to pay for lots of extras.

 

can you tell us what are his Terms of Reference?

Edited by ChrisPy
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The surveyor now says that the vessel will not meet the requirements for a Man Overboard situation, i.e being no access from the steering position through the boat to render assistance. He feels that the design is not in compliance with the RCD. The person trying to assist would have to "shuffle" along the gunwales and this is unsatisfactory.

 

Does he have a point ?

 

I'm single crew, but if anyone "fell in" from the front end, I suppose they would pass me at the back end eventually and I could "throw a line" :-)

 

he who pays the piper ...............

 

if he doesn't accept the ISO it seems like he's wasting your and your builder's time and money.

 

in the oil industry we employ third party inspectors to survey and check everything.

if they find fault with something that is allowed by the codes, standards and specifications they are immediately removed.

 

of course if you want a project manager and 'architect' instead of a surveyor, expect to have lots of changes and to have to pay for lots of extras.

 

can you tell us what are his Terms of Reference?

 

I am a project manager in the oil and gas industry...!! Offshore ..

No idea, what his point of reference s is or are, but I will find out later tonight.

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The surveyor now says that the vessel will not meet the requirements for a Man Overboard situation, i.e being no access from the steering position through the boat to render assistance. He feels that the design is not in compliance with the RCD. The person trying to assist would have to "shuffle" along the gunwales and this is unsatisfactory.

 

Does he have a point ?

 

What is the problem with going along the roof?

 

If need to get from tiller to well deck in a hurry, I sure as hell don't go through the boat.

 

Sounds to me like your surveyor has decided that he won't pass this design, and no matter what you say will try and find something to put up against it.

 

It sounds like the time has arrived to have a conversation that goes;

 

"I think you need to remember that you are working for me, or rather that you were working for me up until this point, goodbye"

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Sorry for keep going on, but this is the surveyors email..

 

Quote.."With the two side doors, there would be adequate escape facilites from the aft cabin if there was no means through to the engine space.

 

However, the boat would not meet the requirement as far as Man Overboard prevention is concerned. The working deck is the area or areas from which the boat can be operated i.e. steering, using the mooring points fore and aft, reaching the interior of the boat etc. There are two working deck areas on a narrowboat, the aft deck and the well deck. These have to be interlinked either through the interior of the boat or via another part of the working deck. The problem is that the side decks are only 100m wide and the minimum width for a working deck is 150mm.

 

From a practical point of view, I would find it really inconvenient not to be able to reach the interior of the boat, it means shuffling along the side deck every time to get inside. What if the missus wants you to bring you a cup of tea? The only means of communication with somebody in the cabin would be by intercom. What if there was a fire inside the boat? Precious seconds would be wasted going down the whole length of the side deck.

 

In summary, the boat would not comply with the MOB standard and the layout would be completely impractical. I would insist that he has a door into the engine room and the cross-bed would have to have a lift up panel to allow access.".. end quote

 

Does he have any right to demand this modification.?

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It might be better to show him several existing boat layouts that already include a bulkhead, but in the end, he's working for you.

 

Richard

 

We decided not to buy a boat with this layout because we found it too inconvenient for us to move from the galley to the rear deck.

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