Consultation opens on proposal for BSS Requirements for CO alarms on boats

[Rob@BSSOffice]

A public consultation on a proposal to introduce mandatory new Boat Safety Scheme (BSS) Requirements for carbon monoxide (CO) alarms on boats opens today Friday 17 August and will run to Friday 9 November 2018.

The Boat Safety Scheme (BSS) is running a public consultation on proposals that have the full support of its stakeholder and management committees.

It is proposed to introduce a mandatory new BSS Requirement for suitable carbon monoxide (CO) alarms in good condition and in suitable locations on all classes of boat with accommodation spaces.

The changes affect all classes of BSS examination, private boats, boats used for hire and other non-private boat classes.

The BSS proposals are presented as both necessary and proportionate risk controls and your comments upon them are welcomed. The consultation is open until 16:30 on Friday 9 November 2018.

The BSS will also be taking the opportunity to seek the respondent’s views on the future possibility of introducing similar checks concerning smoke alarms for private boats.

Please share news of the consultation https://www.boatsafetyscheme.org/abo…/co-alarm-consultation/

[WotEver]

I think it’s a great idea. 

[LadyG]

I think its a good idea to save lives, very good value for money [about a tenner for seven years],

Will there be many objections?

Is it really a good use of scarce resources [money/manpower] to set up a "consultation", Can't someone just take a decision today, and implement it tomorrow?

 

Edited August 17, 2018 by LadyG

[LadyG]

I suggest we set up a consultation to find out why turkeys  never vote for Christmas.

[Arthur Marshall]

No doubt they will only allow the most expensive and hard to find unit on the market, probably with fitting instructions that are impossible to comply with on a narrowboat, and insist it is installed only by their registered installers at a hundred quid a pop. 

[LadyG]

In my earlier days I remember sitting in a field of cows researching water drinking patterns. It was known that milch cows need more water than beef! 

All a bit rubbish ,,,,,,,,,,,,,,,, conclusion?  let them have free access to unlimited water, meter the water 24/7/365 so you know how much they need per annum. It's not rocket science.

26 minutes ago, Arthur Marshall said:

No doubt they will only allow the most expensive and hard to find unit on the market, probably with fitting instructions that are impossible to comply with on a narrowboat, and insist it is installed only by their registered installers at a hundred quid a pop. 

Yes, I was thinking about smoke alarms in rented houses: in Scotland, they are required by law in rented property and have to be hard wired, by a registered electrician.

The trouble with boats is that they shake, rattle and roll, something the current cheapo  alarms don't like.

Edited August 17, 2018 by LadyG

[Rob@BSSOffice]

9 minutes ago, Arthur Marshall said:

No doubt they will only allow the most expensive and hard to find unit on the market, probably with fitting instructions that are impossible to comply with on a narrowboat, and insist it is installed only by their registered installers at a hundred quid a pop. 

I see you read the documention carefully then ?

[LadyG]

17 minutes ago, Rob@BSSOffice said:

I see you read the documention carefully then ?

I think Arthur passed out before he got to the nitty-griitty £13.50, or maybe, like me,   he was busy editing the OED

Edited August 17, 2018 by LadyG

[Horace42]

A good idea for a mandatory requirement as part of the BSS. How it will be 'policed' is another matter. If fairly simple along the lines of a fire-extinguisher check, then no problem.

I have already got both smoke and CO alarms. Apart from batteries that go flat and need changing quite often, there is a presumption that with new batteries they are working properly - it is an act of faith.

Arthur Marshall hints at the problem, to my mind there is officialdom lurking in the back-ground ready to unleash an expensive service on boaters.

But yes. A simple statement of intent to have them will do.  

[Rebotco]

Anyone who lives/sleeps on a boat without a CO alarm is a fool, if they use any gas or solid fuel.

But they are a fool only to themselves.

 

My concern is this could be the thin end of a large wedge. 

I believe every other BSS requirement is designed to address risks that may affect OTHER boaters.

 

But this, for the first time, strays into the realm of Big Brother dictating how we should live "for our own good" even tho it affects nobody else.

How long before they add "no smoking" or "no alcohol" or whatever on boats, because its "safer" for the individual? 

 

Smoke alarms could be justified because any boat fire puts other boaters at risk, but CO does not.

So however life-saving, sensible and desirable CO alarms are, they should not be dictated by the BSS.  They should be encouraged by other means.

[Alan de Enfield]

8 hours ago, Rob@BSSOffice said:

It is proposed to introduce a mandatory new BSS Requirement for suitable carbon monoxide (CO) alarms in good condition and in suitable locations on all classes of boat with accommodation spaces.

Yes - Do it.

[Mike Todd]

7 hours ago, Horace42 said:

A good idea for a mandatory requirement as part of the BSS. How it will be 'policed' is another matter. If fairly simple along the lines of a fire-extinguisher check, then no problem.

I have already got both smoke and CO alarms. Apart from batteries that go flat and need changing quite often, there is a presumption that with new batteries they are working properly - it is an act of faith.

Arthur Marshall hints at the problem, to my mind there is officialdom lurking in the back-ground ready to unleash an expensive service on boaters.

But yes. A simple statement of intent to have them will do.  

It is only a requirement for the BSS not a legal imposition on the boater. Hence there is no need to police it other than as an item when the BSS exam is done. 

 

Of course it is entirely sensible to keep it in good working order on a permanent basis but don't let a good idea be burdened with a notion that it does not need to carry.

[Rob@BSSOffice]

As a BSS Requirement, like all the requirements it becomes one of the things that the navigation authority terms and conditions insist on compliance with anytime the boat is in use on the waterway (as on CRTrust, EA and Broads Auth waters)

 

Comments about cost and benefits and 1st/3rd party protection are answered in the documentation and consultation statements.

 

The links to the supporting documents I can republish here

There is further information if you need it in the following documents:-

• Risk Review and Assessment Paper (26 pages) [Link]
• An Impact Assessment (summarising our appraisal of the potential impacts of a new BSS Requirement - 8 pages) [Link]

Edited August 18, 2018 by Rob@BSSOffice

[nicknorman]

This is what the BSS “mission statement” says on its front page:

 

The Boat Safety Scheme, or BSS, is a public safety initiative owned 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.

 

So in what way does a CO alarm comply with that? I suggest it represents massive “mission creep”. If the BSS is suddenly going to be about saving ourselves from our own stupidity, where does it stop? Mandatory life jackets? Railings around trad sterns? Hard hats in tunnels? Regulating what we eat to avoid obesity?

 

CO alarms are great and only foolish people wouldn’t have them, however they are way beyond the remit of the BSS. CO alarms are not mandatory in people’s houses, why should they be in boats. Stick to the original brief!

[Rob@BSSOffice]

11 minutes ago, nicknorman said:

This is what the BSS “mission statement” says on its front page:

 

The Boat Safety Scheme, or BSS, is a public safety initiative owned 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.

 

So in what way does a CO alarm comply with that?

This question is dealt with at length in the consultation and is core to why it is proposed as a requirement and not advice check or remaining as a strong recommendation.

[Alan de Enfield]

7 minutes ago, nicknorman said:

This is what the BSS “mission statement” says on its front page:

 

The Boat Safety Scheme, or BSS, is a public safety initiative owned 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.

 

So in what way does a CO alarm comply with that? I suggest it represents massive “mission creep”. If the BSS is suddenly going to be about saving ourselves from our own stupidity, where does it stop? Mandatory life jackets? Railings around trad sterns? Hard hats in tunnels? Regulating what we eat to avoid obesity?

 

CO alarms are great and only foolish people wouldn’t have them, however they are way beyond the remit of the BSS. CO alarms are not mandatory in people’s houses, why should they be in boats. Stick to the original brief!

From the consultation documents :

 

1.1.1 From the recent evidence collected, people and their pets aboard their own boats are at medium risk of CO poisoning from sources of CO generated outside of the boat by others e.g. the use of engines and appliances on adjacent boats. 

 

1.2.1 The proposed changes to Boat Safety Scheme (BSS) requirements are intended to help prevent CO poisoning of people and their pets aboard boats from sources of CO generated by the activity of others. 
 

Options :

 

1.3.3 Introduce BSS ‘Advice Checks’ – considered inappropriate because the risk falls within the criteria for mandatory BSS Requirement checks, i.e. the protection of boat owners from the activity of others. Please note that one Advice check is proposed acting as a recommendation for a CO alarm to be placed in the same space as any installed solid fuel stove. 
 
1.3.4 Introduce mandatory new BSS Requirements [Preferred option] - the risk falls within the criteria for mandatory BSS Requirement checks, the risk review supports this outcome and this option has full support from all BSS stakeholder groups. 

[ditchcrawler]

I think its a good initiative but I see many problems:

The people who don't have one now will never test the one they have to fit and it will only be looked at every 4 years.

There will probably be great debate where in the boat they should be fitted, lounge, bedroom, one in each, larger boats one in each sleeping area and the lounge.

At the 4 year BSS inspection will the inspector check the date, press the test button and say all is fine or will he carry a proper test kit to inject a measured amount of CO to see if it alarms.

Its fine saying they have a 5 or 10 year life so the boater wouldn't need to check/change the battery and it wouldn't go flat in the first 4 years, but what about the second or third 4 year period.

I think that nearly all the deaths due to CO poisoning have had a secondary cause leading to it. Modified exhaust on a genny, blocking ventilation to stop drafts, having external escape ways locked. 

 

I am sorry to say its a regulation that will probably do nothing to improve safety and if handled wrong will inconvenience those already taking sensible precautions.

[nicknorman]

41 minutes ago, Rob@BSSOffice said:

This question is dealt with at length in the consultation and is core to why it is proposed as a requirement and not advice check or remaining as a strong recommendation.

Ok I’ve read it now (briefly) but the argument seems very flimsy. Previously the remit of the BSS was to try to prevent a boat becoming a hazard to others. Fair enough. The logic in this consultation is that well, some boats do present a hazard to others even though they are BSS compliant, so now we are going to focus on making other boats more immune to the hazards presented by those “rogue” boats. Once again I say it is out of remit and massive mission creep.

 

I think it is a feeble attempt using slightly twisted logic to justify mandating fitting of CO detectors, 99% of the real reason being to try to save ourselves from our own stupidity, and 1% to save us from a very unlikely scenario of CO from another petrol powered boat affecting us.

 

What proportion of boats on the inland waterways have petrol engines that get left running anyway - a tiny proportion I’d say.

 

As I said, I think CO alarms are a very good idea and of course we have one. But it is matter of principle. The BSS already has some ill-thought out stuff (along with plenty of sensible stuff) and it is an inevitable trait of such organisations that, over time, they gradually seek to increase their power and influence way beyond that which was originally envisaged. This is sometimes justified by one fatality in one highly improbable set of circumstances. Sorry, I don’t support the view that human life must be preserved at all costs. If we go down that route, we must all stay in bed. Except that most people die in bed, so clearly they are very dangerous and should be banned by the BSS.

 

Anyway, out of interest is this a consultation for the sake of ticking a box, with the decision already having been made, or will the responses to the consultation actually shape whether this new rule is adopted or not?

Edited August 18, 2018 by nicknorman

[Rob@BSSOffice]

13 minutes ago, nicknorman said:

Anyway, out of interest is this a consultation for the sake of ticking a box, with the decision already having been made, or will the responses to the consultation actually shape whether this new rule is adopted or not?

We don't run consultations to tick boxes. All opinions are sought. We look forward to all members of CWDF submissions should they choose to participate. It would be a good thing.

[nicknorman]

Ok I completed the feedback. Two comments, at Q9 I was cut off mid sentence (not enough characters allowed) and when I went to put my email in, it was rejected as being an invalid email. After some faffing it transpired that it didn’t like the capital first letter (something my iPad does automatically) but emails are not case sensitive and so it was incorrectly rejecting a perfectly valid email address.

 

Just on the proposed requirements, I found the item A difficult to fathom regarding the number of alarms required. Virtually all narrowboats have multiple “accommodation spaces” with doors. Is the requirement to have an alarm in each accommodation space separated by a door, or just one alarm provided it is within 10m of the door of any accommodation space even if the wrong side of that door? If the former, I think we would need at least 3 alarms on our boat. And of course what is a door? Our doors by design have fairly large ventilation gaps - a far cry from some sort of “waterproof bulkhead” type of door.

 

I can see massive scope for gold plating by an over-enthusiastic BSS examiner.

Edited August 18, 2018 by nicknorman

[dmr]

Its all gets so difficult

 

BSS checklist:

 

Remove all crap from gas bottle locker and hide behind hedge so BSS man won't see it.

Borrow fire extinguishers from boat behind.

Borrow CO meter from boat behind.

Wipe all leaky fuel unions and remove dip trays from below unions (or whisky bottle if you have a Kelvin).

Remove covers from air vents.

Remove underwear that wife has wrapped round stove flue to warm up.

 

Did I forget anything?

 

..................Dave

[MoominPapa]

15 minutes ago, nicknorman said:

Just on the proposed requirements, I found the item A difficult to fathom regarding the number of alarms required. Virtually all narrowboats have multiple “accommodation spaces” with doors. Is the requirement to have an alarm in each accommodation space separated by a door, or just one alarm provided it is within 10m of the door of any accommodation space even if the wrong side of that door? If the former, I think we would need at least 3 alarms on our boat. And of course what is a door? Our doors by design have fairly large ventilation gaps - a far cry from some sort of “waterproof bulkhead” type of door.

 

This is a potential consequence of the twisted logic used to make CO alarms a compulsory, rather than advisory, check. If you're protecting against CO generated in the boat, then an alarm in any space with a fuel burning appliance is sufficient. If you decide that the problem has to include external sources of CO then logically the alarms must be in every space with an external opening. I have a CO alarm which protects the space with the stove and gas cooker and water heater. I don't consider it necessary to protect against external-source CO in other spaces. I don't want to be forced to do that, especially when the motive for that is not a dispassionate risk assessment, but a way of bending the rules to move CO alarms from the advisory to the compulsory category.

 

I assume that smoke alarms are not included in this because there's no way to use the same argument. Lack of smoke alarms doesn't endanger third parties. There is, of course, an argument to have a smoke alarm in every compartment, as fire can start anywhere. I have smoke alarms in places I don't have CO alarms for that reason. The best course is probably to make both smoke and O aarms part of the advisory checks.

 

MP.

 

[nicknorman]

12 minutes ago, MoominPapa said:

This is a potential consequence of the twisted logic used to make CO alarms a compulsory, rather than advisory, check. If you're protecting against CO generated in the boat, then an alarm in any space with a fuel burning appliance is sufficient. If you decide that the problem has to include external sources of CO then logically the alarms must be in every space with an external opening. I have a CO alarm which protects the space with the stove and gas cooker and water heater. I don't consider it necessary to protect against external-source CO in other spaces. I don't want to be forced to do that, especially when the motive for that is not a dispassionate risk assessment, but a way of bending the rules to move CO alarms from the advisory to the compulsory category.

 

I assume that smoke alarms are not included in this because there's no way to use the same argument. Lack of smoke alarms doesn't endanger third parties. There is, of course, an argument to have a smoke alarm in every compartment, as fire can start anywhere. I have smoke alarms in places I don't have CO alarms for that reason. The best course is probably to make both smoke and O aarms part of the advisory checks.

 

MP.

 

The only problem with making it an advisory is that it is mission creep and at the next review, it will likely slip unnoticed from advisory to required. And also there seem to be plenty of BSS examiners who don't understand the difference between an advisory item and a required one. OK two problems!

[rasputin]

I will try and remember to read and react when I am not on my phone 

 

I am against any new legislation 

[rowland al]

1 hour ago, Rob@BSSOffice said:

We don't run consultations to tick boxes. All opinions are sought. We look forward to all members of CWDF submissions should they choose to participate. It would be a good thing.

Just one question Rob (and I’m not trying to shoot the messenger) - What has caused this sudden interest in adding smoke & CO2 alarms to the BSS?

 

It’s taken nearly 20 years!