BMF/MCA/AINA Hire Boat Code.
Summary of Responses to Consultation Comments April 2009
| Item | Source | Reference (Issue CD4) | Comment | Response |
1.1 | Broads Authority | General | Urge earliest possible completion of Part 2 of the code, for unpowered craft, | Noted |
1.2 | Stability testing | Suggest more detailed guidance on defining a "class" of boat for the purposes of stability testing. | Agreed. More detailed guidance added. | |
1.3 | Stability testing - Competent persons | Provide guidance as to what constitutes a competent person for the purposes of carrying out stability testing. | Further advice is available from the BMF, and from a reference document (see text, paragraph 4.3.1 (b)) | |
2.1 | Association of Inland Navigation Authorities | General | There is not consensus amongst AINA members on implementation and enforcement of the code. | Initial issue of the code will cover technical and operational issues only. |
3.1 | Paul Smith | Section 4 - Technical standards. 4.1 para 2 | Suggests specifying a 'competent third party body' with regards to compliance with the RCD? | A number of persons or organisations could provide this service. The code cannot prescribe these. No change. |
3.2 | 4.3.1 (a)(ii). | Change beam to nominal 2.2M. | 2.08M is necessary to provide adequate clearance in narrow locks. No change. | |
3.3 | Appendix 2, A2.3 & A2.1 | Clarify time period for hull integrity inspections. | Frequency will depend on vessel type, age and operating environment. No change. |
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3.4 | Appendix 5. Narrowboat definition. | Change beam to nominal 2.2M. | See 3.2. | |
3.5 | A2.2. | Define cockpit to cover open decks that are not cockpits. | Agreed. Guidance amended. | |
3.6 | A3.3.1(e) | Clarify why engine exhausts are excluded from downflooding points. | Exhausts are a closed system. No change. | |
3.7 | A3.3.1(f) | Clarify the "fully loaded" condition. | Defined in 4.1.2 | |
| Means to determine if lowest aperture is above figure in table 7. | See text, reference 4.3.1(b) | ||
3.8 | A3.3 Tables 7&8 | Match hull lengths in App5 table 5. | Match confirmed. No change. | |
3.9 | A3.3(k) | Match freeboard at heel requirements in 3.2.2 and 3.3 | No change required. Refers to minimum and upright freeboard. | |
3.10 | Check stability test A3.4(b) | Remove requirement to prepare the craft in accordance with 3.2.1(d) (carry-on weights) | Carry-on weight is required. No change. | |
3.11 | A4.1.2(c) Initial freeboard test. | Clarify whether holding tanks such as toilet waste are required to be full (or equivalent weight) | See 4.1.2. | |
3.12 | A4.1.4(a) | Exemption for watertight systems - Does a toilet waste tank connected to a separate toilet fall under this exemption? | No. A toilet is not considered water-tight. | |
3.13 | Table 3. Miscellaneous standards. | Change 'non-slip' to 'slip-resistant'. | Agreed. Table 3 has been changed. | |
3.14 | Weedhatch cill height | Change weedhatch cill height to minimum of 100mm over the deepest laden waterline. | BSS requires 150mm (min) above 'normal' laden water level. No change. | |
4.1 | Port of London Authority | Personal flotation devices. Suggest amending to require carriage of lifejackets on boats operating in category C&D waters. | Agreed. | |
4.2 | Suggest addition of requirement for fire blanket and first aid kit. | Fire blankets are already a Boat Safety Scheme requirement. For operational reasons the carriage of first aid kits is not favoured by operators. No change. | ||
5.1 | National Trust | Various concerns regarding the responsibilities and powers of navigation authorities. | See related comments by AINA above. First issue of the Hire Boat Code will be restricted to technical and operational standards. | |
6.1 | Nigel Stevens | Inclusion of managed shared ownership. | Clarification of intent required. | Wording of definitions is under review. |
6.2 | Risk Assessment | Responsibilities to be clarified. | Done. | |
6.3 | Table 1. 2.13.2 | Suggest remote fuel shut-off be confined to new-build. | Agreed. | |
6.4 | Table 1 9.1.2 | Drip trays should be marked as required for new construction. | Agreed. To include acceptable equivalents. | |
6.5 | Table 2. Means of Escape to be marked. | Clarify wording so that obvious doors do not need marking. | Agreed. | |
6.6 | Smoke detectors | Will suitable detectors be available? | Current advice from the Fire Protection Association and Boat Safety Scheme is that, where appropriately installed and tested, devices currently available provide good protection where their manufacturers declare suitability for marine environments. This advice is expected to be incorporated into the revision of ISO9094 expected to be published in 2010. |
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7.1 | Andrew Taylor | Discusses risks to other boaters from inexperienced hirers. | Hand-over element of the Hire Boat Code is intended to address these risks. No changes required. | |
8.1 | Clifton Cruisers Paul Garfield | Definition 1(e) | Aware of timeshare boats 'loaned' to others. Definition requires clarification. | See comment at 6.1 |
8.2 | Implementation programme and costs. | General concern. | Implementation, including retrospective action, will not now be addressed in the first issue of the Hire Boat Code. | |
8.3 | Handover audits | Costs should not be borne by the hire company. | Audits are not mandatory. No change. | |
8.4 | Appendix 6. Stability | Why does the Code override ISO 12217? | The Hire Boat Code addresses some shortcomings in the ISO standard which is currently under review. | |
8.5 | Appendix 6. 2.1g | Retention of records could be onerous for small businesses. | No content or format is prescribed, similarly for comment on maintenance records. Simple, tick-box formats could be used. No change. | |
8.6 | Appendix 6. | Comments re sizes of boats | Stability requirements may mean that some boats have to carry fewer passengers. No change required. |
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| Appendix 6. General stability procedure. | Can ballast be used instead of people for testing? | Yes. No change required. | |
9.1 | Nene Valley Boats | Lead times for modifying craft. | Urges long lead times for modifying older boats. | Programme is outside the scope of the Code but will be considered in the code committee. No change. |
9.2 | Stability tests. | Can a standard test be derived for narrowboats? | Classes of boats are referred to in later versions of the stability text. | |
| Concern regarding the complexity of the tests. | To be considered for future change by code committee |