PARA NO. | FEEDBACK RECEIVED | MADE BY | RESPONSE |
Introduction | Does not say if it is a voluntary / compulsory Code only applicable to commercial vessels. Both of these should be included | RYA Bridge 19 – 40 | See revised wording in section 1-3. |
| Preface | Too brief – include that commercial and volunteer organisations would be covered. Not clear who Code applies to. | General | It was argued that prefaces’ should be kept brief. Examples included in revised text. |
| 1.2 and section 7 | Many vessels are already subject to BSS and RCD. BSS is only referred to once in document. To avoid duplication of assessment, which would be an unacceptable requirement, satisfactory assessment to the RCD construction
requirements should be directly subsumed into the Code. | Passenger Boats Association RYA | Not all vessels are under RCD or BSS and those who are, still require supporting standards. The technical construction file should include a list of all the standards used, depending on the category of water, which is checked for compliance. Operator should be able to access. |
| 2 | Gives impression of a mandatory requirements Include more phrases such as ‘it is recommended’ | IWAAC | See revised wording of section 1-3 |
| 2.1 | The use of nautical phrases is not helpful to being understood, however if 2.1 was followed this would be resolved - more relevant to operators in their own environments. | IWAAC | See amended draft |
| 3.1.1 | Make it clear that the reference to ‘a child under one year of age’ is only for calculating passenger numbers and not to imply any lesser degree of care needed for such children. | IWA | Not considered necessary |
3.2.2 | Instead of rivers it should read non tidal rivers. Or some rivers with tidal influence should be placed with B waters. Narrow should be defined. | The Broads Society | This wording is an extract from statutory instrument and cannot be changed |
3.3 (Now Annex 5) | Transiting vessels – all points of shelter should be known and previously evaluated. There should be at least one other person on board competent. There should be at least two separate communication systems capable of an alarm system (ideally VHF and a mobile phone). Lifejackets should be available for all person onboard. At least one life buoy at each end of the vessel. | Taylors Waterways Tours | Included ‘points of shelter’ and ‘additional crew members’ for transiting vessels in revised draft Remaining points to be covered by risk assessment |
3.4 NOW para 3.2 | The Code is insufficiently clear in specifying which passenger operations it intends to cover. Should not include the carriage of passengers where that is not the main function of a boats operation i.e. non-fare paying pass. Or occasional passengers taken by boats that do not normally carry passengers. This should be written in introductory paragraph. More work needs to be done to identify the craft at the periphery of the Code. A separate annex could deal with these craft. The code requires further clarity for ‘immediate family and friends’ especially friends. | IWA | See amended draft. |
3.4 & 3.5.2 NOW para 3.2 | Should add here exclusion of canoes, dragon boats etc Does not reflect the sensible requirements which the RYA and BCU approve. | BCU Institute for Outdoor learning | See amended draft |
3.4 NOW para 3.2 | Vessels operated by local sailing/ yacht clubs which carry club members/ members of the public afloat should comply with this code. A new paragraph 3.5.3 should state – ‘Any establishment, which holds a licence from AALA, should be deemed to provide equivalence to the code requirements. | Cowes Harbour Commissioner Institute for Outdoor learning | Agreed. Wording used in line with MCA Harmonised Code Agreed |
3.4 NOW para 3.2 | This definition includes workboats. 3.4.1 implies it covers operations for profit, 3.4.3 adds most other activities involving a boat. 3.4.3 includes boats used by rowing clubs | Bridge 19 - 40 | Added change in 3.4.1 – ‘and which only carry passengers’. This Code is not intended to cover workboats |
| | Request for self-drive hire boats to also be covered by this Code. | Pembroke-shire Council | Consider a separate Code |
| 3.4.2 | What about when the operators are demonstrating to the use of the boat to the hirer? | Broads Authority | Consider a separate Code |
3.6.3 [Now 2.5.10] | This clause is unclear as to what exactly it might mean | IWA | See amended draft |
| 3.6.3 | Should be carefully noted – it allows for equivalence for a vessel/operator who can demonstrate they have an alternative safe system. | IWAAC | See amended draft |
| 3.6.4 | ‘High Ratio’ not supported in small craft; risk assessment by 3rd party might therefore deem operations inappropriate. | | See amended draft |
| 3.6.4 (4) | Consider changing ‘in summer river flow conditions’ to ‘non flood conditions’ or other suitable wording to take into account the change of river flow patterns. | Institute for outdoor learning | Agreed. |
| 3.6.4 items 2, 3, 5, 7, 8, 9 | If there is sufficient rescue cover the equipment requirements need not be met. | Boatsurvey.biz | Cannot assume that rescue services would always be on hand to help. |
| 3.6.4 (12) | Vague – from the point of view from a RIB | Blue Funnel Cruises | Disagree. RIBS should also comply and are not considered separately |
| 3.7 | What systems exist to establish primacy? (ie Local regime or this Code ) | Passenger Boat Association | Competent Local Authority has final say because this Code will not be enforced by national authority. |
| 3.8.3 | Risk assessment does not have to be written down if there are less than 5 employees. Unwritten assessment tends not to be carefully considered and can seldom be proven to exist. It might be better to advocate that all risk assessment be recorded. | London Canal Museum RYA | See amended draft, in line with Harmonised Code. |
3.9 NOW 1.4 | Not via website – hard copy to operators | Passenger Boat Association | A subscription list could be set up to ensure that all interested parties receive the amendments. Possibly charge for hard copies? |
| 4-24 | Would benefit from being divided up into classes of vessels rather than trying to cover all. Suggest: Canal or narrowboat, Decked vessel with watertight integrity, open boats, rigid inflatable, inflatable, those with a petrol engine outboard. | Institute for outdoor learning HSE | MCA to consider an index showing what sections apply to each type of vessel. |
| 4-24 | Proposed split into tidal and non tidal waters | IWAAC | This was tested at the beginning stages of the Code and did not work. All agreed to use one document which visually distinguishes specific requirements for A, B, C or D waters. |
| 4.5 | Application to historic craft - A need for special treatment for historic craft where a risk assessment demonstrates that the risk is negligible or is adequately controlled. It is unclear what is meant by ‘a 5 year history of safe operation – open to interpretation. The definition of an ‘existing vessel’ would seem inappropriate in the context of this clause. It may be more useful to say that vessels should comply with whatever construction regulations were in force at the time of construction of the vessel. It
would be unreasonable to expect vessels to comply with later construction standards. | London Canal Museum Broads Authority Museum of the Broads IWA | The whole Code should be applied on the basis of risk assessment. Changed “a five year history of safe operation” to “a recent history of safe operation”. If the operator can demonstrate a safe history, written evidence will not be required. Reference to ‘written evidence’ removed. |
| 4.7 | Vessels with timber hulls, out of water inspections should be more frequent (2 years). | The Broads Society | Agreed. References to soundness and integrity added. |
| 4.7 | The level of examination intended in this section is unclear. Is a surveyor required? If the examination is required to be to any particular standard this should be stated. At present we read the requirement as being no more than a visual inspection by the boat owner. | IWA | See amended draft |
| 6.1.1 | Is based on expected wave height. Where there are no waves the whole paragraph is not necessary. | | Disagree – “waves” includes wash. |
| 6 and 7 | These are hard to understand. Tabulate what various typical vessels might be defined as. Is a passenger carrying narrow boat with a standard type of cabin an open vessel or not for example? | IWAAC | See amended draft |
| 7 | No part refers to outboard engines - with reference to different sections the code is contradictory The ISO refers to outboard motors | Bridge 19 – 40 YDSA | Outboard engines are permitted under ISO standard quoted. Wording amended in line with Harmonised Code. |
| 7 | There appears to be no provisions for kill cords on RIBs, Inflatable and other required craft. Provisions and use should be mandatory | | Recommendation to fit where risk identified. |
| 7.1.3 | Excessive requirement in the case of diesel boats on class A/B waters. | London Canal Museum | Disagree |
| 7.1.3 | The design of some historic vessels (narrow boats) may not allow for fuel to be shut off outside the engine room. The Boat Safety Scheme has assessed the safety implications of this and there is an exemption for such a requirement for historic vessels under the scheme. Recommend a similar exemption for this code | IWA | Disagree See 4.5 above. Equivalences with BSS dealt with in section 3. |
| 7.1.5 | Some historic boat engines are started by hand – it is a safe method and assumptions should not be made that batteries are required for engine starting. This whole paragraph is not needed on A waters Historic boats with original or similar engines may not have an ‘efficient and reliable’ starting mechanism Should be an exemption for such boats operating on category A and B waters. Assume that an engine driven charger is sufficient for the purposes of this and clause 7.1.6 | London Canal Museum IWA | See 4.5 above Disagree |
| 7.1.5 | Several engine manufacturers do not offer engines with gearboxes which prevent starting in gear. This only applies to outboards | Toughs Boat Yard | Disagree |
| 7.1.5 | Two engine starting batteries is excessive. | Toughs Boat Yard | Disagree |
| 7.1.6 | Vessels are started by a single battery. It would be impractical to have a duplicate start up battery. | Cowes Harbour Commissioners | Disagree |
| 7.1.7 | Cannot accept that this applies to all including inboard engines. The ISO is 11547 is for outboard engines only. | BMF Bridge 19 – 40 | Paragraph removed. |
| 7.3 | The sub requirements 1 to 16 should be checked for their compatibility with the requirements of BSENISO 10088 | RYA | Agree |
| 7.3.1 - 4 | Petrol fuel installed within 1 metre of any engine or heating appliances. This is in excess of both the RCD standard 10088 and the Boat Safety Scheme. How is the distance justified when we are talking about small boats? | BMF | Text to be brought into line with Harmonised Code/BSS as appropriate. |
| 7.3.1(1) | Fuel filling arrangements are not always easy on smaller vessels with fixed tanks. On RIBS there is no where else fuel can go if spilt except on deck or in the bilge. | Blue Funnel | Text to be brought into line with Harmonised Code/BSS as appropriate |
| 7.3.1-2 | The main clause 7.3.1 quotes ISO 10088 for the installation requirements of fuel tanks, this standard includes a fire test of 2.5 mins for non-metallic fuel tanks. This is echoed in the Boat Safety Scheme standard as well as the RCD. | BMF | Text to be brought into line with Harmonised Code/BSS as appropriate |
| 7.3.1 – 11 | This may cause a problem for a craft that needs a flexible section at the tank end which maybe outside the engine compartment. 7.3.1-4 may force this. | BMF | Delete reference to engine compartment. |
| 7.3.3-1 and 2 | Appropriate standards should be specified, either in the text (as other sections) or in an annex | BMF | MCA to add standards |
| 7.3.6 and 7.3.6-6 | This section is under the heading 7.3 petrol engines. Reference to diesel fuel should be in a separate section. | BMF | See revised draft |
| 7.5 | LPG Powered engines – why is this application limited to existing vessels? There is a strong environmental lobby for LPG engines and much work is being done by both the trade and trade associations for LPG fuelled engines both inboard and outboard. There is an LPGA Code of practice number 18 that deals with LPG installations in boats. | BMF | Not current policy |
| 10.1 | Is it necessary for a self draining boat with integral buoyancy tanks and sufficient stability to be equipped with bilge pumps, lifebuoys, torches and compasses | Boat Survey. Biz | To be applied based on risk assessment |
| 11 | 70-ft narrow boat would not achieve an angle of heel of 7 degrees with 12 passengers. A boat of 40ft would - so does this mean the number of passengers could be limited to that number which could result in an angle of heel of 7 degrees? | South Staffs Narrow boat Company | Yes, but see revised text of chapter 11. |
| 11 and 12 | Inappropriate for small craft / category A waters | Passenger Boat Association IWA | See above |
| 11.1.1 | Ballasting some boats is not possible as some are operating in very shallow waters | Folly Reach Harbour Management | Boats should achieve standard or use risk assessment |
| 11.1.1 | This requires a freeboard to down flooding when heeled for categories A and B that is far greater than the freeboard required when upright (12.2.1). This should be reduced for the less demanding categories. Suggest A= 100mm, B= 175mm, C= 275mm and D= 375mm | BMF | See revised text of chapter 11. |
| 11.1.1 | Old boats may not have a builders certificate. | Bridge 19-40 | See 4.5 above |
| 11.3 | Proposals for formulae within this part have been forwarded to MCA | RYA | See revised draft |
| 11 | In agreement with proposed RYA STOPS figures of 14 and 11 | YDSA | As above |
| 12 | Freeboard to downflooding for cat A waters should be increased to 175mm. This brings cat A and B into line at 175mm. | YDSA | See revised draft |
| 12.1 | 250mm is very prescriptive. No problem with an average of this i.e. less at midship and more at bow and stern. This depends on the height of Coamings from the deck, hatch closures etc. | | This was considered an average, which is in line with the BSS. This is not a requirement for Cat A and B |
| 12.2 | No requirements are given for category C waters. Suggest that required freeboard be taken from 12.2.3 and reduced by the ratio of the maximum wave height, i.e. x0.6. | BMF Broads Society IWA | See revised draft |
| 12.2.1 | In 12.2.2 and .3 refers to ‘freeboard to downflooding’ whereas 12.2.1 refers to freeboard. It is also unclear as to how one determines the average freeboard. Suggest that 12.2.1 should refer to freeboard to downflooding. The requirement of 12.2.1 is not consistent to the proven BW [BSS?] standard of 250mm. Recommend a simple minimum freeboard to down flooding of 250 mm anywhere for cat B waters and 175 for cat A waters which are not known to have significant wave height as big as 0.6m | BMF | See revised draft |
| 12.2.3.3 | The required freeboard to down flooding for open boats is less than that required for decked boats. This is strange given that the consequences for swamping are more serious. It was considered acceptable in the HC SCV Code because open boats are required to have sufficient buoyancy to support everyone when the boat was fully swamped. This code appears to have no similar requirement for swamped buoyancy for open boats. Swamped buoyancy should be required for Cat C and D waters | BMF | See revised draft |
| 13.1 &13.2 | In B waters a vessel with freeboard less than 1 foot there should be a requirement for either lifebuoys or buoyancy aids or lifejackets, sufficient in number for the total of passengers plus crew. | Broads Society | Disagree |
| 13.1 | Carrying a suitable life buoy on a sailing dinghy is too onerous. Possibly a length restriction or some equivalent alternative should be included. | RYA | Cf Beachcraft Guidelines at Annex 5. |
| 13.1 | Is there are need for life buoys to be carried on all boats operating on cat A waters? Better if the requirement for such equipment was subject to risk assessment. | IWA | Carriage of lifebuoys or equivalent is best practice. All of the Code is subject to risk assessment |
| 13.2 | Should be life ring provisions for every passenger. Possibly more fire extinguishers | Bristol ferry Boat Company | There is no need for life rings for every person if life jackets are available for every person |
| 13.2.2 | There is no requirement for life jackets to be lit. | Cowes Harbour Commissioners | Lights required only for night-time operation |
| 13.2.2 | This is in excess of the pax vessel requirement for class V operating on class A waters. | | Disagree |
| 13.3 | Not always practical to carry liferafts due to space limitations. | Cowes Harbour Commissioners | Sailing Federation liferafts are not bulky. |
| 13.3 | In some cases this would mean that SOLAS liferaft would have to be fitted to a 14’ aluminium punt type ferryboat. | | Alternative to SOLAS liferafts is quoted. |
| 13.3 | Carrying a life raft on a 3 meter rib – problems – if it complies with 11.2.3.1 then it should be able to float and crew and passengers would be required in cat D to wear a life jacket | Institute for outdoor learning | Disagree – Life rafts may also be needed in the event of a fire |
| 13.3 | Necessary for a raft on a RIB with separate sections in the inflatable tubes? RIBS are not mentioned – not always practical to store a raft on a 6 m vessel using D waters. | Blue Funnel | Disagree – Life raft may also be needed in the event of a fire |
| 13.3.2 | Reference should be included to the ISO Standards on liferafts which it is expected to be adopted in 2004 | RYA | This should be referred to in the text only when the standard is published |
| 13.3.3.1 | Attention is drawn to the lesser requirement for vessels less than 12 meters length (MSN1676 M) This should be stated in the code. Most vessels to which this code applies will be less than 12 meters in length. | YDSA | Agreed |
| 14.3 | The wording suggests that oil absorbent mats are acceptable – this is supported as they are more effective than drip trays | Broads Society | |
| 14.5 | The requirement for fire resistant or fire retardant material on open boats on category A water is unnecessary | IWA | Disagree |
| 14.6 | The BSS allows for an exemption for the minimum requirement of two means of escape on historic vessels. Suggest the code should have a similar exemption for historic vessels. | IWA | This is covered by new 14.8.2 of the Code. See para 3.4.5 on BSS |
| 14.6.1 | Two means of escape prolongs a discrepancy with ISO 9094-1 and MCA Codes. 14.6.2 does provide a route out for operators. | Boatsurvey.biz | ISO 9094-1 is not accepted by MCA but see above |
| 15 | A fire hole is not an appropriate way to put out a fire in the engine room of an 80’Dutch Barge | Toughs Boatyard | Risk assessment based on size of engine space |
| 15 | Should be consistent with BSS and offshore codes. | YDSA | See para 3.4.5 on BSS. |
| 15.2 | Onerous requirement Expensive requirement, depending on the interpretation of second sentence. How far outside is a safe location? | South Staffs Narrow boat company | See revised wording |
| 15.3 | A 13A/113B fire extinguisher is of a size that may not be manufactured. This should be checked. | RYA | These size fire extinguishers do exist. These could also be used in the engine space |
| 15.3 | Question the need for the equipment specified if the boat is always within close reach to the shore and able disembark passengers within a short space of time in the vent of a fire. | IWA | Should not rely on the availability of rescue services – may not be available |
| 15.5 | Not necessary to carry a fire bucket in addition to fire extinguishers | Cowes Harbour Commissioners | Wording from the Harmonised Code for the use of buckets. Buckets are also useful for a bailer on smaller vessels. |
| 16 | Not appropriate for canals. A mobile phone together with instructions on its operation should be sufficient On A waters a mobile phone should be regarded as desirable but in consideration of the actual risks involved, not essential. | South Staffs Narrow Boat Company London Canal Museum | This is already allowed for. See 16.2 Some means of communication is needed in case of emergency |
| 18.2 &19.6 | It may not be appropriate to have a boat hook on all small craft and could be a potential hazard on an inflatable | Institute for Outdoor Learning | Disagree |
| 19.3 | Few boats would have charts on particular waterways. If a river cannot be navigated then the correct procedure would be to moor up. | Toughs Boatyard | This is mandatory for cat D and recommended for cat C – See text : “as appropriate”. |
| 19.1 | Requirement to carry a compass in C waters is superfluous. Suggest substitute the word ‘may’ for ‘will’ in line 2. Or insert ‘a boat operating in cat C waters without a compass should only operate in clear visibility. | YDSA | Disagree – Lochs could be category C and compass should be required. See below |
| 19.7 | An emergency response plan should consist of a very simple flow diagram to aid the coxswain. | | Agreed – this was the intention |
| 20.1 | A minimum water flow should be specified, as there is some flow in nearly all canals and river navigations. An anchor and cable are unnecessary in these circumstances | IWA | See revised wording |
| 22 | Requirement for 1000mm guard-rails at access points on canal boats will cause problems for going under bridges. | YDSA | This is not referring to guard-rails on the roof of narrow boats. |
| 22.1 | For sailing yachts it is common practice to fit guardrails with 600mm high inline with other MCA Codes. Guard wires would be a positive hazard at the height of 1 to 2 metres. Open boats with seated passengers seem to have been ignored. Could benefit from some rewording since sections 22.1and 22.2 impose a requirement without an exemption but 22.3 the states that this requirement may be impractical and unnecessary. | Bridge 19 – 40 | Agreed –wording used from the Harmonised Code |
| 25.4 | Requirement for oil drip tray should be equivalent and with similar exemptions to BSS | IWA | Wording in line with Harmonised Code |
| 26 | Volunteers cannot meet 20/30 weeks – suggest they should undertake a refresher course every time they take a passenger boat out which should be logged. Length of time required is excessive especially for a voluntary run craft which may only be used for a few weeks each year. | NCBA Broads Society South Staffs Narrow Boat Company IWA | Operators should satisfy themselves that crew are competent, referring to the recommendations. See amended draft |
| 26 | Originally this was to be a major half of the code. – it needs more prominence attached to it as a major section heading. Do not attempt to dilute manning requirements. | IWAAC NUMAST | See revised draft |
| 26 | The training/qualification requirements are excessive for some operation. Training requirements should be justified to address real risks rather than standards be set that are beyond the level of any likely need. Training for the operation of such boats could be purely in house and non certified | IWA | Not considered excessive – bearing in mind that the Code is voluntary and that these are recommendations not requirements. Yes – risk assessment must guide manning decisions. |
26 | Would strongly recommend the use of the RYA Inland Waterway Helmsman course – a one day certificate course available at RYA training centres throughout the UK. Powerboat I is not suitable it should be powerboat II See minute 2.1.2.1 Why is RYA inland Waterways Helmsman Certificate not included? RYA Powerboat Level 1 is not suitable. Should be Powerboat II TWT suggest anyone with 500 hours proven experience or who has been under the direct recorded supervision of anyone with such experience for at least 50 hours be exempted from formal qualifications. This experience should also be necessary for transits. | RYA | See revised wording Yes – it should be at least RYA Level 2 (National Powerboat Certificate) for Cat. C & D. See revised wording No – an appropriate formal qualification is our recommendation for Cat C and D at least. |
| 26.2 | Most of 26.2 is at odds with 26.1.1 which rightly suggests that qualifications be appropriate to area of operation | London Canal Museum | See amended draft. 26.2 is guidance for those unfamiliar with the qualifications available. |
| 26.2 | Would have the desired effect if 26.2.2 to 26.2.6 were deleted along with the word local from 26.2.1 | Bridge 19 – 40 | No – guidance is necessary. |
| 26.2.1 | Not all of volunteers have experience ‘gained in a commercial vessels e.g. one season of 20 to 30 weeks | IWA | Noted – but Skipper should have gained experience on other similar craft in the area of operation, or a similar area, and obtained one of the recommended qualifications. |
| 26.2.2 | Reluctant to accept a 17 year old boy as skipper on a disabled passenger vessel. Unlikely to have gained experience and knowledge to safely operate within 12 months. | South Staffs Narrowboat Company | A pro perly competent 17 year old could operate this type of vessel – but operator to apply risk assessment for any particular operation. Additional crew may be needed depending on passengers carried. <sty sys-align-left> |
| 26.2.4 | Requirement for ‘an appropriate certificate or the ability to demonstrate competence …for the appropriate area’. Who would determine ‘the ability to demonstrate competence? And would their training scheme and certificate be considered to meet the requirement? | South Staffs Narrow Boat Company | Competence is best demonstrated by acquiring one of the recommended qualifications or an appropriate equivalent. However operator can make judgement |
| 26.2.4 | Qualifications are over the top in some cases – small voluntary and charitable organisations would be too expensive The level of training and any qualification should be determined by individual risk assessment for each boat operator | Bridge 19 – 40 | There is a need to demonstrate competence whatever the financial implications. Agree that risk assessment is needed. |
| 26.2.4 | Still waters with depth of less than 3 metres should be excluded. Refer to AINA Navigation document | Operator: Wey & Arun Canal trust | Not agreed by working group |
| 26.2.5 | This should refer to licence grades 2 or 3 rather than 1 or 2 (class 1 applies to ships carrying over 100 passengers). Remove the words Watermens Licence issues by the Statutory Authority for the appropriate area because very few harbour or port authorities now do so. | | Agreed. But there are still some available (eg Portsmouth, London) |
| 26.3.3 | Is it practical for a beach boat to carry communications? Should be a case study for beach boats sailed off a Solent beach with a skipper taking out paying passengers | | Plenty of options listed in this paragraph but see Beach Boat Annex. |
| 26.4 | If a Group 2 licence for goods vehicles and buses does not exclude the conditions mentioned why are they excluded from skippering a boat? | Toughs Boatyard | See re-draft |
| 26.4 | The requirement for medical fitness is excessive for operation on cat A and B waters. The requirement might be reduced to that of being sufficiently fit to drive a motor car on the public highway for example. | IWA | See re-draft |
| 26.4 | Many volunteers are 50 + and do have medical conditions which are controlled by drugs. Does not stop them driving a car but would a boat doing 3 mph. | | See re-draft |
| 26.4.3 | Volunteer run boat trips have no employers or employees. For A and B waters a simple self declaration is sufficient. The responsibility for determination of fitness should rest with the employer or operator – MCA should have no role. Should be revised for A and B waters | London Canal Museum / IWA | See re-draft |
| 26.7 | The RYA Sea Survival Course is not included and should be | Institute for out door learning | There are several organisations that run Basic (Sea) Survival courses including the RYA. |
| 26.7 | Should make it clear that attendance on these courses is not a requirement. | IWA | See re-draft . |
| 26.7 | In some cases this would mean for a 200 yard trip, ferrymen would have to have a sea survival course. Inappropriate for small craft carrying few passengers. | Toughs Boatyard | It is a one day course; worthwhile and recommended for all on the water. But see amended draft. |
| 26.7.2 | 26.7.1 should include category C waters and it be deleted from 26.7.2 | YDSA | See amended draft |
| 26.8 | Suggest that 1 crew should have should at least have first aid training if not a first aid certificate. | Taylors Waterways Tours | One person should hold an approved certificate. |
| 26.8 | If first aid should be mandatory for grade 3 skippers suggest that the H&S at work basic certificate would be a good level. | DART | This is more onerous than those listed – which are a minimum standard. |
| 26.8.1 | Appointed person scheme as recommended by HSE should be adequate for small craft. | | As above |
| 27 | No need to carry additional crew in some cases - where disabled passengers are carried always have carers | South Staffs Narrowboat Company | Code recommends decision taken on risk assessment basis |
| 27 | Responsibility for safe manning level lies with the operator – there is little or no guidance with respect to what sufficient, additional crew should be on board. Will MCA issue guidelines and how will MCA ensure the prevention of fatigue? What measures does the MCA intend to put in place for individuals who may have concerns? | NUMAST | Guidance cannot be issued for every single vessel available but see section on fatigue, moved up to link with additional manning. |
28.3 | Requirement for all to carry emergency cards is excessive for small boat trips. | IWA Bridge 19-40 London Canal Museum | Recommendation only. Not considered excessive |
| 29 | For water taxis (for a 5 min journey) a safety briefing may not be practical | | See revised wording (now section 31) |
30 Drugs and Alcohol Policy | Agree with the aim of this section, but is a written policy really necessary? | Bridge 19 – 40 | WG agreed to retain text. |
31.1 Revalidation of certificates | This is disproportionate. The need should simply be to demonstrate the competence. | | See amended draft of this section (now 33) |
| 31.1 | 150 days in 5 year – Boatmasters Grade 3 requirement is 50 days. Even this is hard to achieve in voluntary organisation. Asking for one day every week for 6 months not easy for volunteers Some vessels are only used a few weeks per year so many will not have acquired the 150 days necessary for revalidation of certificates and licences. | Bridge 19 – 40 IWA | n-left>See above<sty sys-align-left> <sty sys-align-left> <sty sys-align-left> <sty sys-align-left>gn-left> <sty sys-align-left> <sty sys-align-left> |
| 31.1 | This should stress that a valid medical certificate includes the self certificate under paragraph 26.4.3 | Institute for Outdoor Learning | See re-draft |
Annex 2 | Code defines ‘operator’ but Harmo Code uses ‘owner /managing agent’ | IWA | See revised definition of “operator” |
| Annex 3 | Amendments to ISO standards | BMF | Annex checked and updated. |
| Annex 4 | Section 27: MCA is not the appropriate authority for incidents on the canal. HSE or Local Authority should be notified. | London Canal Museum | This text refers to regulations about reporting accidents to the Marine Accident Investigation Branch, which apply to all ships in the UK except pleasure vessels. |
Annex 5 [NOW Annex 7] | Method for stability test is complicated | The Kingfisher Project | Alternative methods possible but MCA’s method also supplies a method for measuring freeboard |
Annex 6 [NOW Annex 8] | Unnecessary discrimination against disabled people. Deafness should not bar people from becoming a skipper, if a risk assessment shows it to be safe | London Canal Museum | See above on section 26.4 |
Annex 6 items 1-6 | These items are onerous and suggests that if no symptoms or under control of drugs, then this should be considered acceptable for cat A and B - if more than one crew is on board. | Museum of Broads | See above on section 26.4 |
Annex 7 [NOW Annex 9] | Not appropriate for craft with few people onboard, especially craft where no passenger is out of sight. | Passenger Boats Association | Disagree |
