Richardw's Narrow Boat Project- PLATE THICKNESS

Discussion in 'Metal Boat Building' started by richardw66, Nov 27, 2013.

  1. DCockey
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    DCockey Senior Member

    From the RYA guide; EU guidance on RCD compliance responsibility for narrow boats fitted out by owners from a shell produced by a boat builder.
    N. Narrow Boats – EU Interpretation

    EU guidance has recently helped to clarify the status and responsibility concerning narrow boats fitted out by the
    owners on shells produced by a boat builder. Detailed below is an extract from an EU Commission letter clarifying
    interpretations on the Directive.

    Question:
    Narrow boats fitted out by the owners on shells produced by a boat builder. Who is responsible for their compliance
    with the RCD?

    Answer given by the EU Commission:
    The crucial stage for compliance with the RCD is the stage of transfer of ownership/placing on the market (see the
    Commission’s guide p.13, comments to Article 4). The person responsible for ensuring compliance with the RCD is
    the boat builder, when passing the narrow boat on to the owner (transfer of ownership), or the owner, if he
    completes the boat with a view to selling it (place it on the market). Home-built boats are exempted only if they are
    not subsequently placed on the market within 5 years.

    Question:
    What happens when the owner finishes fitting out the narrow boat but does not intend placing it on the market for 5
    years: “does the completed boat need to comply with the RCD or just to the stage of hand over from boat builder to
    owner”?

    Answer given by the EU Commission:
    The boat is exempted, as long as it is not placed on the market. If the owner decides to place it on the market, then
    the completed boat needs to comply with the RCD.​
     
  2. richardw66
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    richardw66 Junior Member

    But what if the boat is not built by a boat builder? Does a steelwork fabricator have the same legal duties of compliance as a boat builder would?
     
  3. DCockey
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    DCockey Senior Member

    See my post just above yours.
     
  4. TANSL
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    TANSL Senior Member

    Okay, but let's give little information but correct and useful to him.
    It is best at this stage of the Project see the difficulties. Later will be more costly to correct errors.
     
  5. SukiSolo
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    SukiSolo Senior Member

    Thanks David. Lots of stuff that is useful, agree Cat D is the one to aim at. Don't panic Richard, it is quite likely to fairly easy to pass it. Forget any sub to the RYA as not even they may be aware of what is coming down the line. I've had a lot of 'problems' trying to find impending legislation from Europe in the past especially draft legislation proposals.


    Quote

    N. Narrow Boats – EU Interpretation

    EU guidance has recently helped to clarify the status and responsibility concerning narrow boats fitted out by the
    owners on shells produced by a boat builder. Detailed below is an extract from an EU Commission letter clarifying
    interpretations on the Directive.

    Question:
    Narrow boats fitted out by the owners on shells produced by a boat builder. Who is responsible for their compliance
    with the RCD?

    Answer given by the EU Commission:
    The crucial stage for compliance with the RCD is the stage of transfer of ownership/placing on the market (see the
    Commission’s guide p.13, comments to Article 4). The person responsible for ensuring compliance with the RCD is
    the boat builder, when passing the narrow boat on to the owner (transfer of ownership), or the owner, if he
    completes the boat with a view to selling it (place it on the market). Home-built boats are exempted only if they are
    not subsequently placed on the market within 5 years.

    Question:
    What happens when the owner finishes fitting out the narrow boat but does not intend placing it on the market for 5
    years: “does the completed boat need to comply with the RCD or just to the stage of hand over from boat builder to
    owner”?

    Answer given by the EU Commission:
    The boat is exempted, as long as it is not placed on the market. If the owner decides to place it on the market, then
    the completed boat needs to comply with the RCD.

    Typical nonsense answer really, which basically says if you want to sell it make sure it complies regardless - or never sell it!. However it may not be onerous at all. Yes, the steel fabricator would become boatbuilder if he manufactures the shell in my opinion. It is the finished effort that requires certification, probably not self certification, I need to look into this. Maybe you can send the documents, drawings with stability calcs etc etc to an accredited authority ie maritime test house and they can pass it pretty cheaply and quickly. I'm sure Ad Hoc will be able to advise on this.

    Don't let it put you off.
     
  6. Ad Hoc
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    Ad Hoc Naval Architect

    Attached Files:

  7. Ad Hoc
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    Ad Hoc Naval Architect

    That is just an indication of what you have already noted, you are unfamiliar with stability. Thus you should refrain from posting on such as what you have noted is wrong and misleading.

    Just because a program does not ask for such data (I'm unfaimialr with Orca), does not mean it is not required. The VCG is essential and one cannot perform stability calculations without the VCG. Without the VCG it is just a set of hydrostatics and nothing else. The stability must still be calculated from cross curves knowing the values of KM at varying angles of heel and displacement and using the VCG to calculate manually.
     
  8. DCockey
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    DCockey Senior Member

    Based on what I've found the supplier of a shell is not responsible for ensuring the shell is completed in compliance with the RCD. The person who completes the shell is responsible. This makes sense as the seller of the shell does not have any way to compel the purchaser to follow the regulations. It may be possible that the builder of the shell can certify that the materials they used and the work they did complies with specified RCD requirements, and that in turn may be used as evidence that the completed boat meets the RCD.

    The RYA information appears to be very clear that Category D boats can be self-certified.
     
  9. DCockey
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    DCockey Senior Member

    The Inland Waters Small Passenger Boat Code appears not to apply to boats not used for commercial purposes. From the link (bolding added):

    3.2.1 This Code is intended to apply to vessels operating commercially with a skipper or crew, and which only carry passengers. For the purposes of this Code, any vessel that is not a pleasure vessel is deemed to be operating commercially (refer to Annex 2 for a definition). Examples of relevant vessels include, but are not limited to, an angling or dive vessel operating in estuarial waters, a skippered sailing vessel taking passengers out on a lake, a water taxi, a hotel boat and a narrow boat on a canal doing trips in aid of a restoration project.

    3.2.2 Vessels operated by proprietor’s clubs and associations, whether the operator is corporate, private or of a charitable nature, should comply with the Code.

    3.2.3 The Code is not intended to apply to:

    · Self-drive hire craft or bareboat charters (where there is no work activity being carried out by those hiring the vessel);

    · Pleasure vessels, as defined in Annex 2 and the Merchant Shipping (Small Commercial Vessels and Pilot Boats) Regulations 2004;

    · Vessels operated by establishments licensed by the Adventure Activities Licensing Authority (AALA); For more information about AALA, contact them at

    17 Lambourne Crescent
    Cardiff Business Park
    Llanishen
    CARDIFF
    CF14 5GF 029 2075 5715

    www.aala.org

    · Vessels operating as part of Royal Yachting Association recognised training establishments; for further information contact the Royal Yachting Association at

    RYA House
    Ensign Way
    Hamble
    Southampton
    SO31 4YA 023 8062 7400

    www.rya.org.uk

    · canoes, kayaks, white water rafts, bell boats, dragon boats or similar, which are covered by guidance issued by the national sports governing bodies. For further information contact the British Canoe Union at

    John Dudderidge House
    Adbolton Lane
    West Bridgford
    Notts
    NG2 5AS 0115 982 1100

    www.bcu.org.uk

    · Beach craft - There are guidelines for beach craft at Annex 5.
    From Annex 2 in the link:
    Pleasure Vessel means:

    (A) any vessel which at the time it is being used is:

    (i) in the case of a vessel wholly owned by an individual or individuals, used only for the sport or pleasure of the owner or the immediate family or friends of the owner; or

    (ii) in the case of a vessel owned by a body corporate, used only for sport or pleasure and on which the persons on board are employees or officers of the body corporate, or their immediate family or friends; and

    (iii) on a voyage or excursion which is one for which the owner does not receive money for or in connection with operating the vessel or carrying any person, other than as a contribution to the direct expenses of the operation of the vessel incurred during the voyage or excursion; or

    (B) any vessel wholly owned by or on behalf of a members' club formed for the purpose of sport or pleasure which, at the time it is being used, is used only for the sport or pleasure of members of that club or their immediate family, and for the use of which any charges levied are paid into club funds and applied for the general use of the club; and

    (C) in the case of any vessel referred to in paragraphs (a) or (b) above no other payments are made by or on behalf of users of the vessel, other than by the owner.

    In this definition immediate family means, in relation to an individual, the husband or wife of the individual, and a relative of the individual or the individual's husband or wife; and "relative" means brother, sister, ancestor or lineal descendant.

    *as defined in the Merchant Shipping (Vessels in Commercial Use for Sport and Pleasure) Regulations 1998 – to be superseded by the Merchant Shipping (Small Commercial Vessels and Pilot Boats) Regulations 2004
     
  10. DCockey
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    DCockey Senior Member

    The Inland Waters Small Passenger Boat Code mentions:
    Canal Boat Builders Association Code of Practice for Steel Inland Waterways Craft and Narrow Boat Construction.

    This can be obtained from:

    Canal Boatbuilders Association
    Marine House, Thorpe Lea Road
    Egham, Surrey, TW20 8BF
    Tel: 0844 8009575 Email: cba@britishmarine.co.uk
    This looks like it would be a good reference for the design of a steel narrow boat.
     
  11. Ad Hoc
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    Ad Hoc Naval Architect

    That may be, but most of the MCA rules are being harmonised. The stability reference in Annex 8, is the same for all small boats, narrow/canal boats included. This being:

    ISO 12217-Part1:2002 Small craft - Stability and buoyancy assessment and categorisation - Non-sailing boats of hull length greater than or equal to 6 metres

    It is far easy to find such stuff using the "Red Rules" as they are called. For non-commercial and pleasure vessels, most is just basic preamble and obvious checks. But the stability compliance remains the same.
     
  12. rxcomposite
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    rxcomposite Senior Member

    This is more of a question directed towards DCockey and Ad Hoc.

    I have a collection of Guiding Rules for small craft and have added two more as posted by David and Ad Hoc as listed.

    ISO Standards-International Standards for Small Crafts

    RSG Requirements- Recreational Craft Sectoral Group- Bhremen, Germany
    Pleasure craft and EC assessment-RINA, contains a list of requirements to secure a CE certification (refers to ISO standards).

    RYA- Recreational Craft Directive- Posted by David

    Small Passenger Boat Code- Inland Waters Small Passenger Boat Code- By MCA and AINA- Posted by Ad Hoc

    It seems there are more standards (or regulating body) that appears.

    My first question is, are all these bodies similar to International Class standards, meaning I can opt to choose which one is most suitable for the use of the small craft?

    Question no two is, shall I arranged my directory so that all of these guidelines falls under the heading Small Craft Design and then navigate if the boat intended to be built needs EC certification or just compliance to a single body?
     
  13. SamSam
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    SamSam Senior Member

    That sounds pretty useful. This site is a little interesting too...
    http://rugbyboats.co.uk/Advice-for-boat-owners-on-the-inland-waterways
     
  14. SukiSolo
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    SukiSolo Senior Member

    David, with respect I did not say the fabricator who becomes boatbuilder then has to get the boat certified. I simply meant that as fabricating a boat rather than another structure he/she becomes boatbuilder. The finishing off person, company or owner still has the responsibility of certification. Probably more a terminology thing, I prefer to call the fabrication of hull and deck to be called boatbuilding. Internal work generally fitting out.

    Richard, the Standards - ISO, BSI should be available to view free in your nearest County library and sometimes the smaller ones. They have online subscription passes so you can search relevant documents and copy small parts of them. I'm sure the following standard that Ad Hoc advised as the most relevant will be available.

    ISO 12217-Part1:2002 Small craft - Stability and buoyancy assessment and categorisation - Non-sailing boats of hull length greater than or equal to 6 metres

    Thanks Ad Hoc for your insight into the harmonisation of standards. You are a lot closer to this area than some us so it is very useful to know what is going on. It is the 'Draft' legislation that is very difficult to obtain sometimes. Your input much appreciated.

    A few years ago I had to join the British Library as it was the only place in London which held copies of ISO an BSI standards. One place in a city of 8 million.

    I might also add that it was the RYA, who proposed licensing amateur builders (small dinghy class), so that they comply with the EU Directives on RCD from 2004. Full details available if anyone is interested. Kicked into the long grasss for the time being....
    Interesting SamSam, I had a sticker sent me by the RYA confirming exemption from the RCD in 1997 a bit before the RCD came into force.
    Small racing craft are exempt even under the later Directive, if amateur built but are supposed to display a plaque/sticker to that effect.
    It is exactly the problem of HIN or CIN that the Authorities struggle with. How do you get a racing sailboat to display one?, when it is amateur built. All the legislation is geared to professional 'bulk' builders not one offs. Even worse for anything experimental, it does not fit into a neat category. Doubtless officialdom would like every prototype to conform to something or another..... Sometimes legislation comes from the right place sometimes it is worthless.
     

  15. Ad Hoc
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    Ad Hoc Naval Architect

    Not wholly sure what you mean by International Class Standards (may be you mean SOLAS?). However, you must comply with what is says in the SOR (hence having one, so you know what the design must satisfy). Failing that, you must seek guidance from the Flag state asking them which is the most appropriate statutory legislation to apply.

    You can short circuit most of this by simply applying the EU directive. Since if you comply with the EU Directive a Flag state which is a signatory, must accept it. Unless there is a very valid reason why it is not appropriate. Like changing the rules (again!!) or you’ve selected the wrong category!

    Word of caution though. You may be able to have your vessel accepted under local flag state rules…which are not necessarily the same as EU Directive rules. So taking your vessel from one member state to another may fall fowl of this administration nightmare. Thus check in advance.

    “It” keeps being kicked about. I’m on several committees which are looking at “harmonising” or changing such rules for vessels which fall outside the norm…it is a very very slow process.
     
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