Coding required for Aluminium boat build in UK RCD / Maybe Commercial

[Robert-Shetland]

Hi again all,
Thanks for your help the last time.

I have another question for you, i am just starting my first boat build from an approved design from a professional designer.

I have been welding for years, 20 plus, very experienced and competent in it.
The only issue is, I once had Coding's when I was a bit younger and doing it for the company I worked for but since being out of that type of work as my full time job it has all lapsed a long time ago.

As regards RCD and ISO certification requirements, do i need to get coded to BS EN ISO 9606 or another to be able to build boats and get them CE marked?

There is a lot of conflicting information online regarding this and in the Recreational Craft Directive I cannot find one mention of it.

Any info would be more than helpful and if possible if you could provide sources for this so I can have it to hand to refer to, as I say I can find nothing certain on this.

Thanks

 

[Ad Hoc]

Hi Biscuit,

For this part:

...to be able to build boats and get them CE marked?...

This is just a simple measure of compliance. And by that I mean, who is going to be the judge of the compliance.

Building to get a CE mark, the design, from your professional designer, has been (I assume) designed to satisfy a set of rules/codes to demonstrate a measure of compliance. So, what are the rules/codes that the designer has used?
This is the first part of the question.

You also mention:

...There is a lot of conflicting information online regarding this and in the Recreational Craft Directive I cannot find one mention of it....

In the RCD is a set of various rules/codes for a measure of compliance.
ISO is just one of many. Classification rules, is also another etc.

Hence the question above, which rules/codes did your designer use, to design the boat, as the Design's measure of compliance?

If they used Classification society rules, this then becomes easy. Since the dwgs, from the designer, will have been sent to Class for plan approval. The dwgs will come back, "stamped" approved (or with mods to be approved).
So, this satisfies the design part.

When you come to build, you will be building to the dwgs that have been stamped approved by the Class society.
To build to Class rules, it is clear, what standards you need to pass. You will take a simple down-hand and/or over-head weld test. These are, as I am sure you know, to establish whether you can perform major structural welds and their location on the vessel. Since if you pass the down-hand weld test but not the overhead, all your welding can only be done down-hand.

Your work will be inspected by the Class surveyor for compliance of the quality, the location you did the welds and if it is built, as per the dwg...AND... your approval welding cert too. To ensure what thcikness and locations you are permitted to weld, and the date of expiry of your cert. And then, the welds you do, some of them, will be NDT tested too, for the Class seal of approval.

Thus, going the Class route is easy and well defined...in terms of procedures and standards of compliance.

If the design has gone the ISO route, this is not so easy at all.
Since there is no centralised Authority/body of ISO to inspect/survey and conduct tests. ISO, is just a set of codes for compliance nothing else. ISO is only an institution that creates a set of rules for XX or YY, that is it.. There is no inspection dept in ISO in that sense. Just a set of rules, such as ISO 15614-2:2005 & 15607:2003, for example. But who inspects it and says it passes??? That is not the role/job of ISO.
You may find a company that is registered as an ISO "notified body", it could be Joe Bloggs down the road and his small welding shed, or it could be a Welding Equipment supplier etc etc...in other words, anyone that has approached ISO to become a notified body can then perform the task of the inspection and surveying.

The point is, there is no centralised consistent body for inspection and approval in ISO...anyone that is registered as a notified body can do it....they are independent from ISO and must be registered under ISO as the notified body.

What most people do not realise is that Classification Societies are also, notified bodies. Thus if you go down the Class route, you can get a double whammy, a Class cert Build and a CE mark.
This of course will be more expensive.

So, back to the first question...you need to ask your Designer, what codes/rules of compliance did they use to design the boat for them to get their "Stamp" of approval...and that should then be your route?

 

[Rumars]

You need to ask the MCA, and you need to specify if you want to work for the internal or external market. Until we know more about the UK's future relationship with the EU all is unclear. Right now you can self declare the CE mark until the end of the transition period. I doubt it will be possible next year, but miracles do happen. RCD compliance will have to be done via a third party and will be the EU importers problem.
I expect internal market rules to stay the same as before.

 

[Robert-Shetland]

Hi Biscuit,

For this part:



This is just a simple measure of compliance. And by that I mean, who is going to be the judge of the compliance.

Building to get a CE mark, the design, from your professional designer, has been (I assume) designed to satisfy a set of rules/codes to demonstrate a measure of compliance. So, what are the rules/codes that the designer has used?
This is the first part of the question.

You also mention:


In the RCD is a set of various rules/codes for a measure of compliance.
ISO is just one of many. Classification rules, is also another etc.

Hence the question above, which rules/codes did your designer use, to design the boat, as the Design's measure of compliance?

If they used Classification society rules, this then becomes easy. Since the dwgs, from the designer, will have been sent to Class for plan approval. The dwgs will come back, "stamped" approved (or with mods to be approved).
So, this satisfies the design part.

When you come to build, you will be building to the dwgs that have been stamped approved by the Class society.
To build to Class rules, it is clear, what standards you need to pass. You will take a simple down-hand and/or over-head weld test. These are, as I am sure you know, to establish whether you can perform major structural welds and their location on the vessel. Since if you pass the down-hand weld test but not the overhead, all your welding can only be done down-hand.

Your work will be inspected by the Class surveyor for compliance of the quality, the location you did the welds and if it is built, as per the dwg...AND... your approval welding cert too. To ensure what thcikness and locations you are permitted to weld, and the date of expiry of your cert. And then, the welds you do, some of them, will be NDT tested too, for the Class seal of approval.

Thus, going the Class route is easy and well defined...in terms of procedures and standards of compliance.

If the design has gone the ISO route, this is not so easy at all.
Since there is no centralised Authority/body of ISO to inspect/survey and conduct tests. ISO, is just a set of codes for compliance nothing else. ISO is only an institution that creates a set of rules for XX or YY, that is it.. There is no inspection dept in ISO in that sense. Just a set of rules, such as ISO 15614-2:2005 & 15607:2003, for example. But who inspects it and says it passes??? That is not the role/job of ISO.
You may find a company that is registered as an ISO "notified body", it could be Joe Bloggs down the road and his small welding shed, or it could be a Welding Equipment supplier etc etc...in other words, anyone that has approached ISO to become a notified body can then perform the task of the inspection and surveying.

The point is, there is no centralised consistent body for inspection and approval in ISO...anyone that is registered as a notified body can do it....they are independent from ISO and must be registered under ISO as the notified body.

What most people do not realise is that Classification Societies are also, notified bodies. Thus if you go down the Class route, you can get a double whammy, a Class cert Build and a CE mark.
This of course will be more expensive.

So, back to the first question...you need to ask your Designer, what codes/rules of compliance did they use to design the boat for them to get their "Stamp" of approval...and that should then be your route?

Thanks for your very detailed reply, i will speak to the designer next week and see what he says on it.
But from what you said, regardless of which way i go it very much seems i will have to do the welding tests and get tbe certs, unless i am mistaken on this?

 

[Robert-Shetland]

You need to ask the MCA, and you need to specify if you want to work for the internal or external market. Until we know more about the UK's future relationship with the EU all is unclear. Right now you can self declare the CE mark until the end of the transition period. I doubt it will be possible next year, but miracles do happen. RCD compliance will have to be done via a third party and will be the EU importers problem.
I expect internal market rules to stay the same as before.

Thanks for your reply also,
You mention that i can self declare the CE mark, how do i go about this? And certainly for the moment i will be just aiming at the UK internal market, cant see anything going to the EU certainly not for a few years.
As far as the self declaration goes. How do i go about getting that done? Does someone need to inspect it still? And i suppose the main question still is, do i need to be coded to do this self declaration?
Thanks

 

[Rumars]

If you are aiming at the internal market RCD and CE are not valid anymore, CE will be replaced by the UKCA and the RCD is replaced by whatever national legislation the MCA will make. You need to research what those regulations are, for the UKCA you can start here:
Using the UKCA mark from 1 January 2021 https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021

 

[Robert-Shetland]

If you are aiming at the internal market RCD and CE are not valid anymore, CE will be replaced by the UKCA and the RCD is replaced by whatever national legislation the MCA will make. You need to research what those regulations are, for the UKCA you can start here:
Using the UKCA mark from 1 January 2021 https://www.gov.uk/guidance/using-the-ukca-mark-from-1-january-2021

Thanks for that,
I had already downloaded tody the CE self declaration form, do you know if there is one like it for the new UKCA mark? Can you still self declare / certify with this coming into force?
Thanks

 

[Rumars]

Apparently you still can, as long as the Recreational Craft Regulations 2017 are still valid. The Recreational Craft Regulations 2017 https://www.legislation.gov.uk/uksi/2017/737/contents/made

 

[Robert-Shetland]

Apparently you still can, as long as the Recreational Craft Regulations 2017 are still valid. The Recreational Craft Regulations 2017 https://www.legislation.gov.uk/uksi/2017/737/contents/made

Thanks very much for all the info, really helped me out, thanks.