Boat Safety Scheme - views

Re: At least we agree on something .....

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One point here....I know many people who charge their boats to the company presumably for entertaining, or whatever. Others I know of claim to be doing some sort of business-related work. I guess that those people had better make sure that they have certificates, judging from the information you have posted?

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Not sure - if they are effectively hiring the boat to the company, or if the company is hiring the boat to them, then they would appear to cop for the whole lot - It also potentially brings in the whole Health 'n' Safety At Work act / Workplace (Management) Regulations, etc, even if they are "working from home" or equivalent. Then there's the MCA coding thing...

To be honest, if it's anything other than a pure private leisure / pleasure situation, I haven't got the foggiest where you stand!

Still looking for gas fitters who work for free, but there are "Mechanical Technicians" where I work who may be called on to work on gas fired process equipment. The question of CORGI registration arose, and the conclusion was that this was not a legal requirement (based on the above) - competence is still required, though.

Have got a copy of the ACOP at work if it helps anyone...

Andy
 
Re: Wrong again

You have picked up on a general statement in the regs that says a fitter has to be competent.
If you read further you will see that they define this by saying that in order to carry out work on a gas fitting / storage vessel you need to hold membership of "a class of persons" approved by the HSE, At this moment in time CORGI are currently the only body that can supply this membership.

You say you have operatives at your premises whom you deem are competent, but are in fact not members of “a class of persons” approved by the HSE. Well if this is the case then you are breaking the law.

However you can apply to HSE for written dispensation if you think your fitters are competent, but this waiver has to be given by them in writing, when you stop using your fitters for the job you have to inform them, again in writing.

I`m not arguing with you now Andy, it`s just that you don`t seem to have a good grasp of the current regs. as they stand. Seven years ago what you said would have been correct but not now.

I`m only trying to be helpful.

………..
 
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It is open to individual inspectors own ideas of what the rules say.
And the rules have been constantly changed.
Boatyards were deliberately excluded from the scheme and an open invitation was put out to anyone that could afford the couple of grand to sit the exam.

Cert's can be picked up in pub's for £20-£100!!

No one has ever been struck off the inspectors list as far as i know despite loads of documented evidence that the rules have not been stuck to.

Joe

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Unfortunately your assertions specifically detailed above are factually inaccurate or need substantiating.

The requirements are not constantly changed. Successful lobbying by boat owners groups and the marine trade led to the 2001 review and that also prompted the work leading up to last year's consultation and implementation of the further modernisation with a goal-achieving set of requirements last April.
Minor changes to compliance options will develop over time as technology moves on, novel solutions appear or risk assessments present new evidence. The other factor that may force change in the future is that which is driven by the primary regulators such as the HSE or MCA.

Examiners are required to apply the instruction documents known as the examiners checking procedures, accurately and consistently otherwise they risk investigation and if found wanting a set of sanctions of increasing severity. (see below)

There are numerous examiners based in and working for boatyards.

Please send in correspondence with evidence of 'pub selling' of certificates or qualify your statement as being purely anecdotal 'or' urban myth. We hear these tales all the time, but no one has yet supplied a scintilla of evidence other than annecdote. Please believe me if the evidence is presented, robust action will be taken against any person offering certificates for sale.

A number of examiners have been permanently suspended, some have been asked to retrain at their own expense (around £1500 plus accommodation), some have had to undergo reassessment and some have received letters of instruction which lays on their files and will be produced if they are found 'guilty' in another investigation.

Any other points in Joe's post are pure opinion and so treated as such.

Kind regards
Rob
 
Re: Wrong again

UA,

tried to send PM, but you aren't accepting them. What has happened in the last 6 years which changes my interpretation ? - genuine question, and I accept your offer of help! PM me would be best, as I think we've gone way off the original topic.

Andy
 
Rob,
If that is true, then you need to be doing some serious 'spinning' of the current status. Many of us have left the Thames because of onerous requirements, and lack of trust in the surveyors involved. A proactive campaign to ameliorate the lack of genuine information on changes of practice/surveyors

I can't see me coming back, but it might help others

Brendan
 
[ QUOTE ]
Rob,
If that is true, then you need to be doing some serious 'spinning' of the current status. Many of us have left the Thames because of onerous requirements, and lack of trust in the surveyors involved. A proactive campaign to ameliorate the lack of genuine information on changes of practice/surveyors
Brendan

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Brendan,
Noted and I understand and appreciate what you are saying. Whilst 'spinning' isn't a term I would use to describe the job in hand. I anm the communications manager amongst other jobs for the BSS so public relations is part of my cannon, but spinning implies an element of ... shall we say 'emphasis'. I don't think the Scheme can do that, the truth will always surface, so all I must do is present the facts and then let them speak for themselves.

I take your non-return to the Thames as a done-deal, but I can still promote to you and others a read of the new BSS Guide.

I hope I've achieved amongst lots of aims, three things clearly and I'd welcome views from here as to how near to success we are with the following goals.

Firstly, we want to set out which of checks are requirements and which are advice. Secondly we want the reasons behined each check and the risk being managed to be apparent.
Thirdly, and this is pertinent to your point, each check, the checking action action and the pass or fail criteria are clearly described. There is now no excuse for those examiners who apply mists and magic - indeed the new edition of the BSS Guide is taken from the examiner's checking procedures. The two documents only differ in administrative detail and the Guide contains a lot more useful advice and best practice information for boat owners.

In fact I think its possible that the Guide maybe of use to you, even on the sunny south coast. It's constructed as a 'maintenace for safety' handbook so could be used in theory by any small boat owner - you can scan/download it at www.boatsafetyscheme.com

Anyway thanks for the note and watch this space.
 
Rob, I once assumed that the BSS requirements are worked on with equipment manufacturers' input in order to ensure that what is required is already available. I don't intend to raise the old chestnut over one time non-availability of BSS standard gas fridges, I went electric over that and never regretted it. When I moved to the Thames last year a fail point was the plastic drain plug in my primary filter/water separator. I popped into our local LSUK place to get a metal plug to be told that "we don't make them any more". As it happened they had a tray of old spares and a nuppence deal concluded. The tech who gave me the plug did check availbility on the stock computer so I assume he knew what he was talking about.

Perhaps a minor and petty grouse, but at the time I was decidedly vexed, having to have a retest (no charge, but a fag) for a part the filter manufacturer maintained was not available anyway.
 
Hi Andrew - Re filter plug (27/10 @ 14.17)
I cannot be sure of my ground on this, but will get an answer from our tech boys in the morning.

We do have a lot of contact with the trade at two levels, the BMF, BAFE, CoGDEM, LP Gas Assoc and others as representative bodies, and then with numerous individual companies.

But just going back to the principle, the requirement for fire protection of the filtering arrangements aligns with the RCD. So in that case, where does this leave new boat builders? As you can see at 2.12 (esp 2.12.3) if the filter is without the engine space or can be made to be so, then the fire resistance of the filter inc plug is not required.

We also ask at 2.12.2 if the filter is a suitable proprietary filter for marine use. Implicit in that is that need for the filter inc plug to be manufactured to ISO 10088. The argument then goes that if ‘manufacturer A’ is supplying it for 'marine use' then they must believe the ISO is supported. In the absence of any manufacturers stamp on the component to that effect, we would need a manufacturer’s statement or similar evidence eg packaging statement etc. PS. This is just an example of a logic stream and may not apply to your situation.

If it is demonstrable that the BSS requirements are not compromised and the navigation authorities duties of care are covered, then it's in the Scheme's interest to have boats on the water. Hence our strapline.
Cheers
 
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