Gwylan
Well-Known Member
An alternative would be for everyone who anti fouls their boat or changes the engine oil or similar items to "grass themselves up " to the MCA . To the point that an overloaded system collapses in on itself.
Replying to the MCA consultation
- Thread starter Tomahawk
- Start date
An alternative would be for everyone who anti fouls their boat or changes the engine oil or similar items to "grass themselves up " to the MCA . To the point that an overloaded system collapses in on itself.
[70521]
Well-Known Member
As a "professional engineer" am I qualified to do anything on the boat, apart from make the tea and pull bits of string?
JumbleDuck
Well-Known Member
Although 80% of zero is still zero!
Oops.
JumbleDuck
Well-Known Member
Only a little. Registered aircraft in general have to be worked on by qualified people or at the very least checked by them. There are, as I understand it, very few jobs which an unqualified owner can do on her or his own Cessna 152 or Piper Cub. In my own glider flying days it was fine for me to work on my own glider, as long as I got everything signed off by a BGA inspector. Then EASA took over and things got a LOT harder, just as I left the sport.
On the other hand, you can't really do much damage to anything else in a Westerly Centaur whereas a quarter of a ton of GRP hitting the wing of an Airbus 380 on the approach to Heathrow could spoil the days of an awful lot of people
Gwylan
Well-Known Member
Post priori who will define competent?
Sailing is a risky business. The smarter ones amongst us spend our time trying to limit the risk.
There is little to guarantee that a qualified professional will do much better or be available when the brown stuff hits the rapidly rotating.
Tomahawk
Well-Known Member
Can we agree on a few salient points as a response?
Then the question becomes how to present our comments?
A bit of help from the mods might go a long way.
Then the question becomes how to present our comments?
A bit of help from the mods might go a long way.
Neeves
Well-Known Member
It sounds as if, as a back stop, you should include Minn on this. Cannot do harm, might short circuit the whole thing
Jonathan
Jonathan
anoccasionalyachtsman
Well-Known Member
I've been asked to come up with a draft letter to be circulated to members of my club - for them to copy/modify and send on. It's twenty years since I did anything like this and would really appreciate it if those that have written would either publish it here or send it to me via pm.
rgarside
Well-Known Member
A good place to start is with the RYA - follow this link:-
https://www.rya.org.uk/knowledge-ad...nsultationonyachtandpowerboatsafetyatsea.aspx
You can use that material in making your response.
PhillM
Well-Known Member
OK this is my email to the MCA. Hope it makes sense and gets a decent reply:
Dear Sir / Madam,
I am writing to express concern over the Draft MGN notices in relation to yacht and power boat safety. For context, I am the owner of a 1961 wooden classic yacht (Cheverton Caravel Mk2). I fully refitted the boat (using trained professionals where I deemed necessary) and continue with a maintenance regime to ensure that she is fit for purpose.
My general comments are as follows:
1.1) There would appear to be a determination to remove maintenance from owners and insist on marine professionals to undertake the majority of work on a small vessel. While I can see that you do not wish amateurs to take on jobs beyond their capability and that some jobs, or example gas installations and 240V electrics, require a certified professional, your current wording suggests that almost all jobs that need to be done will require a professional.
1.2) I firmly believe that undertaking maintenance not only ensures that the owner is able to deal with problems at sea, but also has available the tools and equipment needed to complete the job as efficiently and safely as possible. Removing this ability will, in my opinion, inherently reduce safety at sea.
1.3) There are not the number of trained professionals available to carry out the work as described in your notices. This will push up prices, prevent boat ownership and in future damage the sport and industry.
1.4) There appears to be a lack of recognised qualifications that cover the wide number of skills needed to maintain the disparate fleet of commercial and pleasure craft that exist within the UK. Consider that you refer only to GRP designed boats, in your proposals but fail to consider steel, aluminium, ferro-cement or wooden construction.
1.5) You appear not to have considered the usage of craft. Small cruising boats that may perhaps take part in weekend club cruiser-racing are in no way comparable to high performance racing craft that are designed and used for RORC events. In my view, you are using your regulations to attempt to prevent accidents within a very small community, but instead of saying so, you are including all craft, regardless of usage. This means that instead of carefully considered guidance for your target audience, you have created generalised advice. To me you have gone for one size to fit all, when in fact it has ended up not fitting any. Why not have guidance for the various classes of vessels, which could then be appropriately tailored to each usergroup?
1.6) With my above point, I would ask you to consider recent changes to car regulations that remove cars that are over 40 years old from the MOT regime. This seems analogous with excluding classic yachts from your guidance notes, as in many cases, what you have written does not apply.
My specific comments are as follows:
2) Modifications, Damage and repairs:
2.1) You do not appear to have considered the age of vessels and refer to regulations that were not existence at the time that some craft were designed and built. For example, my own boat was built in 1961, the designer has sadly passed away, the yard does not exist and there are no plans, maintenance manual or other such documentation in existance. She has had over 7 owners and I do not have a complete history of the work done or modifications made. This means that I would be unable to meet the standard set. Does this mean that my boat is unseaworthy? I think not. In fact I have done extensive work to ensure that she is.
2.2) You do not determine "Safety critical" maintenance. Is for example, changing a fuel filter, changing the oil or even filling the water tank considered to be safety critical? I could argue that a mechanical breakdown can be critical. So can running out of, or having foul water. Where do you draw the line?
2.3) Consider changing the anchor style or chain weight and length. This form of modification could be considered to be good practice in light of the area of operation. Yet, in your documentation, this would require a marine professional to undertake. Is there such a person and what qualification should they hold to be allowed to do this work - are you going to publish a list of "approve qualifications" for every job that could be deemed "safety critical"?
2.4 I note your requirement for all modification that changes the design configuration requires re-certification. In my case there is no design template available, not certification. How will this apply to a classic yacht?
3) Stowage of Life Rafts - Life jackets
3.1) I would argue that removing and washing the gas canister of a Life Jacket is more likely to introduce corrosion and potential for systematic failure. Consider a small family craft that has been sailing for a day. After returning to the marina the canisters are removed, washed and left to dry. Being in a small boat is not really a good place for them to dry quickly. This could lead to them being removed from the boat and with the potential to be lost, forgotten, not replaced, etc. In my opinion, this recommendation is unworkable for all but large scale commercial operators.
3.2) Positioning lifebouys and dan buoys on the transom is not always practical. Nor actually sensible. Consider craft without a pushpit, or those with centre cockpits. This seems and rather badly considered piece of advice.
4) Prepardedness for Non-Coastal Passages
4.1) The way this is currently written would, for example, require the lift and inspection of every craft that wishes to cross the channel from, say Plymouth to Cherborg. That is unlikely to happen (except for annual winter maintenance).
4.2) I contest that a rigging survey by a competent professional would not of itself mitigate risk. I have recently had three rig surveys done, within a month of each other. All three reputable rigging companies made separate and often conflicting recommendations. There appears to be no standardisation within the rigging industry, no standard to inspect to and no regulatory body in which to take disputes. Furthermore, there appears to be no standard to which a rigger must operate. Furthermore, each also caveat their work so that should a rig fail, there is no come-back on them.
5) Rigging
5.1) Please see point 4.2 above. Specifically in respect of "following all advice". Until and unless a set of standards are available, this guidance is not workable.
5.2) You appear to have ignored the difference in vessel usage in respect of rig checks. This ambiguity means that some owners will ignore your recommendations on the basis that it does not apply to them (for example coastal cruising) while others may be compelled to purchase unnecessary services. Adding in various class of use, would be useful.
5.3) Your recommendation to send a person aloft daily, on a non-coastal passage seems to me to be adding risk into this endeavour. Consider rough weather, is a daily rig check more important than crew injury from being thrown around while aloft? Also consider single handed sailors - do you really expect them to climb the mast on their own?
6) Emergency Procedures
6.1) It would seem sensible to add the requirement that Dan Buoy carry a VHF MOB device so that the yacht can more easily steer back to the location of the MOB.
I trust that you find the above useful and look forward to your response.
Phill
Dear Sir / Madam,
I am writing to express concern over the Draft MGN notices in relation to yacht and power boat safety. For context, I am the owner of a 1961 wooden classic yacht (Cheverton Caravel Mk2). I fully refitted the boat (using trained professionals where I deemed necessary) and continue with a maintenance regime to ensure that she is fit for purpose.
My general comments are as follows:
1.1) There would appear to be a determination to remove maintenance from owners and insist on marine professionals to undertake the majority of work on a small vessel. While I can see that you do not wish amateurs to take on jobs beyond their capability and that some jobs, or example gas installations and 240V electrics, require a certified professional, your current wording suggests that almost all jobs that need to be done will require a professional.
1.2) I firmly believe that undertaking maintenance not only ensures that the owner is able to deal with problems at sea, but also has available the tools and equipment needed to complete the job as efficiently and safely as possible. Removing this ability will, in my opinion, inherently reduce safety at sea.
1.3) There are not the number of trained professionals available to carry out the work as described in your notices. This will push up prices, prevent boat ownership and in future damage the sport and industry.
1.4) There appears to be a lack of recognised qualifications that cover the wide number of skills needed to maintain the disparate fleet of commercial and pleasure craft that exist within the UK. Consider that you refer only to GRP designed boats, in your proposals but fail to consider steel, aluminium, ferro-cement or wooden construction.
1.5) You appear not to have considered the usage of craft. Small cruising boats that may perhaps take part in weekend club cruiser-racing are in no way comparable to high performance racing craft that are designed and used for RORC events. In my view, you are using your regulations to attempt to prevent accidents within a very small community, but instead of saying so, you are including all craft, regardless of usage. This means that instead of carefully considered guidance for your target audience, you have created generalised advice. To me you have gone for one size to fit all, when in fact it has ended up not fitting any. Why not have guidance for the various classes of vessels, which could then be appropriately tailored to each usergroup?
1.6) With my above point, I would ask you to consider recent changes to car regulations that remove cars that are over 40 years old from the MOT regime. This seems analogous with excluding classic yachts from your guidance notes, as in many cases, what you have written does not apply.
My specific comments are as follows:
2) Modifications, Damage and repairs:
2.1) You do not appear to have considered the age of vessels and refer to regulations that were not existence at the time that some craft were designed and built. For example, my own boat was built in 1961, the designer has sadly passed away, the yard does not exist and there are no plans, maintenance manual or other such documentation in existance. She has had over 7 owners and I do not have a complete history of the work done or modifications made. This means that I would be unable to meet the standard set. Does this mean that my boat is unseaworthy? I think not. In fact I have done extensive work to ensure that she is.
2.2) You do not determine "Safety critical" maintenance. Is for example, changing a fuel filter, changing the oil or even filling the water tank considered to be safety critical? I could argue that a mechanical breakdown can be critical. So can running out of, or having foul water. Where do you draw the line?
2.3) Consider changing the anchor style or chain weight and length. This form of modification could be considered to be good practice in light of the area of operation. Yet, in your documentation, this would require a marine professional to undertake. Is there such a person and what qualification should they hold to be allowed to do this work - are you going to publish a list of "approve qualifications" for every job that could be deemed "safety critical"?
2.4 I note your requirement for all modification that changes the design configuration requires re-certification. In my case there is no design template available, not certification. How will this apply to a classic yacht?
3) Stowage of Life Rafts - Life jackets
3.1) I would argue that removing and washing the gas canister of a Life Jacket is more likely to introduce corrosion and potential for systematic failure. Consider a small family craft that has been sailing for a day. After returning to the marina the canisters are removed, washed and left to dry. Being in a small boat is not really a good place for them to dry quickly. This could lead to them being removed from the boat and with the potential to be lost, forgotten, not replaced, etc. In my opinion, this recommendation is unworkable for all but large scale commercial operators.
3.2) Positioning lifebouys and dan buoys on the transom is not always practical. Nor actually sensible. Consider craft without a pushpit, or those with centre cockpits. This seems and rather badly considered piece of advice.
4) Prepardedness for Non-Coastal Passages
4.1) The way this is currently written would, for example, require the lift and inspection of every craft that wishes to cross the channel from, say Plymouth to Cherborg. That is unlikely to happen (except for annual winter maintenance).
4.2) I contest that a rigging survey by a competent professional would not of itself mitigate risk. I have recently had three rig surveys done, within a month of each other. All three reputable rigging companies made separate and often conflicting recommendations. There appears to be no standardisation within the rigging industry, no standard to inspect to and no regulatory body in which to take disputes. Furthermore, there appears to be no standard to which a rigger must operate. Furthermore, each also caveat their work so that should a rig fail, there is no come-back on them.
5) Rigging
5.1) Please see point 4.2 above. Specifically in respect of "following all advice". Until and unless a set of standards are available, this guidance is not workable.
5.2) You appear to have ignored the difference in vessel usage in respect of rig checks. This ambiguity means that some owners will ignore your recommendations on the basis that it does not apply to them (for example coastal cruising) while others may be compelled to purchase unnecessary services. Adding in various class of use, would be useful.
5.3) Your recommendation to send a person aloft daily, on a non-coastal passage seems to me to be adding risk into this endeavour. Consider rough weather, is a daily rig check more important than crew injury from being thrown around while aloft? Also consider single handed sailors - do you really expect them to climb the mast on their own?
6) Emergency Procedures
6.1) It would seem sensible to add the requirement that Dan Buoy carry a VHF MOB device so that the yacht can more easily steer back to the location of the MOB.
I trust that you find the above useful and look forward to your response.
Phill
Kukri
Well-Known Member
That’s really good, Phill. You have gone through the draft MGNs carefully and made sensible points.
PhillM
Well-Known Member
Thank you, I hope that some of what I spotted is considered by the MCA and that by joining in my voice helps to add to the overall volume of dissent over these guidance notes.
Robert Wilson
Well-Known Member
To PhillM
Well said :encouragement:
I had hoped that I said likewise, but I now realise nowhere near as eloquently or succinctly.
Well said :encouragement:
I had hoped that I said likewise, but I now realise nowhere near as eloquently or succinctly.
Last edited:
rgarside
Well-Known Member
PhillM - Excellent reply, well done! Would that I had the patience to be so thorough.
Plum
Well-Known Member
Phill, your input to the consultation is excellent, thankyou, although I read it after preparing my response which I quote here in case it helps others to write their own letter:-
I request you to re-consider your whole approach to the leisure sector and to separate it from advice to commercial operators. Your guidance does not recognises the full range and complexity of craft in the leisure fleet and the knowledge and experience of many owners who do their own maintenance and repairs to a very high standard. You have provided no evidence that owner maintenance is worse than "professional" and until you can clearly define an "experienced marine professional" or a "competent person" you should remove all reference to maintenance and repair of leisure craft from all guidance notes.
Owners spend much more time on checking, maintaining and repairing their vessels in order to ensure their own, and their families, safety and will be more thorough than a "profesional" who's main interest is charging a competitive price for minimal working time. Some "profesionals" are very competent and experienced but the owner has no guaranteed method of choosing who they are.
I have direct experience of rescues of leisure craft at sea resulting from gear failure and in the majority of cases the failur occured after work done by a profesional person. In none of the rescues the gear failure was as a result of work done by the owner. Therefore, if your guidance influences owners to have more work done by professionals, gear failures will increase.
Www.solocoastalsailing.co.uk
I request you to re-consider your whole approach to the leisure sector and to separate it from advice to commercial operators. Your guidance does not recognises the full range and complexity of craft in the leisure fleet and the knowledge and experience of many owners who do their own maintenance and repairs to a very high standard. You have provided no evidence that owner maintenance is worse than "professional" and until you can clearly define an "experienced marine professional" or a "competent person" you should remove all reference to maintenance and repair of leisure craft from all guidance notes.
Owners spend much more time on checking, maintaining and repairing their vessels in order to ensure their own, and their families, safety and will be more thorough than a "profesional" who's main interest is charging a competitive price for minimal working time. Some "profesionals" are very competent and experienced but the owner has no guaranteed method of choosing who they are.
I have direct experience of rescues of leisure craft at sea resulting from gear failure and in the majority of cases the failur occured after work done by a profesional person. In none of the rescues the gear failure was as a result of work done by the owner. Therefore, if your guidance influences owners to have more work done by professionals, gear failures will increase.
Www.solocoastalsailing.co.uk
PhillM
Well-Known Member
I got the same standard reply saying that they intend to make it clear that the guidance is not compulsory. I have replied with:
Dear Sir / Madam,
Thank you for your prompt response. However, while I understand that the MGN’s are not compulsory, they do set a standard that may be adopted by insurers and, should the worst happen, a Jury.
The way that your notices are currently written leaves significant ambiguity, so as to be unclear as to what an owner can and cannot do to follow best practice.
With that in mind I would be grateful if you could provide a detailed response to each of my points. That would at least provide clarification, upon which I can further comment.
In summary, saying “this is not compulsory” is not a sufficient answer as it leaves the amateur leisure boat open to criticism, as your advice is both vague and in places, impractical to follow.
Thank you for your assistance.
Phill
Dear Sir / Madam,
Thank you for your prompt response. However, while I understand that the MGN’s are not compulsory, they do set a standard that may be adopted by insurers and, should the worst happen, a Jury.
The way that your notices are currently written leaves significant ambiguity, so as to be unclear as to what an owner can and cannot do to follow best practice.
With that in mind I would be grateful if you could provide a detailed response to each of my points. That would at least provide clarification, upon which I can further comment.
In summary, saying “this is not compulsory” is not a sufficient answer as it leaves the amateur leisure boat open to criticism, as your advice is both vague and in places, impractical to follow.
Thank you for your assistance.
Phill
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