Friday 29 August 08 - 23:05
 

Boat Safety Scheme

Simpler Boat Safety Scheme on the way

Boat-owners could benefit from a simpler, modernised Boat Safety Scheme (BSS) under new proposals announced in July, the aim of which is to replace the many detailed requirements in the existing scheme for privately owned boats with new, risk-based goals, as David Foxwell explains
Watts: effective management of risks
Watts: effective management of risks

Often compared to a MOT for boats, the BSS was jointly established in 1997 by the Environment Agency (EA) and British Waterways (BW) to promote safety on the inland waterways in respect of boats, their installations and components.

Meeting these safety standards in order to obtain a navigation licence became a requirement at the same time.

In a nutshell, the aim of the BSS is to ensure boats with engines, and/or cooking, heating, lighting and refrigerating appliances are safe from explosions and fire. It is necessary to have a Boat Safety Scheme certificate, issued by an authorised examiner, in order to licence a boat on most inland waterways.

To date, some 45,000 powered craft have successfully met the requirements, which first became the subject of a review process in 2001, when an independent review of the scope of the BSS requirements recommended that BW and the EA re-publish the full set of check list items, split into essential safety or environmental requirements and best safety practice recommendations.

Now, however, the navigation authorities which support it have unveiled new proposals, which will see a total of 91 detailed requirements replaced by 34 more general goals (see box), proposals that are intended to apply to all privatelyowned boats on the waterways covered by the scheme.

As Graham Watts, manager of the BSS, explained the aim of the latest consultation exercise is to implement a "risk-based" approach to safety. Rather than being prescriptive, with lots of do's and don'ts, the new goals will list principles of good boat maintenance and design that every owner and builder should follow.

Firefighting equipment, for example, is dealt with in just two goals and the proposed new scheme states that "all vessels must carry specified fire-fighting equipment", and that "all firefighting equipment must be in good condition and kept readily accessible for safe use in an emergency".

The goals seek to minimise risks and prevent pollution and, in a change from the current approach, the proposals set out what must be achieved with advice on how this can be done.

They also set out a new, straightforward appeals procedure for boat owners and, for the first time, the proposals include measures encouraging boaters to protect the environment.

The reappraised standards will not significantly affect the boat owner that currently holds a certificate, however craft applying for a certificate for the first time may find that some standards are relaxed compared to the existing compliance levels, making attainment of a certificate more straightforward with a possible reduction in overall costs.

Target dates Speaking to BB in July, Watts provided more details about the review of requirements for the scheme and the target dates for the implementation of the revised scheme.

"Part of the process acknowledges that the Recreational Craft Directive (RCD) is now in place, " Watts told BB, "and allows us to presume that all new craft are being built to ecceptable standards."

This being the case, he added, we want to focus more on the kinds of changes that are introduced after boats are built, wherever possible using existing standards, such as ISO and British Standards as preferred ways of meeting compliance with BSS requirements.

"The key aim of the reform is to ensure efficient and effective management of risks introduced by boats that have been inadequately equipped or maintained and to guide boat owners on matters of risk avoidance, " Watts said. "Modernisation will provide a structure for a modern, risk-based approach, in which general 'goal-setting' requirements replace the existing detailed construction standards. It will also set out a framework for balancing the responsibilities of the navigation authorities and the responsibilities of the individual boater."

Whilst recognising that it is not possible to eliminate all risk, the navigation authorities have a duty - as far as reasonably practicable - to minimise the risks.

The BSS is one of the means they use to try to do so. "It is essential that scheme is effective, " said Watts, "and employs the best possible methods, because the navigation authorities will use it as one of the ways they impose legal obligations on vessel owners and users."

In the latest consultation, a range of subjects is being reviewed and the key proposals on which views are being sought include:

1) Replacement of the 91 existing legally enforceable standards listed in appendix F of the BSS Guide and Annex A3 of the full consultation document, with 34 "goalsetting" general requirements listed in section 5.

2) Changing the existing ways of complying with the general requirements as set out in the BSS Guide.

3) The introduction of a straightforward compliance appeals process in order to safeguard the interests of vessel owners.

4) The introduction of measures to assist boat owners to manage risks for which they have responsibility.

Another feature of the consultation is that the EA and BW are trying to move away from the concept of age-based exemptions, but some exemptions are likely to be kept - probably, for instance, class-based.

In the current BSS, each of the exemptions for older vessels was considered by overlaying the framework principles. "It was clear that those vessel installations meeting the existing exemption level should be accepted as meeting the proposed new general requirements, " say the EA and BW in the consultation document, "and while proposing to accept the exemption levels, the latest industry and other safety standards will be promoted as best practice advice wherever possible and specifically to the point of selection of new or replacement appliances."

The revised BSS will, said Watts, also focus in more detail on the concept of personal safety checks and reinforce the notion of the skipper's responsibility for his craft and the regulations will be supported by new guidance in the framework of a goal-setting approach.

As Watts explained, a regulatory impact assessment of the proposals has also been carried out, setting out the options considered at the time the proposals were drawn up and assessing the impact of the options in terms of the costs, benefits and risks.

"The changes are felt to be needed to ensure the BSS regulations are in line with accepted risk management practices in accordance with the implementation of the recommendations of the BSS Review in 2001, " Watts told BB, noting the consultation is directed at all those who have an interest in the safety of vessels on inland waterways, including owners of vessels, navigation authorities, the marine trade, marine insurance providers and BSS examiners.

Over the past 18 months stakeholder groups represented on the BSS support committees have been involved in drawing up the new proposals. The committee is now seeking a wider representation of views and the new document has been sent to nearly 200 organisations.

Individual boaters are now being asked for their views on these proposed changes, and many boating organisations have already become involved in shaping the new scheme.

The changes are detailed in two documents available from the BSS web site - boatsafetyscheme. com - and anyone interested in making their views known has until September 30 to do so.

Once responses to the consultation have been received, they will be reviewed and the outcome of the consultation will be published.

During late 2004 the proposed general BSS requirements will be subject to notification to the EU Commission, and it is intended to publish the general BSS requirements in early 2005, followed by implementation in April 2005.

Goal-setting - the new requirements

Space restrictions mean we have had to abridge the following list of the 34 goal-setting requirements that the EA and BW intend to use to replace the detailed requirements in the existing scheme.

Permanently installed fuel systems and fixed engines:

. All permanently installed fuel systems and fixed engines must be designed, installed and maintained to prevent the risks of explosion or of fire starting or spreading.

. Fuel tank filling arrangements must prevent any overflow from entering the interior of the boat.

. All fuel filling points must clearly identify the fuel in use.

. Marking must be provided to identify the location of fuel system emergency shutoff devices, or their means of operation, which are not in open view.

. All permanently installed fuel systems must be designed, installed and maintained to ensure to ensure fuel-tight integrity.

. All permanently installed fuel tanks and fuel system connections must be accessible for inspection.

Electrical systems:

. All electrical systems must be designed, installed and maintained to minimise the risks of explosion or of fire starting and spreading.

. All electrical systems must be capable of being safely and quickly disconnected from their power source(s) in an emergency.

. Control and emergency devices, or their means of operation, must be marked when not in clear view or when their function is not clear.

. All battery compartments containing unsealed or open-vented batteries must be adequately ventilated.

Electrical propulsion system:

. All electrical systems must be designed, installed and maintained to minimise the risks of explosion or of fire starting and spreading.

. All electrical systems must be capable of being safely and quickly disconnected from their power source(s) in an emergency.

. Control and emergency devices, or their means of operation, must be marked when not in clear view or when their function is not clear.

. All battery compartments containing unsealed or open-vented batteries must be adequately ventilated.

. All motors, controller equipment and charging equipment relating to electrical propulsion must be adequately ventilated.

Outboard and portable combustion engines and portable fuel systems:

. All portable and outboard engines and portable fuel systems must be designed, installed and maintained to minimise the risks of explosion or of fire starting and spreading.

. All spare petrol must be stored to minimise the risk of fire and explosion.

. All portable and outboard engines with integral petrol or LPG tanks, and all portable petrol tanks, must be stored to minimise the risks of fire or explosion when not in use.

Fire extinguishing and escape:

. All vessels must carry specified fire-fighting equipment.

. All fire fighting equipment must be in good condition and kept readily accessible for safe use in an emergency.

All LPG systems must:

. Be designed, installed and maintained to minimise the risks of explosion or of fire starting and spreading.

. Be secured in a position where escaping gas does not enter the interior of the boat.

. Be designed, installed and maintained to ensure gas-tight integrity.

. All LPG system connections and flexible hoses must be accessible for inspection.

. All LPG control and shut-off devices, or the means to operate them must be readily accessible.

. LPG shut off valves, or their means of operation, must be marked when not in clear view or when their function is not clear.

. All LPG systems must have a suitable means to test that the system is gas-tight.

Appliances and flues:

. Must be designed, installed and maintained to prevent the risks of explosion or of fire starting and spreading.

. All liquid-fuelled appliances must have an emergency shut-off valve located at a safe distance from the appliance.

. All appliances of the following types must be fitted with a device that automatically shuts off the fuel supply if there is a flame failure: catalytic appliances; appliances with a pilot light; appliances with a continuously burning flame.

. Must be designed, installed and maintained to minimise the risk of fire.

. All fuel and power supply systems for appliances must meet the requirements of the relevant other parts of these general requirements. DF Check the full list on www.boatsafetyscheme.com

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Watts: effective management of risks

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