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Recreational Craft Directive


mrartisan

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I currently have for sale my recently completed narrowboat:-

 

http://web.me.com/jpye/narrowboat

 

However, due to the 'Recreational Craft Directive' imposed on boats under five years old, it seems I have to get my documentation more in order. After internet searches, it seems that the RCD is just that, more a compilation of information and not a test-to-pass as I originally thought.

There seems to be much scare-mongering and idle gossip all over the internet concerning the RCD, (as I'm sure there is about all topics). However, something remains unclear about the RCD process:-

 

If the RCD is, as I think I have gleaned, 'a compilation of information' ie: Materials, Processes, Standards, Conformity , etc. then why does the process of achieving RCD compliance seem to be kept out of reach of the sail-away self-builder. After-all, the complicated side of the RCD compliance would have been satisfied by the hull builder (or at least should of been).

So, would it not be better to create a standard format for completing the RCD compliance for the sail-away self-builder, and not make him reliant on a Marine Surveyor to compile the information for him? I think autobiographies are always more exacting than Biographies!

 

Anyway, as I have only just started researching this subject, and need RCD compliance rather sharpish, I though I would post this message to the wealth of knowledge that abounds in the Canalworld forums, any information on this subject would be greatly appreciated, preferably from those of you who have navigated the murky bog of the RCD.

 

Thanks for reading,

 

John.

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So, would it not be better to create a standard format for completing the RCD compliance for the sail-away self-builder, and not make him reliant on a Marine Surveyor to compile the information for him? I think autobiographies are always more exacting than Biographies!

 

 

 

John.

 

Yes but who would make any money doing that.

 

public or university libraries are your friend if you want to read the standards and do it all yourself

 

otherwise there is one organization which (for several hundred pounds) provide a computer programme/guide, the name escapes me but they advertise and have been mentioned on here

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In some ways you are correct that the RCD is a 'compilation of information' but that can be said of many things!

The standards to be reached are fairly exacting, and not in all cases the same as the BSS regs.

In my opinion, at a cost of around £500-£600 it is considerably less stressfull and time consuming to have a surveyor do it, and that will also give peace of mind that things are up to scratch and anything missed that becomes an issue.....or dangerous.....does not lay purely on your own shoulders, but that's just my opinion, and I would advise a good surveyor such as Paul Smith or the like. They can produce a full manual then for you also.

You can of course do it yourself, but there is a lot to wade through!

Good luck!

Edited by Ally
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Yes but who would make any money doing that.

 

public or university libraries are your friend if you want to read the standards and do it all yourself

 

otherwise there is one organization which (for several hundred pounds) provide a computer programme/guide, the name escapes me but they advertise and have been mentioned on here

thanks for your reply, but that is just my point! The boating world or any other for that matter should not be fed on by parasites that feed from the confusion that legislation promotes.

 

Thanks also for the DIY library angle but I don't want to, nor have the time to, interpret the legislation direct. Besides, the majority of the legislation, as I already said, has been satisfied by the hull builder or, is not even applicable to narrow-boats!

 

As a narrowboat community we should be able to compile a 'standard format' approach i.e. applicable to narrow-boats, to satisfy the legislation. And not have to pay yet more 'Quango' bodies to certify our existence!

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As a narrowboat community we should be able to compile a 'standard format' approach i.e. applicable to narrow-boats, to satisfy the legislation. And not have to pay yet more 'Quango' bodies to certify our existence!

As a boat community we can't even agree on cassette or pump out. How will we agree on a standard format for a complicated document?

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I have done the research myself and have accessed all the RCD Harmonised standards and read them. If printed out they would occupy 2 A4 sized books each 3" thick ie enormously more info than in the BSS guide!!. Of course for a canal boat (RCD Category D) the requirements are more relaxed than for a Cat A ocean going yacht but you still have to read through the standards from cover to cover to find which clauses apply and which don't.

 

I chose to do it this way because I'm retired, have lots of time and perhaps perversely, rather enjoy getting stuck in to a load of technical documentation and picking bits out of it as it was more or less what I used to do at work!

 

So my answer is, of course you can do your own RCD compliance certification (which does not require any Notified Body involvement if it is for a Cat D boat). However you will have to do what I've done and somehow read all of the standards if you're going to do it properly. For the sheer hours I've spent on it it would probably have been cheaper to pay a surveyor but then, for me, that would have spoilt the fun!

 

As a half way house there are internet based firms that, for a fee, will give you access to their "RCD compliance" system of interactive check lists. I don't know the costs but perhaps another poster will join in. Biggles is a member who has done this I believe.

 

Another thing you can do is have a look at the RYA website here. Read this page I've linked to and follow ALL the links to other stuff on there. That's how I got started.

 

In summary I would say complying with the RCD is NOT just about gathering info about how your boat was built, it is about checking that all aspects of the build were compliant with the standards. Your hull builder has hopefully given you an Annex III "partly complete boat" declaration for his work on the hull showing that it complies. You have then to show that your fit out work to complete the boat is also compliant! This might not be so easy to do as a retrospective exercise! If you've kept a lot of records of what you did, maybe it won't be too bad as you can use this to make up a Technical File and produce your Owners Manual.

 

I can't think of a way to produce a "standard format for RCD compliance" when all narrowboat hulls are very different and are certainly fitted out in all manner of different ways.

 

Hope this helps a bit!

 

Richard

 

PS I'm still building my boat so I can't say I know all the answers!

Edited by rjasmith
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Thanks for the in-depth, and knowledgeable reply Richard,

 

That is the annoying part, I have kept all records, wire diagrams, water layouts, gas, central heating, etc. etc. and of course all user information for all fixtures, etc. Compiling the user manual would be the easy part for me. With user manual and Annex III under my wing what else would I be paying a marine surveyor £500-£600 for??? But, If this is what I have to do though then so be it.

 

I certainly won't be buying a new shell again, I'll refit an older one! This legislation is going to have a negative affect on hull builders, certainly one less order for next year anyway. Hey presto the government puts another nail in the coffin of British industry!

Edited by mrartisan
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I used the software from CE-Craft. This has all the relevant sections from the standards documented, and you have to state how you have achieved compliance with each. This all adds up to a 120 page document. I couldn't have done the RCD without it. I think it was about £200 IIRC.

 

It was easier doing it as the build progressed rather than going back afterwards!

 

Richard

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Thanks for the in-depth, and knowledgeable reply Richard,

 

That is the annoying part, I have kept all records, wire diagrams, water layouts, gas, central heating, etc. etc. and of course all user information for all fixtures, etc. Compiling the user manual would be the easy part for me. With user manual and Annex III under my wing what else would I be paying a marine surveyor £500-£600 for??? But, If this is what I have to do though then so be it.

 

I certainly won't be buying a new shell again, I'll refit an older one! This legislation is going to have a negative affect on hull builders, certainly one less order for next year anyway. Hey presto the government puts another nail in the coffin of British industry!

 

Very good that you have all those records but to do it right you'll need to check that the way you did everything complied with the RCD stds so I'm afraid you'll need to know what they say! Do you know that your wiring meets ISO 10133 and 13297 for example?

 

The surveyor (BTW I'm not one!) earns his corn by keeping up to date with the stds having first paid out £5k to buy a set! I haven't used a surveyor but I suppose he visits you/your boat at various stages and tells you in detail how to keep in compliance. The web based check lists presumably work in a similar way.

 

Another aspect is the boat's downflooding and stability compliance. Your hull builder has hopefully made you a hull that won't fall apart (!) but your fit out will greatly affect how the boat floats and so it's down to you to either calculate or do tests to ensure the completed job meets the Cat D criteria in these areas.

 

Of course you could just sign the Declaration of Conformity, list the relevant standards on page 2 and hope for the best! Perhaps you could also fit a Builders Plate and take a guess at the Max Crew Limit and recommended Max load figures to be shown on it.

 

You may be asked for an Owners Manual by the new owner if they are knowledgeable but that needs to be written in accordance with ISO 10240!

 

It will only be if someone you sell to is somehow aggrieved with your boat and calls in Trading Standards (and if the local TS know much about the RCD!!) that you might then be in a bit of bother!

 

Your comment about nails in the coffin etc is interesting! I always understood that the development of the RCD was particularly called for by the British boat industry (perhaps more from the salty boat firms) to help protect it from dodgy quality cheap imports from outside Europe!

 

Sorry - I don't mean to come across in a negative way for you but doing the RCD properly is quite involved for someone doing just one boat. There are about 30 separate ISO standards and I've waded through them all - and more than once as they get modified from time to time!

 

It's probably a great deal easier for a boat builder doing one boat after another once he's got his staff trained and maybe some sort of Q/A system in place!

 

Richard

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thanks again Richard,

 

interesting that the industry called for such an unregulated mess! Like you say though probably the producers of sea-going boats. I still think it will have a detrimental affect to the narrow-boat builders.

 

Anyway, think I may have found an answer http://www.small-craft-consultancy.com/CE-craftsample.pdf is just what I needed. It even quotes the applicable ISO to view for each category!

 

Cheers.

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What really p*ss*s me off about all this is the fact that the ISO standards are not in the public domain. After all they were drawn up for safety purposes. You can't even read them for free to see if you one is relevant to anything you may be doing.

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What really p*ss*s me off about all this is the fact that the ISO standards are not in the public domain. After all they were drawn up for safety purposes. You can't even read them for free to see if you one is relevant to anything you may be doing.

 

The bit in bold is the mistake. They were drawn up as a money making scam.

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This, I'm afraid, rings bells in my mind from other threads. People who start threads about problems with 'new build' boats that they've bought relatively cheaply from someone who's built one effectively as a DIY boat for themselves then sold it on.

With all due respect, I am sure you have taken great care and complied to all the requirements...hopefully anyway,...but there are quite a few people 'having a go' at boat building, 'on the side' and selling sometimes less than compliant, and in some cases severly non-compliant boats. They self certify without full understanding of the requirements they should comply to, and thus a cheaper, but often poor quality, occassionally dangerous boat is born.

Now please don't get me wrong, I have no reason to assume you are one of these people, but they are out there doing it, as has been noted in threads on here. People get upset about the boat they just bought and then de-cry all boat builders not always understanding the difference.

Having said that, I have also seen some superb builds done in such a way, and all power to those people...I will best assume you are one of those.

But please, do yourself and the buyer a favour and understand that the RCD is NOT fulfilled by the hull builder, that is just a part of it. Get help in whichever way you chose to FULLY understand how you need to comply for this and any other boats, and know in your mind then that you are sending out a safe boat.

(Not all 'professionals' even do this, as we all know.....don't join those ranks!)

Again, good luck with completion, hope it all goes well.

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Thinking on from what Ally said, the problem you will have will not be in creating the paperwork to your satisfaction, it will be in creating it to the satisfaction of a purchaser's surveyor. There have been people here who have walked away from buying nice boats with insufficient RCD paperwork on their surveyors recommendation

 

Richard

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I currently have for sale my recently completed narrowboat:-

 

http://web.me.com/jpye/narrowboat

 

However, due to the 'Recreational Craft Directive' imposed on boats under five years old, it seems I have to get my documentation more in order. After internet searches, it seems that the RCD is just that, more a compilation of information and not a test-to-pass as I originally thought.

There seems to be much scare-mongering and idle gossip all over the internet concerning the RCD, (as I'm sure there is about all topics). However, something remains unclear about the RCD process:-

 

If the RCD is, as I think I have gleaned, 'a compilation of information' ie: Materials, Processes, Standards, Conformity , etc. then why does the process of achieving RCD compliance seem to be kept out of reach of the sail-away self-builder. After-all, the complicated side of the RCD compliance would have been satisfied by the hull builder (or at least should of been).

So, would it not be better to create a standard format for completing the RCD compliance for the sail-away self-builder, and not make him reliant on a Marine Surveyor to compile the information for him? I think autobiographies are always more exacting than Biographies!

 

Anyway, as I have only just started researching this subject, and need RCD compliance rather sharpish, I though I would post this message to the wealth of knowledge that abounds in the Canalworld forums, any information on this subject would be greatly appreciated, preferably from those of you who have navigated the murky bog of the RCD.

 

Thanks for reading,

 

John.

It is probably worth getting a surveyor who is well versed in the RCD and the ISOs involved for all the installations. Not all surveyors are particularly up to to speed with the RCD, it must be said.

 

The RCD is not simply a "compilation of information". Your various installations such as gas, low voltage and mains voltage must comply with the relevant ISOs, and they are pretty strict. Every appliance must be installed in accordance with the manufacturer's instructions otherwise their CE mark is negated. For example, I once had a big problem in brokering a boat where the surveyor insisted that the gas oven unit had to be installed with rigid pipework rather than the normal flexible connection. His reasoning was that the manufacturer's manual stated that only rigid pipework connections were to be used. And if you get a very exacting surveyor who interprets everything to the letter, they should point out that any washing machine installed does not comply, as all washing machine manufacturers state that they cannot recommend the installation of their product on a boat! Crazy, but true.

 

Is the RCD just a money making scheme? With Cat. D boats such as narrowboats the fact that it is a process of self assessment makes it pretty much a nonsense. With Cat C (over 12 metres) and Cats. A & B it is different. Before the scheme came in in June 1998 some cheaper yachts were produced which were not truly seaworthy, and by one or two fairly well known manufacturers at that. The RCD put a stop to that, as all these vessels must be independently assessed.

 

Either Cat. D boats should be independently assessed, which wouldn't be a bad thing not least for consumer confidence, or they should be outside the scheme altogether. The current arrangement whereby the boat builder can declare his or her own work to be compliant simply by signing a bit of paper is a farce.

Edited by Dominic M
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If a person buys a sailaway, fixes it up, sells it to his brother, who sells it to his other brother....is it then seen as a pre-owned boat...or does it apply to anyone buying a boat less than 5 yrs old. For example I bought a pre-owned boat...I was told it was built in a certain year, but I have no real proof...

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If a person buys a sailaway, fixes it up, sells it to his brother, who sells it to his other brother....is it then seen as a pre-owned boat...or does it apply to anyone buying a boat less than 5 yrs old. For example I bought a pre-owned boat...I was told it was built in a certain year, but I have no real proof...

 

Without any doubt, your example describes a pre owned boat! I suppose it could give the lawyers a field day to determine whether the selling within the family constituted "placing it on the market within the EU". But if they thought it did then strictly speaking the law has been broken.

 

As to who might enforce the law? One of the brothers would have to become upset with his purchase and call in his local Trading Standards. Trading Standards are a department within each County Council and so their knowledge of the RCD must vary up and down UK. Allegedly Hampshire has the best RCD aware TS Dept.

 

TS would investigate the brother's grievance with the boat and decide whether or not to prosecute the boat builder. The boat builder IS the person who completed the sailaway and made the first sale NOT the sailaway builder who only sold a "part complete boat".

 

As to determining the age of the boat - the key date is 16 June 1998 when the RCD came into effect. The sailaway builder should have issued an Annex III declaration to the first brother who bought it. The sailaway builder should have kept copies for ten years so even if the brother has lost his copy the build date could be traced by TS I suppose.

 

 

All this is a bit far fetched to actually happen but it isn't impossible!!

 

Richard

Edited by rjasmith
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It is probably worth getting a surveyor who is well versed in the RCD and the ISOs involved for all the installations. Not all surveyors are particularly up to to speed with the RCD, it must be said.

 

The RCD is not simply a "compilation of information". Your various installations such as gas, low voltage and mains voltage must comply with the relevant ISOs, and they are pretty strict. Every appliance must be installed in accordance with the manufacturer's instructions otherwise their CE mark is negated. For example, I once had a big problem in brokering a boat where the surveyor insisted that the gas oven unit had to be installed with rigid pipework rather than the normal flexible connection. His reasoning was that the manufacturer's manual stated that only rigid pipework connections were to be used. And if you get a very exacting surveyor who interprets everything to the letter, they should point out that any washing machine installed does not comply, as all washing machine manufacturers state that they cannot recommend the installation of their product on a boat! Crazy, but true.

 

Is the RCD just a money making scheme? With Cat. D boats such as narrowboats the fact that it is a process of self assessment makes it pretty much a nonsense. With Cat C (over 12 metres) and Cats. A & B it is different. Before the scheme came in in June 1998 some cheaper yachts were produced which were not truly seaworthy, and by one or two fairly well known manufacturers at that. The RCD put a stop to that, as all these vessels must be independently assessed.

 

Either Cat. D boats should be independently assessed, which wouldn't be a bad thing not least for consumer confidence, or they should be outside the scheme altogether. The current arrangement whereby the boat builder can declare his or her own work to be compliant simply by signing a bit of paper is a farce.

I couldn't agree more with this....(the bold section)...and that is why we, and a few other builders, use an independant surveyor instead of doing our own sign off. There is talk of the CBA bringing this in to an extent, for it's members....roll on that day! Otherwise, it's a bit comparable to doing your own MOT!

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I agree that cat D boats should be inspected by an appointed person for the task, just as sea going vessels are. But, seeing that they are not then the RCD for cat D is just "a compilation of information'.

 

Yes the certain aspects of the relavent ISOs have to be satisfied but lets face it, it is just common sense. ISOs are long winded documents that cover every eventuality, hardly any of which applies.

 

If a boat has been fitted competently by the owner (as has my own) then that is plain to see, and that is where a marine surveyor should come into play, anybody that is thinking of buying a boat would be mad not to have it surveyed first, regardless of weather its RCDs and BSSs.

 

The RCD is not there to protect the purchaser, it is there to constrain the self-builder. I can't sell my boat (legally) without an RCD as its only three and a half years old and I fitted it out myself. But in eighteen months time I can sell it without one!

 

It's all about money! and It's all a load of bollocks if you ask me!!

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BSI are an influential body whose business is to make money, they are also absolutely necessary especially in engineering and without them we would end up with a hotch potch of crap all deemed by individuals to be of a good or acceptable 'standard' Standards be them BS, En etc have proved to be necessary unfortunately.

 

We've just spent in excess of £10k for a set of engineering standards, so I do feel for your predicament however, I've found that this mantra keeps me sane:

 

God, grant me the serenity to accept the things I cannot change,

Courage to change the things I can,

And wisdom to know the difference.

Edited by chieftiff
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As someone has said RCD constrains the self builder but it doesn't constrain 'professional' canal boat builders of the cowboy ilk who don't give a toss, why should they, it's a so called self declaration of proper 'build quality'.

 

All it does is give the cowboy builder carte blanche to do as he wants.

 

Why shouldn't builders be required to provide a BSSC

Edited by nb Innisfree
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