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RCD Compliance


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Ladies and Gents,

I'm aware this topic has been discussed before but I have yet to find what I would call a conclusion or convincing argument either way.

As part of my self-fit-out, I have been pointed in the direction of a marine surveyor who can offer me:

inspection for Essential Requirements (ER's) and Boat Safety Scheme (BSS) standards. Supply Declaration of Conformity. Advise on Craft Identification Number (CIN) compilation and location. Advised marking for CE plate, Fitout consultation and conformity assessment, Compilation of Boat Manual (OM), Compilation of Technical Construction File (TCF).

Which will take two visits to the boat. I imagine a bit of back/forth via phone and email too.

The price is a cool £1,500 :o.

The obvious pros are that you can sell the boat within 5 years (if need be) and you should achieve a high level of safety stanards. The con being the cost.

Is there a cheaper way? Is it necessary at all? Has anyone used someone like this?

Edited by Mohsen
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The way I see it is that you could make a simple inexpensive mistake or omission that could either necessitate major strip back to rectify or even be impossible to rectify. As soon as I tried to decipher the various ISOs I realised that absorbing all that information would take literally months of full-time study. On the thread I started a few days ago, someone mentioned that he was able to negotiate substantial discounts of many thousands of pounds on boats without RCD compliance (link) so if there's a chance of you might sell, it certainly makes sense.

I've instructed a surveyor who's providing a 'distance' service with a single visit. It means I'm taking on responsibility for quite a lot of it myself with guidance via phone and email. This was as much as he could offer because of his commitments over the summer. It's unlikely that the size of the craft affects the cost of the surveyor so £1500 will be a lot more of a hit on a 30' narrowboat with £10k spent on it than a 70' widebeam with £70k spent. I'm somewhere in the middle; certainly on size and hopefully on fit-out costs.

One thing I'm particularly adept at is scratching my head, procrastinating over the right way to do something. Having someone who can tell me that something is definitely wrong or definitely right is going to cut my build time down by at least 50%. As my shell has gets closer to completion, the stress (mixed with excitement) has been increasing. Finding a surveyor who can handle the paperwork side of things was a mighty relief. So a big thank you to mrsmelly for pointing me in that direction.

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Thanks Stegra, I appreciate your considered response and sharing your experience. You make a lot of valid points.

If you dont mind me asking, are you paying a similar price for a similar service as I have outlined or is yours significantly different?

  • Greenie 1
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I'd be wary of anyone proposing to simply inspect the boat a couple of times and write up the paperwork. What the paperwork is supposed to show is how the fitout has been designed and built according to the standards. Without becoming familiar with the standards yourself, how can you do the job right in the first place?

 

Edited by Giant
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1 minute ago, Murflynn said:

the price appears to limited to inspecting and documenting a compliant boat.

how do you propose to ensure compliance? - 2 visits by a surveyor won't prevent you from failing to know, understand and comply with the standards.

I'm under the impression he provides an amount of guidance in areas of common mistakes and will correct me if I make any mistakes that he can see. Though I have not discussed the process with him indepth yet.

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13 minutes ago, Murflynn said:

the price appears to limited to inspecting and documenting a compliant boat.

how do you propose to ensure compliance? - 2 visits by a surveyor won't prevent you from failing to know, understand and comply with the standards.

I think this phrase: Fitout consultation and conformity assessment, might have been better with a comma in place of the 'and'. So the fit-out consultation is the means of ensuring compliance. Can't really see that a 'fitout consultation assessment' would make sense. Perhaps a case for the Oxford comma.

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25 minutes ago, stegra said:

I think this phrase: Fitout consultation and conformity assessment, might have been better with a comma in place of the 'and'. So the fit-out consultation is the means of ensuring compliance. Can't really see that a 'fitout consultation assessment' would make sense. Perhaps a case for the Oxford comma.

It was explained to me by a university lecturer during a chat in a pub that if you're writing a list of items and they are all to have equal prominence, the comma before the and is essential. Without the comma you are either giving extra emphasis to the final item in the list or, as above, introducing ambiguity.  

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37 minutes ago, Giant said:

I'd be wary of anyone proposing to simply inspect the boat a couple of times and write up the paperwork. What the paperwork is supposed to show is how the fitout has been designed and built according to the standards. Without becoming familiar with the standards yourself, how can you do the job right in the first place?

 

Firstly I am not an expert and its been a few years since I started down the RCD route. As I understand it you need a certificate that says that the shell complies, that's from the builder and even if it doesn't comply he will say it does. It doesn't matter though because it will be a perfectly ok shell as the RCD is so vague that it is frankly irrelevant. In Giants last sentence he mentions 'becoming familiar with the standards'. If only you could that. When I built our boat it would have cost a huge sum of money to buy the standards. Thing is that the RCD is not like the boat safety thingy in that it doesn't tell you much about how to build anything.  A narrowboat is not required to be inspected so the RCD is really just to show that manufacturing standards have been met. I gave up with the whole thing, built it to the BSS and self certified the boat. If anybody has more recent experience I would be interested to know as it was mostly bollocks.

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9 minutes ago, WotEver said:

It was explained to me by a university lecturer during a chat in a pub that if you're writing a list of items and they are all to have equal prominence, the comma before the and is essential. Without the comma you are either giving extra emphasis to the final item in the list or, as above, introducing ambiguity.  

HaHa. Yes, I'd like to thank my parents, Mother Teresa and the Pope. :o

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1 hour ago, Bee said:

Firstly I am not an expert and its been a few years since I started down the RCD route. As I understand it you need a certificate that says that the shell complies, that's from the builder and even if it doesn't comply he will say it does. It doesn't matter though because it will be a perfectly ok shell as the RCD is so vague that it is frankly irrelevant. In Giants last sentence he mentions 'becoming familiar with the standards'. If only you could that. When I built our boat it would have cost a huge sum of money to buy the standards. Thing is that the RCD is not like the boat safety thingy in that it doesn't tell you much about how to build anything.  A narrowboat is not required to be inspected so the RCD is really just to show that manufacturing standards have been met. I gave up with the whole thing, built it to the BSS and self certified the boat. If anybody has more recent experience I would be interested to know as it was mostly bollocks.

self-certified what?  the RCD? in which case your RCD is falsified.  why publicise that on a forum?

anyone with any experience of writing technical documents and having access to the standards at the local library (the meat of which is not very voluminous in most case and can be written down as a series of bullet points of the relevant bits) can ensure he knows the requirements, is able to comply, and can document it accordingly. 

regarding Annexe 3 the requirements for design and scantlings (for example) are specific, I don't understand how you can claim otherwise.

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It would be of interest-certainly to me - to have a list of the common mistakes made by D.I.Y. fitters in their attempts to cut costs by fitting out a sailaway or "restoring" a narrowboat which breached RCD rules. Is it possible as a point of reference or am I asking too much?

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29 minutes ago, Murflynn said:

self-certified what?  the RCD? in which case your RCD is falsified.  why publicise that on a forum?

anyone with any experience of writing technical documents and having access to the standards at the local library (the meat of which is not very voluminous in most case and can be written down as a series of bullet points of the relevant bits) can ensure he knows the requirements, is able to comply, and can document it accordingly. 

regarding Annexe 3 the requirements for design and scantlings (for example) are specific, I don't understand how you can claim otherwise.

I'm not sure too many folk have experience writing technical documents, but that aside, the first ISO I tried to study was only limited in 'voluminosity' by the inclusion of references to a dozen or more different ISOs. I've no doubt that those who are accustomed to deciphering technical documentation will be comfortable but those of a more craft-based background are likely to be overwhelmed. There's a thread running now where a boat has twin and earth domestic wiring. I don't know whether that is permissible or not but it certainly isn't best practise. A mistake like that could costs thousands to rectify, and be thoroughly demoralising; but so easily done.

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10 hours ago, jddevel said:

It would be of interest-certainly to me - to have a list of the common mistakes made by D.I.Y. fitters in their attempts to cut costs by fitting out a sailaway or "restoring" a narrowboat which breached RCD rules. Is it possible as a point of reference or am I asking too much?

there are no short cuts.

the only useful guide would be to obtain a copy of an RCD technical file for a compliant and certified boat.  Unfortunately these remain the property of the builder, and are not usually made available to a purchaser, so it is unlikely you could obtain one except from a close friend. However, the file only explains in general terms how compliance has been achieved.

As I said, get thee to your local library (business section) and get on line to read the ISOs, including those that are cross referenced.  If you find the will to do it it is not a lot worse than reading an IKEA instruction sheet, just needs more cross checking.

 

Edited by Murflynn
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12 hours ago, Bee said:

 I gave up with the whole thing, built it to the BSS and self certified the boat.

So, if one was to see an advert for a boat called 'Bee'

Maybe, for example, one such as this :

Bee Built by Unknown - Length : 17.37 metres ( 57 feet ) - Beam : 1.97 metres ( 6 feet 6 inches ) - Draft : 0.01 metres ( 0 feet ). Metal hull N/A power of 999 HP. Registered with Canal & River Trust number 48431 as a Powered Motor Boat.  ( Last updated on Wednesday 22nd May 2013 )

 

One should quickly walk away knowing that it was not built in accordance with the documentation that certifies it.

If you can be so dishonest about that, what else is 'hiding in the woodwork' ?

 

Why did you just not 'bother' with the declaration and not claim it was built to he RCD - at least you would not be committing fraud.

 

You do no favours to self fit-out fraternity.

 

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As I recall for a boat that is not going offshore it is (was ?) perfectly ok to self certify the vessel. It was all but impossible to obtain the standards anyway - that may have changed but it was a closed shop where the holders could charge huge sums to write a technical file. The only standards that I bought were the electrical ones. It nearly all related to saying that the boat was built in accordance to manufacturing processes - virtually nothing about whether it was safe or not. The bit about your new shell not being compliant was that the manufacturer is supposed to test for all sorts of stability theories and stuff, I doubt if a narrowboat would ever comply and a cruises stern would have to be tested differently than a trad and a tug might fail completely and tugs could be banned. Anyway, there is no checking ever done because all builders self certify including amateurs, it is all about writing a technical file and manual. So not fraud, just common sense.

Edited by Bee
missed a bit.
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4 hours ago, Bee said:

As I recall for a boat that is not going offshore it is (was ?) perfectly ok to self certify the vessel. It was all but impossible to obtain the standards anyway - that may have changed but it was a closed shop where the holders could charge huge sums to write a technical file. The only standards that I bought were the electrical ones. It nearly all related to saying that the boat was built in accordance to manufacturing processes - virtually nothing about whether it was safe or not. The bit about your new shell not being compliant was that the manufacturer is supposed to test for all sorts of stability theories and stuff, I doubt if a narrowboat would ever comply and a cruises stern would have to be tested differently than a trad and a tug might fail completely and tugs could be banned. Anyway, there is no checking ever done because all builders self certify including amateurs, it is all about writing a technical file and manual. So not fraud, just common sense.

What a load of b*ll*x.  

Are you saying that it is OK to state the boat was built in accordance with the standards even though you don't know the content of those standards?  Many of the standards are about safety - electrics, lpg, flame resistance & fireproofness, fuel systems, downflooding, etc. 

For your information, testing a bare shell for stability is meaningless and I am not aware that it is part of Annexe 3.  in my case the stability testing was undertaken on the completed and ballasted boat.

As I said - all the standards are in the public domain - but they are protected by copyright.  I can't beleive that any sensible person wouldn't bother to get his backside down to the local library and note down the requirements.  I visited Bristol Central Library 5 times to read, check and cross refer as necessary.  If I could do it, why can't you?

To avoid any confusion - you should build/fit-out the boat according to the standards and the document it accordingly, not just do it any old way and then play catch up by producing a declaration of conformity.

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5 hours ago, Bee said:

The bit about your new shell not being compliant was that the manufacturer is supposed to test for all sorts of stability theories and stuff

No they are not

It is one of the final test for the completed boat - If an empty shell was used, and then fitted out with a tonne of pump-out tank, a kitchen and bathroom,  7 adults and a dog all on one side of the boat, would you be surprised it the angle of heel was different ?

 

You show you ignorance of boat building in a multitude of ways -

I hope never to pass near your boat - who who knows when it will burst into flames

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8 hours ago, Alan de Enfield said:

So, if one was to see an advert for a boat called 'Bee'

Maybe, for example, one such as this :

Bee Built by Unknown - Length : 17.37 metres ( 57 feet ) - Beam : 1.97 metres ( 6 feet 6 inches ) - Draft : 0.01 metres ( 0 feet ). Metal hull N/A power of 999 HP. Registered with Canal & River Trust number 48431 as a Powered Motor Boat.  ( Last updated on Wednesday 22nd May 2013 )

.

 

With that number Bee was built in the 80's therefore pre RCD.

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1 hour ago, Detling said:

With that number Bee was built in the 80's therefore pre RCD.

Different Bee, our boat lives in France and is a newbuild Dutch tug. As I said, I am not an expert on the RCD and I stand to be corrected on all sorts of details. Annexe 3 is a declaration by the builder that the boat is for 'completion by others' - that exonerates the builder from any responsibility and he can build it to any standard he wants, it can roll over and its your fault. What I am saying is that the RCD has very little about how to build the thing. It is not a manual. the Boat safety scheme is far more relevant and if a boat is built to those requirements it should be safe. Bristol library might have had the standards available, I worked for Shropshire libraries for 25 years and we couldn't afford to get them. Our boat was built to the standards of years of experience and the boat safety standards and has a technical file compiled by me. I self certified the whole thing and the boat has been on the Severn, Thames, Seine, Yonne, Lek, Sambre, Marne, Saone, Somme, Rhone and the Waal, half a dozen tidal waters and a stack of others that I cannot remember offhand plus a heap of commercial canals where it matters very much what you do and not just  if you hang a rope over the tiller pin. I still stand by what I have said about the RCD and basically it adds sod all to safety and very, very, little, if anything, to building standards. If someone wants to spend £1,500 on a technical file that's up to them but I think its a waste of money and if they think the boat is safer because its got a certificate of some sort then they are mistaken.

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13 hours ago, Bee said:

Different Bee, our boat lives in France and is a newbuild Dutch tug. As I said, I am not an expert on the RCD and I stand to be corrected on all sorts of details. Annexe 3 is a declaration by the builder that the boat is for 'completion by others' - that exonerates the builder from any responsibility and he can build it to any standard he wants, it can roll over and its your fault. What I am saying is that the RCD has very little about how to build the thing. It is not a manual. the Boat safety scheme is far more relevant and if a boat is built to those requirements it should be safe. Bristol library might have had the standards available, I worked for Shropshire libraries for 25 years and we couldn't afford to get them. Our boat was built to the standards of years of experience and the boat safety standards and has a technical file compiled by me. I self certified the whole thing and the boat has been on the Severn, Thames, Seine, Yonne, Lek, Sambre, Marne, Saone, Somme, Rhone and the Waal, half a dozen tidal waters and a stack of others that I cannot remember offhand plus a heap of commercial canals where it matters very much what you do and not just  if you hang a rope over the tiller pin. I still stand by what I have said about the RCD and basically it adds sod all to safety and very, very, little, if anything, to building standards. If someone wants to spend £1,500 on a technical file that's up to them but I think its a waste of money and if they think the boat is safer because its got a certificate of some sort then they are mistaken.

You haven't denied that your 'self certification' was an RCD Declaration of Conformity.  Nobody has said that the DoC is essential to safety, as you seem to be suggesting, but it is required if you put the boat up for sale within 5 years. .  Let us repeat - Falsifying a DoC for the RCD is FRAUD.

What you are saying is a load of hot air.  The RCD requires compliance to standards which are VERY MUCH about 'how to build the thing'.  You obviously haven't read the relevant ones.  What on earth do you mean by 'the standards of years of experience and the boat safety standards'?  If you mean you built the boat to BSS requirements then that is very superficial.  Nobody is saying that your boat isn't safe, but your means of documenting it are meaningless.

My RCD compliance cost me the price of registering a Craft identification Number with the RYA, the cost of a Builder's Plate, and the cost of petrol & parking to access the library.  You have stated that you have compiled a technical file, so you have admitted that you can do it yourself, and would not need to spend £1500.  To suggest that a public library in the UK (before the recent budget cutbacks) could not access British (and the corresponding international) Standards, for example through the computer system currently used for all such documents, is highly suspect IMHO.  

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If I've remembered correctly, one simple difference between RCD and BSS is that the RCD specifies tinned copper cables for all wiring in the engine compartment. So if tinned copper cable hasn't been used then the boat does not conform. And ferrules must be used where stranded cable is secured by a screw terminal such as on a 13A socket outlet. Once again, a single missing ferrule means that the boat does not conform. 

I'm sure there will be hundreds of little items such as that. 

So to say that the RCD "has very little about how to build the thing" is total nonsense. 

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