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The Recreational Craft Directive (RCD)


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Just been reading this directive, and trying to help a friend who is exporting a boat overseas.

I understand that new boats that are sold onto the market need to meet these regulations,and think

that narrow boats are not exempt.

 

How do builders get round the requirement to provide the following: All craft must allow re-boarding from the water.

Just interested as it has bee talked about many times on here.

 

Mark

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I'm not sure if you/friend realise this already but the RCD document itself doesn't give much practical detail as it is really just an Act of the EU Parliament turned into an EU Directive. It concentrates on the more legal aspects of compliance and only lists safety requirements as "headings" in "Annex 1 - Essential Requirements".

 

If you want the full works practical stuff you need to access a whole lot (about 30) International Standards (ISOs). To get your own copies costs money unfortunately but there are ways to read them for free and online. The RCD itself does not list the related ISO numbers unfortunately but there are websites that do. The RYA used to but I'm not sure they still do. (They gave up being an RCD Notified Body some years ago).

 

Try Manchester City Library website here and use their link to go to the BSOL website where you can look up the ISOs. MCL pay the BSOL licence fee and any UK resident can join MCL who are very splendid people to allow this!!! Most local libraries have stopped because it's too expensive!

 

You need ISO 15085 for stuff about "Means of Reboarding".

 

It took me a very long time to get my head around all aspects of the RCD - Good Luck if that's what you're now trying to do!

 

Another thing - do you know that on 18 January 2017 the two old (linked) versions of the RCD will die and be replaced by the new version approved in January 2014?

 

It's not very significantly different unless you're planning on fitting any non compliant vintage engines in a new boat!

 

There are other ways to get help on RCD stuff - pay a suitable surveyor or try one of the companies that supply compliance software tools (eg CE Craft) for a bit less money.

 

Richard

Edited by rjasmith
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You are correct that narrowboats must comply with the directive if put on the market within the defined territories - basically the EU.

 

However I think you may find that some UK narrowboat builders take a fairly relaxed and flexible interpretation of the regs.

As to getting back on board an additional step as mentioned above, or a short length of ladder hanging over the side may be acceptable if fixed and safe to use.

Best read the regs and see what they say.

Edited by Chewbacka
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It took me a very long time to get my head around all aspects of the RCD - Good Luck if that's what you're now trying to do!

 

 

 

I would imagine that trying to do it retrospectively to a boat already 'in existence' would be even more of a nightmare - who will certify the Hull and any fitting / internal work ?

Whose responsibility is 'signing off' the wiring, plumbing, gas, buoyancy calculations, weight carrying / No of person rating and so on.

 

Just thoughts but :

Why would you be exporting a NB ?

Where else in the world has similar narrow, muddy ditches ?

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Just been reading this directive, and trying to help a friend who is exporting a boat overseas.

I understand that new boats that are sold onto the market need to meet these regulations,and think

that narrow boats are not exempt.

 

 

If it is being exported are rcd requirements relevant? (I suspect it is where it is being exported to that matters. but do not know)

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................................ The RCD itself does not list the related ISO numbers unfortunately but there are websites that do. The RYA used to but I'm not sure they still do. (They gave up being an RCD Notified Body some years ago).

 

Try Manchester City Library website here and use their link to go to the BSOL website where you can look up the ISOs. MCL pay the BSOL licence fee and any UK resident can join MCL who are very splendid people to allow this!!! Most local libraries have stopped because it's too expensive!

 

You need ISO 15085 for stuff about "Means of Reboarding".

 

.................................

This site list the harmonised standards that are applicable, and there are a lot, though the applicability to specific craft does depend upon the class of craft (ocean, canal etc) and size.

https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/recreational-craft_en

 

If it is an existing craft then it should be CE marked and the documentation supplied with the craft should tell you which standards and version of the standards were applicable at the time it was certified.

 

There is a clause that does allow a non CE marked vessel that was a self build to be sold on when the craft is over 5 years old without CE marking. Not sure if a mainland Europe country will agree..........................

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I would imagine that trying to do it retrospectively to a boat already 'in existence' would be even more of a nightmare - who will certify the Hull and any fitting / internal work ?

Whose responsibility is 'signing off' the wiring, plumbing, gas, buoyancy calculations, weight carrying / No of person rating and so on.

 

Just thoughts but :

Why would you be exporting a NB ?

Where else in the world has similar narrow, muddy ditches ?

agree.

 

not just a nightmare - impossible, I would suggest, unless you pay a surveyor thousands to check compliance and then more thousands to do all the work (or replacements) to comply. for example, if no Annex 3 exists it will require a lot of checks and even testing of materials and workmanship to provide the same information retrospectively regarding the shell construction.

 

when the OP says 'export' does he imply selling it overseas? If not, and he is exporting it for his own use, I am not sure that he needs an RCD, but of course the wonderfully bureaucratic French authorities (for example) may not agree.

 

to answer OP's specific query - yes, a step built in to extend the swimplate where it projects at the transom.

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I would imagine that trying to do it retrospectively to a boat already 'in existence' would be even more of a nightmare - who will certify the Hull and any fitting / internal work ?

Whose responsibility is 'signing off' the wiring, plumbing, gas, buoyancy calculations, weight carrying / No of person rating and so on.

 

Just thoughts but :

Why would you be exporting a NB ?

Where else in the world has similar narrow, muddy ditches ?

No need. Compliance is only required when a boat is first placed on the EU market (except for self built boats more than five years old). So legally you don't need to do anything. But a buyer may want evidence that the boat did comply when first put on the EU market.

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Thank's for the replies everyone, Just to confirm the boat is not a narrow boat but it is built in Poland which is within the EU

I understand that some narrow boats are manufactured in Poland and shipped to the UK. The boat complies to all the EU regulations

 

Importing a boat to a banana republic within the commonwealth is far easier if you have proof of construction and it's legal

status, so it is much easier to get the craft registered with this documentation.

 

We have no problems with the boat as it has all the documentation and has been constructed to the requirements which includes

access from the water. the question was how do narrow boat builder get round this,As Alan said you weld a plate onto the hull to give you

access from the water but have all new boats got this ?

 

Mark

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Thank's for the replies everyone, Just to confirm the boat is not a narrow boat but it is built in Poland which is within the EU

I understand that some narrow boats are manufactured in Poland and shipped to the UK. The boat complies to all the EU regulations

 

Importing a boat to a banana republic within the commonwealth is far easier if you have proof of construction and it's legal

status, so it is much easier to get the craft registered with this documentation.

 

We have no problems with the boat as it has all the documentation and has been constructed to the requirements which includes

access from the water. the question was how do narrow boat builder get round this,As Alan said you weld a plate onto the hull to give you

access from the water but have all new boats got this ?

 

Mark

They vary, some put a bit of step on the edge of the base plate at the stern where its about an inch below the water level, some on the side of the rudder, other cut a food hole in the hull that also acts as the front well drain.

Edit to add

Remember its self certification, no one is going to check.

Edited by ditchcrawler
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As an aside, when we leave the EU we'll be released from building to the RCD and will go back to being able to build ourselves death traps in the Great British way, right?

 

(Well it was a nice dream I was having...)

Yes, a nice dream.

 

Perhaps we should explain why it's a dream. All EU regulations (not just boats, but electrics, houses, cars, everything) that have been put into British Law will remain there until Parlement takes each one of them out - which won't happen to many of them. Also, in order to trade with the EU and in order to take your boat on European canals, or sell it into the EU it will be best if it meets their regs. AND guess what - we will have no way of changing any of these regulations we don't like - because we will no longer be part of the committee's that change them.

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Yes, a nice dream.

 

Perhaps we should explain why it's a dream. All EU regulations (not just boats, but electrics, houses, cars, everything) that have been put into British Law will remain there until Parlement takes each one of them out - which won't happen to many of them. Also, in order to trade with the EU and in order to take your boat on European canals, or sell it into the EU it will be best if it meets their regs. AND guess what - we will have no way of changing any of these regulations we don't like - because we will no longer be part of the committee's that change them.

 

I think that this post is extremely misleading, and typical of the 'frighteners' used by both sides in the Brexit argument.

 

1) I would suggest that boats conducting trade with the EU will not be subject to the RCD anyway.

2) Your boat does not need an RCD to be USED in European waters ( otherwise a lot of visiting boats from outside the EU would be disallowed)

3) You can sell a boat without an RCD 5 years after it was built / first used / first put on the market.

 

In fact the only part that you are probably correct about is the fact that we will be unlikely to change any of the existing legislation enshrined in UK law.

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to return to the original question.

 

Our boat had the scuppers for the foredeck made big enough to get a foot into it.

 

We had a boat like that - have you tried getting your foot 6" above the waterline and then lifting yourself into the boat - I couldn't manage it.

 

If that is your only method of re-entry I would really suggest you try it (fully clothed) one day.

 

As I see it the 'best method' is to have an emergency ladder (commonly used on lumpy water boats), it is kept in a 'tube' attached to 'somewhere' on the boat, you pull the lanyard and the weighted ladder comes out and drops down to give 2 or 3 feet below the water line, if you are capable of climbing a ladder, you can get back on board.

 

Just a couple of examples (£30) many others are available.

 

0000026848.jpg

 

plastimo-flushmount-safety-ladder-z-599-

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We had a boat like that - have you tried getting your foot 6" above the waterline and then lifting yourself into the boat - I couldn't manage it.

 

If that is your only method of re-entry I would really suggest you try it (fully clothed) one day.

 

As I see it the 'best method' is to have an emergency ladder (commonly used on lumpy water boats), it is kept in a 'tube' attached to 'somewhere' on the boat, you pull the lanyard and the weighted ladder comes out and drops down to give 2 or 3 feet below the water line, if you are capable of climbing a ladder, you can get back on board.

 

Just a couple of examples (£30) many others are available.

 

0000026848.jpg

 

plastimo-flushmount-safety-ladder-z-599-

The boarding ladder on ours is a stainless steel ladder which folds out from the transom. It folds down with three rungs in the water but even still it is difficult to use and haul oneself out of the water. We have taken to using the stern drive as an additional step up which works much better.

 

I would also suggest to those who think that their well drains on their narrowboats will act as a step up that they give it a try. I doubt many people will actually be able to get their legs high enough to use them.

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to return to the original question.

 

Our boat had the scuppers for the foredeck made big enough to get a foot into it.

Thanks to all who have replied for clearing this up, so they have made allowance for this requirement. I would say

it's a bit basic, and would have liked to see a better effort than what they have done like a small flip down ladder

Has any of you tried to get back onto a boat when you have fallen in cold water in the dark it is not easy !! just thinking

do hire boats tell you how you should go about this when you pick the boat up.

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We had a boat like that - have you tried getting your foot 6" above the waterline and then lifting yourself into the boat - I couldn't manage it.

 

If that is your only method of re-entry I would really suggest you try it (fully clothed) one day.

 

As I see it the 'best method' is to have an emergency ladder (commonly used on lumpy water boats), it is kept in a 'tube' attached to 'somewhere' on the boat, you pull the lanyard and the weighted ladder comes out and drops down to give 2 or 3 feet below the water line, if you are capable of climbing a ladder, you can get back on board.

 

Just a couple of examples (£30) many others are available.

 

0000026848.jpg

 

plastimo-flushmount-safety-ladder-z-599-

Well said Alan I totally agree,it is not just welding a few bits on to get around the requirement it should be a basic safety requirement.

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We had a boat like that - have you tried getting your foot 6" above the waterline and then lifting yourself into the boat - I couldn't manage it.

 

If that is your only method of re-entry I would really suggest you try it (fully clothed) one day.

 

As I see it the 'best method' is to have an emergency ladder (commonly used on lumpy water boats), it is kept in a 'tube' attached to 'somewhere' on the boat, you pull the lanyard and the weighted ladder comes out and drops down to give 2 or 3 feet below the water line, if you are capable of climbing a ladder, you can get back on board.

 

Just a couple of examples (£30) many others are available.

 

0000026848.jpg

 

plastimo-flushmount-safety-ladder-z-599-

 

Alan can you please point me to the £30 for Lalizas "Safe Up" MOB 5-Step Safety Ladder I can not get below £50 ish

Thanks Ray

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