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BSS part way through refit


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I am currently working on a boat from 1987 that is in the process of undergoing a major refurbishment, not in use, but is still in the water and the BSS expires in May. Whilst the engine systems and fire safety are compliant it is unlikely that the gas and electrical systems will be completed and all appliances have been removed. For example rewired only to the fuse box but not throughout the accommodation which is largely empty and whilst there is a gas locker no bottles or pipework is going to be in place at this renewal date or any appliances or heating installed. How will this effect the issueing of a certificate?

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18 minutes ago, Mike Adams said:

I am currently working on a boat from 1987 that is in the process of undergoing a major refurbishment, not in use, but is still in the water and the BSS expires in May. Whilst the engine systems and fire safety are compliant it is unlikely that the gas and electrical systems will be completed and all appliances have been removed. For example rewired only to the fuse box but not throughout the accommodation which is largely empty and whilst there is a gas locker no bottles or pipework is going to be in place at this renewal date or any appliances or heating installed. How will this effect the issueing of a certificate?

Speak to your chosen examiner and get his opinions.

Whilst the BSS examinations SHOULD be undertaken to a common standard, unfortunately in reality they are not. One examiner may insist that all wiring and gas piping is removed, whilst another may just want it 'capped off' / terminated to his acceptable method.

Just remember that the instant you add an appliance (ie gas cooker) your new BSSC may become invalid and you will require a new examination. It may be more effective to get the boat lifted out onto the hard and save numerous examinations.

 

See attached document :

. If, for example, the boat has had an engine change, major electrical re-work, a galley re-fit or any of its LPG appliances changed/upgraded since its last examination, the certificate may not be valid if the work was carried out in a non-BSS compliant manner (which could also have insurance implications).

 

BSS Invalidated.doc

Edited by Alan de Enfield
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I have quite a lot of experience of the BSC scheme and have never had one fail. My assumption would be that every change/addition after the date of the certificate would fully comply with the standards but at the end of the work obtain a new certificate before navigating as confirmation. Of the number of boats I have had over the years none of them has fully complied when I purchased them and remedial work was required despite them having a Valid BSC. On this basis it must be that many boats are non compliant at some stage during the 4 year certificate validation.

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5 minutes ago, Mike Adams said:

I have quite a lot of experience of the BSC scheme and have never had one fail. My assumption would be that every change/addition after the date of the certificate would fully comply with the standards but at the end of the work obtain a new certificate before navigating as confirmation. Of the number of boats I have had over the years none of them has fully complied when I purchased them and remedial work was required despite them having a Valid BSC. On this basis it must be that many boats are non compliant at some stage during the 4 year certificate validation.

I guess it is worse for live aboards where only a suitably qualified GSIUR registered person can work on the gas.

 

It is all a bit of a farce anyway as I have 'secret shopper' a boat and despite purposely making 6 BSS failures the boat passed with 'flying colours' and not a single failure point identified.

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Well, my boat was fully compliant for twenty five years until it wasn't, with no changes to the boat.  I've always regarded he BSC like an MOT, valid on that day.  No reason at all why the boat should be compliant again till the next examination - I mean, how can you tell?  Mine got failed this year on the electrics, which I had had done by the previous BSC examiner, who obviously passed his own work. It was certainly safer after he'd done it than it had been at any of the previous examinations, all of which it passed, but the latest examiner still failed it.

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2 minutes ago, Arthur Marshall said:

Well, my boat was fully compliant for twenty five years until it wasn't, with no changes to the boat.  I've always regarded he BSC like an MOT, valid on that day.  No reason at all why the boat should be compliant again till the next examination - I mean, how can you tell?  Mine got failed this year on the electrics, which I had had done by the previous BSC examiner, who obviously passed his own work. It was certainly safer after he'd done it than it had been at any of the previous examinations, all of which it passed, but the latest examiner still failed it.

That is (to boaters) a well known problem, but is not recognised as such by the BSS, 

I repeat what I said in post #3

"Whilst the BSS examinations SHOULD be undertaken to a common standard, unfortunately in reality they are not"

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59 minutes ago, Alan de Enfield said:

 

Just remember that the instant you add an appliance (ie gas cooker) your new BSSC may become invalid and you will require a new examination. 

The document you link to doesn't say that. It simply warns that work done in a non BSS-compliant manner may (not will) invalidate the BSC. Compliant work should be absolutely fine.

And the document is not an official Boat Safety Scheme document. It was produced by a trade body that has a vested interest in getting more examinations done by its members.

 

Edited by David Mack
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13 minutes ago, David Mack said:

The document you link to doesn't say that. It simply warns that work done in a non BSS-compliant manner may (not will) invalidate the BSC. Compliant work should be absolutely fine.

And the document is not an official Boat Safety Scheme document. It was produced by a trade body that has a vested interest in getting more examinations done by its members.

 

Ok - this is the relevant paragraph from the BSS website :

If any works have affected or disturbed previously compliant items; or if modification to any boat system is made known by the owner (or owner's representative); or if modifications are identified during the re-examination, then a full examination of the particular modified system (e.g. gas, electric, diesel etc.), must be carried out, irrespective of the interval since the previous full examination.

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6 minutes ago, Alan de Enfield said:

Ok - this is the relevant paragraph from the BSS website :

If any works have affected or disturbed previously compliant items; or if modification to any boat system is made known by the owner (or owner's representative); or if modifications are identified during the re-examination, then a full examination of the particular modified system (e.g. gas, electric, diesel etc.), must be carried out, irrespective of the interval since the previous full examination.

Ok so pragmatically, how does that work with a boat being refitted while its on (eg CRT) waters which require it to have a BSS..........because the boat will be in a constant state of change. For example, you might spend a number of days gradually installing electrical systems, gas and other pipework, removing then refitting a solid fuel stove, etc. If the "law" or whatever the relevant legislation surrounding BSS says that the BSS is invalidated by (non-compliant) work, then it must be invalidated at the outset of a typical refit when the first testable item is altered - possibly only re-validated by another BSS test once the work is complete (which could be many months or years on). And if the "law" says its not invalidated, then the validity can't be anything less than the remaining time on the BSS cert. 

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Are you living aboard? I had a sailaway in the water for final fitting out and as it was work in progress a interim visit by a surveyor purely advised on work todate and future work. Surely a BSS could be suspended until work finished. Licencing I was led to believe was not necessary if in a private marina. Am I wrong?

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1 minute ago, Paul C said:

Ok so pragmatically, how does that work with a boat being refitted while its on (eg CRT) waters which require it to have a BSS..........because the boat will be in a constant state of change. For example, you might spend a number of days gradually installing electrical systems, gas and other pipework, removing then refitting a solid fuel stove, etc. If the "law" or whatever the relevant legislation surrounding BSS says that the BSS is invalidated by (non-compliant) work, then it must be invalidated at the outset of a typical refit when the first testable item is altered - possibly only re-validated by another BSS test once the work is complete (which could be many months or years on). And if the "law" says its not invalidated, then the validity can't be anything less than the remaining time on the BSS cert. 

I have 'no dog in the fight', I am just pointing out the 'official view' of the process.

That is exactly the problem and gives 'wriggle' room to C&RT and/or the insurance company say the boat catches fire and it is traced to the gas system which was installed after the safety checks, the insurers must be tempted to say that it was not installed correctly  ?

I have boats on waters that do not require a BSS and could obviously 'muck-about' with the gas system / electric system to my hearts content, but my insurers have several clauses which could be implemented and the insurance cancelled :

* Claims arising from your reckless actions, or those to whom this policy extends.

* You will maintain and keep “Sea Wolf”, her machinery, sails boats and equipment in a proper state of repair and
seaworthiness and shall at all times exercise due care and diligence in safeguarding them.

 

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I know but you quoted something off the website, I will assume for now that the text you quoted is a truthful reflection of the underlying conditions/validity of a BSS. If so, then, to answer the OP:

* The May 2018 date (if the BSS expiry) is meaningless, since it is already invalidated by the work done in the major refurbishment
* It is not practicable to do major refurbishment in waters which require (by law) a BSS, such as online moorings etc. It may be practicable in a marina where their T&Cs require boats to have BSS (amongst other things....) but where the waters are private. Because they are private, the BSS requirement is no longer a legal requirement but one imposed by the T&Cs, which you may be able to renegotiate. Other refurbishment (eg minor items, or items not covered by BSS) would still be possible on an online mooring.
* Look very closely at insurance, and the requirement for insurance (ie in addition to the legal requirement while online eg on CRT waters, there may also be a T&Cs requirement imposed by the moorings operator).
* Don't forget that a lack of valid BSS also can lead to licence cancellation.

I am sure onionbargee could add some practical experience to echo the above, it is a shame he no longer posts though.

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47 minutes ago, Paul C said:

I know but you quoted something off the website, I will assume for now that the text you quoted is a truthful reflection of the underlying conditions/validity of a BSS.

From their website :

About the BSS Examination and its limitations

Please note: the BSS Examination findings, and examination report, relate only to the facts observed at the time of the BSS Examination. It is not evidence of compliance with the navigation authorities' requirements at any other time.

The owner's on-going responsibility: it is crucial to maintain the vessel in good condition in accordance with the safety requirements; and, any other licensing, registration or mooring conditions of the relevant navigation or harbour authority.  The validity of a BSS pass result may be affected and can be cancelled if the vessel is not properly maintained; and/or non-compliant alterations are made; or if a hire boat or other type of non-private boat is examined against the 'private boat' category of BSS checks.

https://www.boatsafetyscheme.org/boat-examination/arranging-the-examination/bss-certification-what-it-is-what-it-is-not/

 

(Obviously 'properly maintained' & 'non-compliant' is down to the interpretation of the examiner rather than the owner.)

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1 hour ago, jddevel said:

Are you living aboard? 

BSS Website :

Carrying out 'work on the gas system of boats used primarily for residential or domestic purposes fall within scope of a piece of  UK legislation known as the Gas Safety [Installation and Use] Regulations (GSIUR).

As such, the law demands that anyone contracted to 'work' on the LPG system of a boat in scope must be (LPG boats-competent) Gas Safe registered.

As the definition of 'work' covers the removal and replacement of a screw nipple on a gas test point, the scope of the GSIUR includes carrying out BSS LPG tightness test.

Therefore, on a boat in scope of GSIUR, examiners who are not Gas Safe registered can only complete check 7.12.2 (confirming gas tightness) by either:

  • undertaking a gas tightness test using a bubble tester where fitted and correctly located; or,
  • observing the tightness test conducted by a (LPG boats-competent) Gas Safe registered installer
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17 minutes ago, Alan de Enfield said:

can be cancelled if the vessel is not properly maintained; and/or non-compliant alterations are made;

It gets worse! Before, the extract you quoted, said "a full (re)examination MUST be carried out" in other words, the act of modifying a previously-passed system automatically invalidated a BSS. Now its saying the certificate CAN be cancelled - ie its not automatic, but some action must be taken. By whom? How? If the certificate could be cancelled but isn't, presumably its still valid, therefore no issue.....

This is why (for the OP) it is the underlying conditions or regulations which are important, instead of snippets of quotes off the website which appear to be inaccurately paraphrased misinformation.

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1 minute ago, Paul C said:

This is why (for the OP) it is the underlying conditions or regulations which are important, instead of snippets of quotes off the website which appear to be inaccurately paraphrased misinformation.

Not sure why you think I have incorrectly paraphrased, the previous :

If any works have affected or disturbed previously compliant items; or if modification to any boat system is made known by the owner (or owner's representative); or if modifications are identified during the re-examination, then a full examination of the particular modified system (e.g. gas, electric, diesel etc.), must be carried out, irrespective of the interval since the previous full examination.

Was taken from a different 'page'  - you try working thru their website, it is at best 'a bit clumsy'.

Interesting that the navigation authority seems to have the final say "This is a BSS policy, it will always defer to the Navigation Authority's licensing interests concerning specific boats"

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No, I am saying you have (simply) quoted off the website. If you've quoted it then you've not paraphrased it, you've just done a copy & paste. I am saying the things you have quoted, are misinformation because they incorrectly paraphrase (one saying MUST get another examination, the other saying CAN be invalidated....) whatever the actual underlying regulations are. I agree 100% that the BSS and their website is to blame here. 

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I would say a BSS is only valid on the day of inspection, just like a car M.O.T,  the OP kowns the answer like we all do, the boat can only be inspected on the day and any systems that comply with the BSS must pass, any systems that come under the BSS that are not in use must be made safe/de-commissioned. Any systems fitted afterwards must comply with BSS and be signed off and a new BSS issued. If the boat has been on and is still is on the water it must comply.  New builds/sailaways slightly different. A 1987 boat on CaRT water needs a BSS, if you fit a system after the current BSS then that BSS is invalid until a new BSS  passing it has been issued. Also insurance is invalid too. 

How many clueless boat owners fit things after the BSS only for their work to fail the next inspection.

 

 

 

 

 

 

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3 hours ago, Mike Adams said:

 it must be that many boats are non compliant at some stage during the 4 year certificate validation.

True.

But many boats not complying  with the regulations doesn't make it right.

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I seemed to have opened an interesting debate. Clearly a lot of fog around this area. I wonder how many people have had a new bss  when they have changed something testable. I have taken the view that the BSS is like a car MOT that it is only valid on the day of the test but like a car it doesn't comply with the Road Traffic acts later on you can still be prosecuted. Luckily I have been through the whole BSS check list and the only thing that has been altered in respect of testable items is the removal in its entirety of the gas system and appliances ( which didn't comply when I bought the boat and have never used) and the boat would still comply if tested tomorrow. Taking some members views changing the battery for a slightly higher Ah one or replacing the Fire extinguishers or a starter motor cable would require a re examination. Overall the BSS is probably as good a compromise if you remember the state of some boats prior to its instigation that you were forced to share locks with and the number of boats you pass with petrol generators running in the cockpit.

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I'm sure if your battery cable is sufficient to carry the amps, same with the starter battery cable all will be OK. I think it is more to do with fitting new major systems ie  a new gas systems, new fire installations, fuel systems, major electrical upgrades. I think you have the common sense to know you need to upgrade the amp capacity of a cable for it to be safe to use and not cause a fire risk.

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36 minutes ago, Mike Adams said:

I seemed to have opened an interesting debate. Clearly a lot of fog around this area. I wonder how many people have had a new bss  when they have changed something testable. I have taken the view that the BSS is like a car MOT that it is only valid on the day of the test but like a car it doesn't comply with the Road Traffic acts later on you can still be prosecuted. Luckily I have been through the whole BSS check list and the only thing that has been altered in respect of testable items is the removal in its entirety of the gas system and appliances ( which didn't comply when I bought the boat and have never used) and the boat would still comply if tested tomorrow. Taking some members views changing the battery for a slightly higher Ah one or replacing the Fire extinguishers or a starter motor cable would require a re examination. Overall the BSS is probably as good a compromise if you remember the state of some boats prior to its instigation that you were forced to share locks with and the number of boats you pass with petrol generators running in the cockpit.

Car MoT is a bad analogy, although one often made. People get confused about the validity of an MoT certificate too. When a car passes an MOT, it what actually happens is its issued with a certificate which is valid for a year (or a bit longer, if you took advantage of the facility to test the car in the month before it expires etc). A car doesn't actually "fail", technically its a "refusal to issue a certificate" which is almost but not quite the same thing - the refusal doesn't render any previous certificate invalid. So for example, if I have a car with an MoT cert, take it in for test a few weeks before expiry and it "fails" (doesn't get another certificate), the old one still applies and I can drive it round until this expires, irrespective of what was found at the more recent test, until the old one expires or the car passes a retest or another test.

HOWEVER there is entirely separate legislation - the Construction and Use Regulations - which makes it against the law to use an unsafe car on the road. Of course, each set of regulations (the MoT and the C&U) cover broadly similar ground but there are differences. (Also worth mentioning there is other legislation to deal with car safety issues, eg the VDRN scheme).

In a similar way to the C&U regs, each navigation authority has a piece of legislation which allows them to revoke the licence of a boat which is (in their opinion) unsafe, irrespective of whether it has a BSS cert or not - although a recent BSS cert and no changes in the interim would obviously play in your favour in challenging such a revokation. I believe (happy to be corrected) this legislation is hardly ever used though.

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1 hour ago, Mike Adams said:

 Taking some members views changing the battery for a slightly higher Ah one or replacing the Fire extinguishers or a starter motor cable would require a re examination. 

No one would be any the wiser  providing the installation of the new battery etc is compliant with the BSS requirements. I don't think anyone would say changing an existing battery  for a new one  would be a significant change. However adding extra batteries might be a significant change. Similarly a replaced fire extinguisher or starter motor cable could not be recognised by looking at the boat and comparing it with an earlier BSS surveyors report .........assuming  the replacement  items are in  no way defective.

 

If you have no gas pipes or appliances at the time of the BSS exam the absence of a gas system will be noted by the examiner. The paperwork shows whether a pressure test was completed and whether the outcome was satisfactory - obviously this would be struck out as not applicable and it will be clear the boat has no gas  system.

When  a gas  system is later fitted a fresh  BSS exam should arranged. However if you do not do so until the earlier BSS certificate expires I doubt anyone will notice.

 

 

Edited by MartynG
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