All sectors of small commercial vessels in the Oban and other western ansd northern area are showing concern re MGN 280 188.8.131.52
We are people in the front line. I offer RIB trips, others are coded sailing charter yachts, small passenger ferries, RYA yacht teaching establishments. It is not just RIBs who are seeking justification for the change.
We are to advise our passengers, we should have on board. These are the words of the code and the interpretation from the MCA and RYA.
Some of the potential issues for RIB trips
We have to stand at the top of the jetty and 'advise' our customers who purchase a ticket as passing trade that they should have a drysuit, immersion suit or floatation suit. Certainly the customer won't have one
the 'advice' immediately indicates to the customer (who may not be from a sea background) potential risk We admitted there is but we belive this is well managed.
The customer will expect the operator to provide suitable equipment - a suit per person per trip as a floatation suit really needs cleaning after each use if they are to be used by others. There are practicality and hygiene issues.
What of the sizes for the 5 year old on a sunny day wishing to go out and see the seals? We just issue waterproofs and take something in the locker whilst parents get a floatation suit?
What of the disabled person with independent seated balance who wishes to go for a 'gentle cruise' with family. In the event of abandonment they would never get in a suit.
The general view from many sectors of the small commercial boat operators in our area are that these changes to the regulations are wrong.
The debate about the word should on providing these garments could eventually be interpreted as must (perhaps lead by insurers)
There is growing opoosition here.
As a point of interest, yesterday's sea temperatures around the UK did not reach 10 degrees apart from west coast of Ireland. Did anyone who was out on the water yesterday advise their general customers that they should be wearing drysuit, immersion suit or other suitable garment? We have all been working to MGN 280 Harmonised code even theough technically its not statute.
I have tried to copy the temp chart to this post and failed but I can supply
If you believe we have a justifiable case do please write to Mark Towl at Mark.Towl@mcga.gov.uk
If you are an RYA member/teaching establishment also write to Richard.Falk@rya.org.uk