This is linked to the thread sea temperature.
Argyll Charter Boat Association
wishes to publicise the following statement. It will affect all those operating small commercial vessels 12 passengers or less. Many RIBs operate under this code RIB operators can find the sea temperatures for their local area
Small Commercial Vessels - New Harmonized Code MGN 280
These new regulations will affect all small commercial vessels (12 passengers or less) operating currently as yellow, brown, code, Proposed introduction Oct 2011
[B]MCGA Working Group Meeting 29th/30th March 2011
Section 22.214.171.124 – MCA Harmonised Code [/B]
Mark Towl MCA Policies Unit Southampton – part of e mail received
The current wording in the Code requires the operator to ensure that there is suitable clothing onboard for the prevailing sea and air temperatures.
Additionally when there is a sea surface temperature of less than 10C, there should be an approved immersion suit, dry suit or other efficient garment onboard to reduce the likelihood of hypothermia should the wearer enter the water. That could mean a floatation suit or anything else that is suitable. I would not foresee that a set of wet-weather clothing would necessarily be suitable. The garment would need to have some form of thermal insulation properties when worn in the sea.
Bas Edmunds RYA Technical Manager – part of e mail received
Wet weather gear alone does not provide any form of insulation nor does it prevent the ingress of water when the user is immersed. It should be noted that this requirement is for the skipper/owner agent to provide this for the passengers and is not a requirement for survey. However, it would form part of an inspection if stopped by the MCA. It is not a requirement that they are worn but more that they are available. Generally our experience of the inspectorate branch of the MCA is that they are very thorough
Sea surface temperature Scotland is confirmed at 10 degrees C or less between mid/late November and mid/late May.
PLEASE NOTE – Current codes – there is no section 126.96.36.199 Section 22.7.2 requires immersion suits for vessels operating in high latitudes only
Argyll Charter Boat Association will be writing to Mark Towl at The MCA Policies Unit for information and clarification of the following points
1. What recent incidents have occurred with small vessels to justify the introduction of these new regulations?.
2. Vessel abandonment should be to Liferaft. Entering the water is a last resort. How many incidents have occurred with small commercial vessels when abandonment to liferaft has not been possible, the sole alternative being entering the water.
3. The yellow code required suits for vessels operating in high latitudes.
What were the criteria used to establish high latitudes as a sea temperature of 10 degrees C?
4. The provision of floatation suits and immersion suits are difficult where the relative sizes of the passengers are unknown till arrival. Immersion suits (one size fits all) will not fit babies and children. Floatation suit are individually sized – no child sizes.
5. Entering the water in an immersion suit should we suggest be preceded with some form of training. This is not possible with passenger transport of the general public.
Many northern charter boat operators appear unaware of these changes which will be enforced from Southampton. Sea temperatures of 10 degrees or less affects Scottish waters (east, north and west coasts) not necessarily the south coast of England. The Professional Boatman’s Association will express concern at the Working Group meeting 29/30 March on behalf of its northern members
If you are concerned about the potential impact of these new regulations on our industry we urge you to ACT NOW
and state your concerns
1. write to Mark Towl at Mark.Towl@mcga.gov.uk
2. If you are a PBA member write to Dave Gibson (secretary).
If you are not a member could we suggest you consider joining so your views have representation by an organization at this meeting.
3. Write to your MP stating how this new legislation will adversely affect your business.
4. Pass on this information to anyone you know who has a small commercial vessel. Small island ferries (< 12 passengers) also appear affected.
The intention is to at least keep this topic on the agenda for a later Working Group Meeting so if you receive this notification after 29th March 2011 please do still write and let your views be known. The MCA need to be aware of the views of small boat operators before any future Working Group meetings
these are the personal views and concerns of our Association following considerable consultation with the MCA Policies Unit and the Royal Yachting Association. They do not represent any official policy interpretation. It is suggested that you should seek independent advice.