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Old 20 March 2011, 14:27   #1
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MGN 280 22.9.1.2 - Harmonised code - possible introduction late 2011

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 22.9.1.2 – MCA Harmonised Code [/B]
Mark Towl MCA Policies Unit Southampton – part of e mail receivedThe 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 receivedWet 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 22.9.1.2 Section 22.7.2 requires immersion suits for vessels operating in high latitudes onlyArgyll 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).
info@weymouth-angling.co.uk
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

Please note 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.
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Old 20 March 2011, 16:22   #2
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Interesting thread,, i will send info for circulation via Professional Charter Association as I am aware we have a representative who has been attending the briefs and conferences about the plans and proposed changes wit the MCA. Up to now we have been kept well informed but had not been notified of this direction

i note " 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"
Can this mean we could carry an immersion suit for such a situation or ACTUALLY carry one for every client? The TPAs we carry are a coding requirement and I suspect were the accepted level for this eventuality. I am aware that conditions attached to CAT 3 night restricted for us is that suitable clothing is available for all passengers but it does ot included wearing them. I would recommend the wearing and instruct clients to do so. I cannot see how an operator could meet this level of equipment.
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Old 20 March 2011, 17:34   #3
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I have already raised this as a question to the RYA in respect of guidance for recognised training centres operating in these type of water temperatures

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Old 21 March 2011, 14:51   #4
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Further Background information on sea temperature thread

Our problem is trying to sort out the interpretation and the actual statements/regulations.
If you read Mark Towl's mail contents then he clearly states there must be a suitable garment for every person on board be they baby, child, adult, pensioner, disabled. I live on an island where the public ferry is an open 20 foot boat. For babes in arms there must be a thermal cot, my mother recently visited and she is 85 - not immersion suit material I fear.

The RYA have clearly followed the party line. If wearing waterproofs whilst out on a RIB is not considered 'safe for passengers then neither can it be safe for instructional purposes. The RYA cannot hide under their priviledged exemption clauses as issued by the MCA. Bas Edmunds states that there must be suitable 'immersion suits or other garments aboard.

ACBA are trying to publish the information widely, please pass it on. We believe the changes to the regulations cannot be justified on the grounds that there have been incidents. We are prepared to stand corrected. This perhaps is changing the rules for the sake of change and the implications to the operators particularly those up north will be significant.

We encourage everyone to write to Mark Towl and air your views as a commercial operator.
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Old 22 March 2011, 09:20   #5
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Whilst initially I was alarmed to see this proposal as I do not run an all year business in the UK I think the impact should be minimal.
The year round average for the whole of the UK is 11.1 and even today there are parts of the Bristol Chanel at 10 and the Solent is 8.
Are there any other changes proposed for the coding for passenger craft<12 persons
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Old 22 March 2011, 11:06   #6
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Unfortunately the UK extends further north than Brizzle...

Up here there are many small but inhabited islands where the ferry service is little more than a man in a wee boat - if these people (who are often on what would be less than the minimum wage, being self-employed) are required to make a large capital outlay on items which will never be used I can foresee that many of them will just pack up; and then the island economies will deteriorate even further. (Don't imagine for one minute that any Scottish politician will stand up and say "It's alright, we've got it covered.") It's all very well for a man at a desk in Southampton to have these brilliant ideas - he doesn't have to bear the financial and social consequences.

I understand perfectly well the consequences of an unintended dip in winter (as would any other commercial skipper); but the answer is easy to arrive at:
If the weather's so bad there's an unacceptable level of risk to vessel or persons thereon - just wait until it settles down. Simples!
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Old 22 March 2011, 13:28   #7
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Would Fladen suits cover it?
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Old 22 March 2011, 13:40   #8
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Originally Posted by Rogue Wave View Post
Would Fladen suits cover it?
If they were:

1) Small enough to store the required number on a small vessel;

2) One size fits all precisely;

3) Very, very cheap...

...when you need to spend X x £75 on stuff you'll never use, and your gross profit per passenger per trip could be between £3 and £5, it's going to take a long time to cover the cost - especially in an area where J. Public is an infrequent visitor.

(Anyone who starts arguing about "business models" is probably an accountant [or a banker - even worse] with no grasp of real life in the islands).
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Old 22 March 2011, 13:42   #9
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Russell, I agree with you, the outlay for any operation is huge. It also does not say if they have to be worn or just available on the craft in case someone went in the water then the supply of a suitable suit or similar after recovery. I thought this is why we had TPAs for these occassions.

"I understand perfectly well the consequences of an unintended dip in winter (as would any other commercial skipper); but the answer is easy to arrive at:
If the weather's so bad there's an unacceptable level of risk to vessel or persons thereon - just wait until it settles down. Simples!"

I am down souf and do not support this additional inventory, safety comes first


Rogue- Fladen suits I have a couple but they are still not cheap and I believe they let water in at cuffs and ankles so very similar to the weatherproof kit we supply when needed.
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Old 22 March 2011, 13:49   #10
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Not sure what use this stuff will be on the boat. In almost any circumstance where a small open boat requires these you'll already be in the water before you've had a chance to put them on.

Quote:
Rogue- Fladen suits I have a couple but they are still not cheap and I believe they let water in at cuffs and ankles so very similar to the weatherproof kit we supply when needed.
You need to try both out jumping into cold water, then staying in there for 15-20 minutes.
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