THE RECREATIONAL CRAFT DIRECTIVE 2013/53/EU
A BRIEF GUIDE FOR INLAND CRAFT
Within this brief overview I will attempt to clarify some of the requirements associated with the RCD. Unfortunately, the relevant statute has been composed in legalese and somewhat complicated. The current directive can be found here.
There remains a great deal of myth and confusion associated with the Directive. Morse Marine can offer a consultation and inspection package that enables the builder or owner to comply with the Directive.
THE NEW RCD
On the 17th January 2017 a new directive came into force, the new statute being 2013/53/EU. There are some changes within the new directive, one or two areas have become more stringent in particular the new restrictions for engine emissions have been particularly difficult to achieve by some engine manufacturers.
Furthermore, the UK association of trading standards authorities have interpreted the new directive in a peculiar way, they have decided that a ‘sailaway’ is a completed product and therefore in a condition that can be used. Accordingly, the manufacturer of the ‘sailaway’ should have a 3-letter Manufactures Identification Code (MIC) and in turn affix a 14-character Watercraft Identification Number (WIN) on the vessel.
- Craft smaller than 2.5m and larger than 24m.
- Craft that were completely finished before 16th June 1998.
- Completed craft that were sold before the 16th June 1998.
- Craft built for own use AND not sold for 5 years.
- Gondolas etc.
Lies with the company or person first placing the product on the European market. The ‘Responsible Person’ shall ensure that all aspects of the Directive are complied with. Each craft must be allocated a prescribed Watercraft Identification Number (WIN) and the craft must carry an approved CE Plate marked accordingly.
Trading Standards Officers (TSO’s) are responsible for enforcement within Local Authorities.
Prosecution can lead to a £5,000 fine and/or three months imprisonment. Should there be a successful prosecution the offender will attract a criminal conviction. The RCD is not a code of practice it is a legal requirement.
There are four design categories ranging from ‘A’ to ‘D’.
- For category ‘D’ craft the builder has recommended that the craft is suitable for conditions where the wave height is no greater than 0.3m and the wind strength is no greater than 4 (Beaufort).
- For category ‘C’ craft the builder has recommended that the craft is suitable for conditions where the wave height is no greater than 2m and the wind strength is no greater than 6 (Beaufort).
Morse Marine can assist with all categories but for category ‘C’ craft (greater than 12m) the involvement of a Notified Body will be required. Morse Marine will combine with the Notified Body and the Notified Body will specifically undertake assessments for the craft structure and stability.
ESSENTIAL REQUIREMENTS (ERs)
Upon completion of the craft the following ERs must be complied with. It is intended that the ERs be supported by the harmonised standards, however this not a mandatory stipulation; other standards, proven industry standards and codes of practice can be utilised to demonstrate conformity where appropriate.
1 – Boat Design Categories
2 – General Requirements
2.1 – Hull Identification
2.2 – Builders plate
2.3 – Protection from falling overboard and means of reboarding
2.4 – Visibility from main steering position
2.5 – Owners manual
3 – Integrity and Structural Requirements
3.1 – Structure
3.2 – Stability & freeboard
3.3 – Buoyancy and floatation
3.4 – Openings in hull, deck & superstructure
3.5 – Flooding
3.6 – Manufactures recommended load
3.7 – Life raft stowage
3.8 – Escape
3.9 – Anchoring, mooring & towing
4 – Handling characteristics
5 – Installation Requirements
5.1.1 – Inboard engine
5.1.2 – Engine ventilation
5.1.3 – Engine exposed parts
5.1.4 – Outboard engines starting
5.2.1 – Fuel system – general
5.2.2 – Fuel tanks
5.3 – Electrical Systems
5.4.1 – Steering System General
5.4.2 – Emergency Arrangements
5.5 – Gas System
5.6.1 – General Fire Protection
5.6.2 – Fire Fighting Equipment
5.7 – Navigation Lights
5.8 – Discharge prevention
B Exhaust emissions (propulsion engines)
C Noise emissions
DECLARATION OF CONFORMITY
Upon completion of the craft the responsible person must issue a Declaration of Conformity stipulating that the RCD provisions have been complied with. The certificate should include the standards used to demonstrate that the ESR’s have been attained.
Each craft must be provided with a dedicated boat manual that should include specific detail and explain the following to the user:
The identity of the boat (i.e. builder, model and Craft Identification Number)
That the boat complies with the RCD;
The meaning of the RCD category & associated stability & loading data;
The limitations of the systems and the boat itself;
How the boat and systems should be safely operated;
What equipment is on board;
Where essential (including) equipment can be found;
How the boat systems should be maintained;
TECHNICAL CONSTRUCTION FILE (TCF)
During the construction of the craft the builder is required to compile a TCF; the builder must retain the file for a period of 10 years.
Extracted from the statute: –
“The technical documentation must comprise all relevant data or means by the manufacturer to ensure that components or craft comply with the essential requirements relating to them.
The technical documentation shall enable understanding of the design, manufacture and operation of the product, and shall enable assessment of conformity with the requirements of this Directive.
The documentation shall contain so far as relevant for assessment:
- a general description of type,
- conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits etc.,
- descriptions and explanations necessary for the understanding of said drawings and schemes and the operation of the product,
- a list of the standards refereed to in Article 5, applied in full or in part, and descriptions of the solutions adopted to fulfil the essential requirements when the standards referred to in Article 5 have not been applied.
- results of design calculations made, examinations carried out, etc,
- test reports, or calculations namely on stability to point 3.2 of the Essential Requirements and on buoyancy to point 3.3 of the Essential Requirements.”
Canal & River Trust (C&RT) and The Environment Agency (EA) control, for the most part, the UK waterway system. Upon licensing a new craft the following will be required:
A ‘Declaration of Conformity’ (Annex III Declaration) issued by the shell builder.
A ‘Declaration of Conformity’ (Annex IV) issued by the supplier of the completed craft.
Upon the second annual licence application the Annex III Declaration for a partly completed craft will not qualify for a licence; either a ‘Boat Safety Certificate’ or a full ‘Declaration of Conformity’ will be required.
1. There is no mandatory requirement for a Boat Safety Certificate with a new craft, although for licensing purposes the Navigation Authorities require a Boat Safety Certificate after a four-year term from the initial registration.
2. The Boat Safety Scheme management stipulate that almost without exception the harmonised European Standards are in accordance with the compliance options within the BSS Guide.