Summary:
Having gathered the information and read it all, it is my opinion that unless a vessel is designated a particular design category you cannot assess its stability and/or freeboard requirements. That is why design categories were created in the first place. Because the majority of Inland Waterways craft were constructed and placed on the market without a Certificate of Compliance and therefore never certificated to be in compliance with any rules regarding stability, floatation, freeboard or downflooding, no plates allocating and stating the maximum passenger capacity and load or even Design Category were fitted and these limitations were never included in the boats operating manuals because they were never supplied with one.
No doubt this is why there has been a wider discussion recently that all Inland Waterways Craft must now become compliant with the Recreational Craft Regulations. This is a monumental undertaking when you consider the amount of vessels concerned, an estimate of up to 80,000 vessels has been suggested.
As a result of this confusion in the sector, is it any wonder that surveyors, insurers, owners and operators are at a loss to know what rules to apply when assessing the risk. How can an insurer, for example, assess the risk and quote a level of cover if they have no idea what they are actually insuring?
The answer is that they can’t. In some instances, they may rely on an owner’s declaration regarding the details of his/her craft and its intended use, which places the onus on the owner.
In other instances, insurers will depend on the details contained within a marine surveyor’s Survey Report which places the onus on the surveyor. However, without any information regarding the suitability (i.e. conformity) of a vessel and its compliance with the relative standards how can a surveyor accurately assess the suitability of a vessel without knowing what the vessel has been designed to do?
To avoid the full RCR Post Constructive Compliance process perhaps one solution may be to simplify the assessment of Inland Waterways Craft by conducting a simple stability assessment, such as a Heel Test. IIMS has a procedure and certification process which is used by Commercial Certification Authorities to satisfy the requirements of stability of vessels which do not have Certificates of Conformity in regard to ISO 12217 or a full Stability Information Book.
Another issue is that vessel sinkings have brought about conflicting and confusing statements from some insurers regarding steel hull thickness limits - one being a requirement for a 4mm limit and another a 3mm limit.
In reality setting these limits is largely pointless. A vessel built of 6mm thick
plate may have pitting or diminution which has reduced the thickness of the hull to 1mm making it likely to sink, whereas a vessel built of 3mm thick plate without pitting or corrosive loss will be unlikely to sink.
For example, providing that it has been well maintained a vessel built out of 3mm plate with a freeboard of 100mm may be perfectly acceptable for operating in the flat calm knee deep waters of a canal no wider than the vessel’s own length in sheltered inland waters; but may not be suitable for operating in deep tidal rivers and estuaries exposed to the elements and wave action.
The next topic for discussion is the construction and corrosion issues with regards to steel Inland Waterways vessels and, in fact, steel craft generally.
I have written in the past about the surveying standards of Inland Waterways craft, which was triggered by an Insurer refusing to insure a steel narrowboat with a hull under 4mm thick. As mentioned previously, we have heard of some insurers setting a limit of 3mm, even though as we know some vessels were originally built using 3mm steel plate.
Insurers were also insisting that all the surveyor’s recommendations, even minor advisories, should be rectified before insurance cover could be granted. But as can be seen from the previous and following sections this brings into question on what basis these recommendations were made and their validity.
108 | ISSUE 111 | MAR 2025 | THE REPORT
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