To conclude, the reason for producing this Open Letter to industry is that we are keen to advise our surveyor members, insurers, owners and operators of the correct rules, as well as highlighting some of confusion and conflicting regulations that currently exist.
We also recognised a need to advise our members and other interested parties of a correct Code of Practice to apply in an attempt to level the playing field and ultimately to keep surveyors safe from litigation.
The readings should be presented on a separate UTS form (see example below) stating the parameters used for assessment. As you can see the diminution measurements have been listed as a percentage of material lost and can be colour-coded and easily referenced, so highlighting when a repair is imminent or required.
In truth, there may be no simple answer to all of this. I personally find some of it confusing. I hope that this article has helped to shine a light on the complexities and to enable a more informed judgment to be made when undertaking and assessing these types of surveys.
And finally. Another question recently posed by a member was to do with the installation of lithium-ion batteries in Inland Waterways vessels and for that matter, in all vessels. This remains a hot topic currently.
The requirements are covered in MGN 550 and the Workboat 3 Code of Practice below:
Repair recommendations
In response to the question regarding ‘Over-plating’ or ‘Doubling’, I personally recall in the 1980s the Ministry of Defence requiring all welders on hull structure (me included), to be code B qualified to a hull insert inclined overhead procedure. Doubling plates were to be considered an emergency repair process only. In the 1990s as a Ship Repair Manager the attending Lloyd’s surveyors would only allow doublers as temporary repairs, which were required to be replaced with inserts at the next scheduled docking. However, this was in relation to sea going craft.
In Inland Waterways vessels the over-plating/doubling of the wind and waterline appears to be quite common and if completed properly with window welding to ensure
attachment to the underlying structure, should be considered a suitable repair. However future surveys should take into consideration that no one ever knows what is going on under the over-plating.
Another exception would be floating house boats (definition: a boat which is or can be moored for use as a dwelling or a non-navigable vessel used for accommodation), often kept on non-tidal waters or drying berths. With these vessels the principal concern is keeping water out and staying afloat rather than structural strength. But again, this must be made perfectly clear in the report, because the danger is that the vessel could be sold to someone who intends to re- engine the craft and turn it back into a navigable vessel. It is not unknown for owners to take their vessels across the English channel to cruise the continental waterways!
8.3.3
- A fuel tank and lithium-ion batteries
used as a source of power for propulsion shall be located in separate spaces which do not share a boundary with any accommodation space or each other.
The misleading wording is “batteries used as a source of power for propulsion” which implies that batteries installed for other uses such as engine starting and domestic power are not subject to the same guidelines.
This has resulted in surveyors, (me included) in making judgements and interpretations which were not to the vessel owner/operator’s liking. Unless more specific advice is forthcoming, the decision on the suitability of a particular installation will often fall to the surveyor concerned depending on the individual circumstances. Once again it is left to the surveyor to interpret the rules and guidance to the best of his/her ability and ultimately at their own conscience.
112 | ISSUE 111 | MAR 2025 | THE REPORT
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