Rethinking Post-construction Assessment
A discussion paper of interest to UK inland waterways narrowboat surveyors and brokers by Tom Keeling CMarEng MIMarEST and Peter Brookes CEng, MIET, AffilIIMS.
IIMS statement: This article is a lite version and brief synopsis extracted from the much greater volume of work contained in the main document which can be downloaded at the end. IIMS is grateful and supports the immense time and detailed research that Tom and Peter have jointly put into making their argument in an attempt to stimulate debate and bring clarity to an area that is still shrouded in mystery and confusion for many. Once you have read and digested the content and are involved in this particular sector, Tom and Peter are very keen to hear your thoughts and feedback by email at
info@smallcraftservices.com or
peter@technicalsupport.ltd.uk before deciding on their next course of action which IIMS is keen to support.
Abstract
The authors present arguments that suggest the UK inland waterways sector has, since 1998, been led to conflate sailaway narrowboats with own-built boats. The Recreational Craft Regulations 2017 (RCR 2017) confirms there is a difference, and this paper outlines that there are three kinds of vessel that need consideration against the RCR 2017. They are own-built, manufactured sailaway boats, and manufactured completed boats.
Developing this point, the scope of the RCR 2017 is considered, particularly how this is clearly defined as applying to manufacturers, distributors and importers of boats. An argument follows that the RCR 2017 does not apply to a manufactured boat once in private ownership and that the current understanding of the scope of the legislation requires revisiting. Continuing on from this, if the RCR 2017 does not apply to manufactured boats once in private ownership, then
neither can any of the requirements of Post-construction Assessment (PCA). Furthermore, the legislation states PCA applies to a product when ‘first placed on the market’ or ‘first put into service’. The logic of applying this “first” only process (as defined by the legislation itself) a second time to privately sold and owned used vessels is questioned.
Further to this, recent claims that brokers of privately sold used vessels have responsibility for RCR 2017 conformity is dispelled, and the distinction between brokers of privately owned used boats and distributors of manufactured new products is discussed.
Subsequently, brokers and marine surveyors involved in the used boat market are cleared of any responsibility to consider RCR 2017 conformity, or whether PCA is required.
What remains is to try and understand how the sector has got to where it is with this legislation.
Introduction
The Recreational Craft Regulations 2017 (RCR 2017) sets out conformity requirements for new and imported recreational craft, and obligations for manufacturers, their authorised representatives, importers and distributors. HM Govt. RCR guidance (2021, 2023) explains the purpose of the legislation is to ensure safe products are placed on the GB market by requiring manufacturers to show how their products meet the ‘essential requirements’ listed in Schedule 1 of RCR 2017.
The RCR mirrors the EU’s Recreational Craft Directive (RCD) which first became law in 1996 (RCR 1996 / Directive 94/25/EC), being fully implemented in 1998 after a two-year introductory period. The RCR 2017 is essentially the GB version of the latest RCD release (Directive 2013/53/EU).
Within the RCR 2017 is a requirement to complete Post-construction Assessment (PCA) of a boat when
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