IIMS member, Jason Rudd MIIMS, writes,


I read Jeffrey’s piece in the latest issue of Te Report with interest, and as always he made a fine job of simplifying a very technical subject; however there were a couple of parts where references are made to “Category of Waters” that I believe may be misleading.


As you are aware I spent ten years employed as the Marine Surveyor for the Port of London Authority, and I can say without doubt the most commonly asked question relates to categorisation of waters and the limitations of vessels. Whilst I believe that Jeffrey has a sound knowledge of this subject, the way in which some of the article is worded may lead to confusion for surveyors less well informed about the subject. In the foreword to the article Jeffrey makes reference to vessels EU Category C & D waters which in its self is a little confusing. If the intention was to point towards RCD categorisation of vessels, which I believe it was when you read onto Appendix 1, it would have been better worded as “EU Design Categories” so as not to confuse it with Categories of Waters. When Stating EU Category C waters for passenger ships, this could lead to confusion with vessels operating in Category C waters, which are Inland waters as defined in MSN 1837.


As I read on I was also surprised to note that EU 94/25/ EC was quoted in Appendix 1. As far as I am aware this Directive has been repealed and superseded by EU 2013/53EC, albeit the point of discussion contains the same text as that upliſted for the article. Furthermore “Category Definitions” should have read “Design Category Definitions” as these have been liſted from RCD (EU2013/53) and relate to the design and construction standards and not sea areas as the title would suggest. Te second part of Appendix 1 makes reference to MSN1719 which I can not find, but looking at the first sentence would suggest that this has been liſted from MSN1747 - Te Merchant Shipping (Passenger Ships on Domestic Voyages) Regulations 2000, which could quite easily add to the confusion, as the following text is all about the Categorisation of Inland Waters set out in MSN 1837.


Also in relation to N.B.4; the safety bulletin issued by the PLA (01/2012) was at the time aimed specifically at narrowboats operating in Central London, on a section of the Tames which are considered to be Category C waters. I would just like to clarify that Category C waters do not extend downriver to Sea Reach No.1 buoy. Te outer limits of Category C waters are Denton Wharf as defined in MSN1837, and beyond this point the River is classified as Category D waters until it meets the Sea where MCA Coding takes over. Te River Medway upstream of Garrison Point is also defined in MSN1837 as Category C waters.


22 | The Report • June 2019 • Issue 88


Letter to the Editor


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