ECP review 2012 Coments Received

Comments Submitted During Summer 2012 on Proposed Changes to the BSS Examination Checking Procedures

Ref:

Comments Received

General comment

General

RBOA - The Residential Boat Owners' Association (RBOA) feels that it has had many opportunities to have input into the proposed revisions of the Examiner Checking Procedures (ECPs) via its representative on BSSAC, and feels that most of the specific details of the checks have been well aired via this route.  However, it seems that there are likely to be certain aspects of the ECPs where there is a need for the BSS Examiner to inspect certain items, and might not legally / for H & S reasons be able to do this without specific preparation having been made.  Specific examples might be the need for the Examiner to examine the condition of the gas locker, necessitating the removal of the gas bottles; or the need for an a.c. shore line to be disconnected, prior to its being visually examined.   RBOA would urge BSS to ensure that written guidance is provided to Examiners on the need to alert boaters to the need to make items readily accessible for examination, prior to attending to undertake the actual examination.  This could mean removing gas bottles, disconnecting shore leads, uncovering any "hidden" connections, and so on.  

Therefore, if the boater does not plan to be present during the BSS examination to remove/uncover relevant items, then (s)he should be made aware in advance of the preparations which should be made.  To avoid any doubt about whether such instructions have been given, we would suggest a brief tick-list of required preparations could be handed to / emailed to the boater when the test booking is made.

 

Part 2 - Permanently installed fuel systems and fixed engines

2.2.1

NABSE observation - What does 'free of signs of leaks' actually mean. If the Examiner was to find a 'signs of leak'in the form of a stain on a flexible hose / fuel tank top surface, what is the boat owner meant to do about it - change the hose based upon the fact that an (unspecified) stain has been observed ? What is the difference in responsibility on the Examiner between checking for 'signs of leaks' rather than to confirm a fuel system is 'leak-free?

NABSE comment - The dilemma presented by his change proposal is, that by changing the standard engineering term relevant to this check to 'signs of' means that the Examiner can only apply a visual check to establish the fact that a fuel system is free of 'signs of leaks'. By contrast, the freedom to ensure that a fuel system is 'leak free' enables the use of a combination of sight, touch and smell. On the assumption that the 'difference in responsibility' does not imply any change to the Examiner's insurance liabilities, the original terms should be retained.

2.2.2

NABSE observation - The Rationale for the change states that: "The risk assessment is the change is necessary to address the potential for petrol escape into the tank space. (GR 5)" However, this ECP CLI relates to the 'self-draining'  characteristics of a fuel filling line (and is not directed at a particular fuel type).

NABSE comment - Because GR5 relates to 'design, installation and, maintenance' this ECP CLI does not have 'a loophole' because there is no anomaly for the simple reason that the requirement for this check relates to the risks associated with the retention of fuel in a kinked or otherwise non-falling fuel filler pipe. The original text should be retained for the following reasons: The objective of this CLI is related to fuel. As written, the check has been hi-jacked by specific reference to petrol (thereby falsely justifying the need of a non-existent ENHANCED check) The cited risk justification does not exist (ie: a craft with a non-kinked, falling fuel filler pipe which is properly secured (2.2.1) will predominantly mitigate the potential for petrol fuel escape into the tank space.

2.2.3

NABSE observation - While the need to incorporate the statement in TN01.06.ECP01 (RINA DIP/66/96 hoses) is understood, how should the case of Freeman fuel filler hose which is marked 'EXHAUST' be communicated to all Examiners?

NABSE comment - Consideration should be given to publishing the detail of the 'agreement' between the BSS Office and the cited hose supplier in a Tech Note / Appendix to the ECP's to cut down the number of phone calls / emails to the BSS Office on 'case-by-case' basis

2.3.5

NABSE observation - While the need to incorporate the statement contained in TN01.06.ECP01 (RINA DIP/66/96 hoses) is understood, what about cases where the fuel tank vent line is achieved by an equally suitable length of (properly sized and fitted) hose whose flame resistance and fuel transport capability matches / exceeds those of BS 7840 (eg: SAE 100 / EN 853)? Because SAE 100 / 853 hose is fire rated to ISO 15540/41 (30mins at 800°C), which exceeds that of BS 7840 (2.5mins at 600°C) why isn't this class of hose included in the BSS 'Approved List'?

NABSE comment - In addition to the specific comment at 2.2.3 above, consideration should also be given to publishing the detail of all fuel hose data held by the BSS Office in a Tech Note / Appendix to the ECP's to cut down the number of phone calls / emails to the BSS Office on 'case-by-case' basis

2.10.1

2.10.2

2.10.3

2.10.4

NABO - All this section is specifically about fuel lines. The change to this ECP introduces the term "on-engine hoses" and the change is understood.

However, there can be many types of on-engine hoses including, water cooling, air, vacuum and breather hoses. The use of the word "fuel" is not consistent throughout the ECPs, and omitted in the text with the term "on engine pipes". "Fuel" should either be used everywhere, or omitted in the text and reliance placed on the title of the section. This is to protect against overzealous examining.

2.10.1

NABSE observation - The proposed amended CLI title does not align with that proposed for 2.10.2 The cited applicability (reproduced below) primarily focuses on the instance where a boat owner has made a temporary repair to a high pressure (diesel) metallic fuel pipe by use of a non-metallic line (which has become a 'permanent' repair). Applicability - to incorporate agreement from BSSTC Meeting #32 addressing a significant potential risk of failure of high-pressure diesel fuel lines. The impact assessment is that this will affect perhaps one or two boat hose in this application will be unreasonably be relying upon a 'get-me-home' temporary fix of a injector pipe fracture. The risk assessment is the change is necessary to address the potential for diesel spray over a hot engine leading to a fire (GR 1).  Once again, a broad application CLI has been 'tinkered' with to address a SPECIFIC issue whose risk quotient was judged by the BSSTC to be significant. The issue here is clear - ONE of the checks the Examiner needs to confirm is that fuel LINES between diesel injection pumps and injectors are of a composition that is suitable for the fuel pressures present in this environment! Furthermore, the statement: The risk assessment is the change potential for diesel spray over a hot engine leading to a fire (GR 1).   acknowledges that a fire risk is present and therefore makes a mockery of the proposed deletion of the requirement to lag / shield exhaust components at CLI 2.15.2.

NABSE comment - For continuity with 2.10.2, amend title to read: Are all rigid fuel feed, and return and on-engine pipes lines made of suitable materials? Two (related) issues exist here - the need to recognise and act on:

• The discovery of a 'temporary' fix to a diesel HP injector pipe effected by fuel hose (presumably secured by worm drive clips).

The acceptability of HP injector lines being implemented in HP hose (eg: SAE 100 / EN 853). Before this ECP change proposal is ratified, this issue must be re-addressed by the BSSTC. Additionally, the rationale supporting the proposal to delete the requirement to lag / shield exhaust components at CLI 2.15.2 needs be re-assessed as it exposes the fact that the risk methodology /analysis methods employed by the BSSTC are flawed. Have the hull insurers' been consulted on this proposed amendment ? If not does the BSS Office believe that they (the insurers') would agree with the fact that an opportunity for sensible risk mitigation (exhaust lagging / shielding) has been deleted by the BSS (on behalf of the participating Navigation Authorities) thereby nullifying the overall objective of the CLI and opening the door to both 1st and 3rd   party claims ?

2.10.2

NABSE observation -

1st Applicability - hoses marked to SAE J 1527, and DIN 4798 or RINA DIP/66/96 are acceptable. While the need to incorporate the statement in TN01.06.ECP01 (RINA DIP/66/96 hoses) is understood, there are many instances of telephone calls from Examiners seeking advice on the acceptability of specific on-engine fuel hoses. If the BSS Office holds a database on these hoses, should this information not be published in the ECPs (as an Appendix ?).

New 5th Applicability - - the nylon type fuel hose material connecting small capacity diesel containers to the cold start facility on older diesel engines should be considered as exempt from this requirement.

In this context, what does 'small capacity diesel containers' mean ?

NABSE comment -

1st Applicability - In addition to the comments at 2.2.1 which also apply in this instance, if the BSS Office holds a database of specific on-engine fuel hoses (including those certified by the USCG), can this information be published in the ECPs (as an Appendix ?).

New 5th Applicability - This CLI amendment should include an indication of maximum permitted tank capacity to reduce the number of phone calls to the Office to establish what constitutes a small capacity diesel container'.

2.10.4

NABSE observation - The Applicability states: 'pay particular attention to rotating engine components, sharp or hot engine and exhaust components, engine bearers and other vessel structures'. In relation to what criteria ?

NABSE comment - In addition to the comments at 2.2.1 which also apply in this instance, suggest that the wording of the Applicability be amended to read: 'pay particular attention to fuel hoses located in close proximity to rotating engine components, sharp or hot engine and exhaust components, engine bearers and other vessel structures'.  

2.11.1

NABSE observation - New 3rd Applicability - - the nylon type fuel hose material connecting small capacity diesel containers to the cold start facility on older diesel engines should be considered as exempt from this requirement. In this context, what does 'small capacity diesel containers' mean ?

NABSE comment - This CLI amendment should include an indication of maximum permitted tank capacity to reduce the number of phone calls to the Office to establish what constitutes a 'small capacity diesel container'.

2.11.3

BSS Office - The suggested checking action deletion needs to be slightly extended to be effective in removing the check for fuel leaks that is already published at 2.11.1.

The addition deletion is indicated by the yellow highlighted text - 'Check flexible fuel hose connections made with hose clips or clamps that can be seen and reached, assess their condition and look and feel for leaks.

2.12.3

NABSE observation - With the proposed deletion of 2.12.2 on the stated grounds, this remaining CLI concentrates purely on the fire resistant qualities of fuel filters. Should the opportunity not be taken to expand this CLI to specifically include devices such as stand alone water separators / agglomerators and combined filter / agglomerators (which are mandated for incorporation on diesel systems by BS EN ISO 10088:2001)?

NABSE comment - Because the majority of these devices can incorporate a glass or plastic sight-bowl, have the BSSTC performed a risk assessment in this regard ?

2.14.4

NABSE observation - The Applicability states: there is no requirement for examiners to dismantle the air filter to determine the nature of the filter element. The 2nd Rationale states: The impact assessment is that replacement gauze and pleated-'paper' filter elements are an inherent maintenance cost and only a tiny proportion of petrol boats will not have them fitted.  It is anticipated that between 10 - 20 boats per year subject to BSS examination may be affected. The risk assessment is that filters must have filter elements to be effective and that the change is necessary to address the potential for petrol backfire leading to a petrol vapour ignition and fire. (GR 1).

NABSE comment - The risk assessment in this critical safety area indicates: "... filters must have filter elements to be effective ..."  While this impact may be perceived to be lessened by estimating that the arising rate of the risk being realised is low (ie: 10 to 20 boats will not have a filter fitted), logic dictates that the Examiner must award an NV for every petrol engined boat with an enclosed air filter housing as he / she is unable to determine if a filter is present Is the BSSMC satisfied that the proposed amendment provides a credible solution to this high-impact problem ? Have the hull insurers' been consulted on this proposed amendment ? If not, does the BSS Office believe that they (the insurers') would agree with the fact that an opportunity for sensible

risk mitigation has been diluted by the BSS (on behalf of the participating Navigation Authorities) to a point where the overall objective of the CLI is nullified and opens the door to both 1st and 3rd party claims ?

2.15.3

NABSE observation - The Title of this new CLI does not align with:

• the content of the 'Checking items to be performed' box,

• the 'Requirements to be met for a pass' box,

• the Applicability or the Rationale in that aspects of a portable fuel system are included.

NABSE comment - Simply put, there is little-to-no justification for this (over-complicated) new CLI.; the requirements for Permanently installed fuel systems and fixed engines are addressed by Part 2; those for Outboard and portable combustion engines and portable fuel systems are addressed by Part 5. The composition of any 'interface' between fixed and portable fuel system is already contained within extant ECP's and is sufficient to manage all eventualities. The only 'embellishment' worthy of consideration is the provision of adequate cross-referencing between Part 2 and Part 5 (based upon the wording of the Applicability at ECP CLI 8.1.1)

2.17.1

BSS Office -the word 'standard' needs to be added to the check question, as follows:

Do the fuel supply arrangements to LPG-fuelled propulsion engines comply with UKLPG LPGA CoP 18 or equivalent standard, and are any dual-fuel petrol/LPG arrangements of an acceptable type?

 

Part 3 - Electrical systems

Part 3 General

NABSE via the web facility - The NABSE Partners wish to communicate to you their belief that the proposed changes to Part 3 regarding, particularly, the inspection of 230 Volts AC systems on boats will put Examiners in serious peril and, as currently proposed, may well be in breach of Statutory legislation. We would draw your attention to the Health & Safety at Work Act 1974 and the Electricity at Work Regulations 1989, particularly Regulation 14 and, for your guidance, page 6 of the Electricity Safety Council Best Practice Guide No 4 - Electrical installation condition reporting:

It is the NABSE Partners view that the proposed checks cannot be 'Advisory' and any dangerous situation discovered must be made safe at the time of the inspection. It is not satisfactory to simply make the owner (or their representative) aware of the danger because an agreement should be made with the client to make safe, normally through 'isolation' of any dangerous condition. 'Best Practice' also requires any faulty installation to be formally reported in writing through the use of a modified 'Warning Notice' along with the labelling of such installations to make it perfectly clear the 'Danger' is present even after isolation. The measures described are similar in many respects to the actions currently required by Section 7 ECP 7.12.2 (which are mandated by GSIUR Regulation 34)

For these reasons alone, the NABSE Partners believe the checks relating to 230 Volt AC systems cannot be 'Advisory' and must be mandatory and be complemented by a requirement for any identified problems to be made safe before the examination is concluded. We would therefore propose an urgent meeting with yourselves and the HSE to resolve our grave concerns on behalf of all BSS Examiners.

Finally, it is also our strong belief that to protect the examiner and client, all 230 Volt sources of supply must be isolated before any checks, including 'visuals' are undertaken as, at the time of the Examination an (as yet undiscovered) electrocution risk may be present on the craft. 'Live working' must be avoided at all times and is only permitted in the electrical industry when accompanied by an appropriately authorised 'Permit to Work' scheme

Part 3 General

Boat owner - To my mind the biggest risk of electrical fires is the way cables are threaded around gunwales and though bulkheads, with no protection from abrasion whatsoever. It is very simple, and fairly inexpensive to install all cable runs in plastic conduit, keeping of course 12/24v and 230v separate. This should at least be a recommendation in the BSS

Part 3 General

Marine trade representative - As time progresses & demand for 240v on boats increase daily, we see 100's of boat fitted with DIY 240volt shore supply systems. Some of which are 'very' dangerous (no earth) and normally we either disconnect or advise customer accordingly.240v systems can be more dangerous then household electrics so they should be under some sort of certification/testing. It's easy for you to introduce and will no doubt save a life in the future. Any questions let me know or survey of visiting boats let me know.

3.1.2

NABSE observation -

The requirement to apply light manual force to the batteries has been deleted from the 'Checking items to be performed' box despite the fact that the 'Requirements to be met for a pass' box states that "All batteries must be incapable of movement in excess of 10mm in any direction"" How is this 'incapability of movement' to be assessed ?

NABSE comment - By omitting the criterion to check for battery movement, the stated rationale fails to clarify the requirement. Amend wording in the 'Checking items to be performed' box to read:

  • 'Apply light manual force to all batteries, battery boxes, cradles, frameworks etc to verify the extent of possible movement'.

3.2.3

NABSE observation - These requirements are proposed to ensure the existence of a BALANCED requirement between ECP CLI's 3.2.3 and 3.3.1 in addition to recognising the fact that the item / object that caused the impact damage may / may not be present at the time of examination.

NABSE comment - The wording of bullet 2 and the last paragraph of the 'Requirements to be met for a pass' box should be amended to read:

  • signs of impact damage, chaffing, abrasion, broken strands or heat damage.''

New Applicability: 'Insulation and sheathing must show no signs of damage where cables pass through bulkheads or craft structure or deterioration caused by reaction with water or fuel.'

3.3.1

NABSE observation - Good design of cable support and / or containment systems will provide protection from mechanical damage (impact, abrasion or chaffing). To legislate against the possibility of impact damage from 'any structure' or 'item of equipment' is an uncontrolled variable for the Examiner to make judgement upon. If all cables were in containment (conduit), the impact / abrasion / chaffing risk would be minimised; however, such an imposition in impractical. For cables not in containment, they should be adequately supported by clipping at regular intervals and / or supported in adequately sized cable tray. The primary objective of this check should be to establish if the craft's cables are adequately supported (in terms of cable runs and through-bulkhead penetrations. Cable condition should addressed under ECP CLI 3.2.3. The wording of the second 'Applicability' paragraph is factually incorrect - the term 'double-insulated' only applies to electrical equipment (also referred to as Class II). The layer of insulation on a conductor (basic insulation) provides protection from electric shock and mechanical damage. Where multi-core cables employ a sheath (for support and mechanical protection) this layer does not 'double insulate' the cable because the material properties of the sheath are optimised against wear, abrasion, heat etc.

NABSE comment - Amend wording in the 'Checking items to be performed' box to read: 'Check the run of all cables which can be seen and confirm that they are supported along their length at regular) by surface clipping intervals (250mm horizontal and 400mm vertical *) or located and supported within adequately sized cable tray.' Alternatively, recommended clipping distances could be included under 'Advice for owners' (best practise). * Spacing as recommended by BS7671: 2008 (2011) OSG Appendix D Table D1. The wording of second 'Applicability' paragraph should be amended to read: 'Single core cables with basic insulation and no outer sheath should not pass through bulkheads and other structural members without additional protection - ie: grommets, sleeves. Where multiple core cables are enclosed in a sheath, the sheathing should be considered as adequate protection, providing the sheathing material is in good condition.'

3.4.1

NABSE observation - The wording of the new 2nd 'Applicability' states: 'Crocodile' type clips are not acceptable as battery connections for permanently installed cables' What evidence is available to indicate that the use of 'crocodile clips' contributes to the fire / explosion risk ? In cases where a craft has a permanently fitted (proprietary) battery charger / PV Panel which employs 'crocodile clip' terminations, are the charging leads regarded as ''permanently installed cables' ?

NABSE comment - The wording of the second 'Applicability' paragraph should be amended to read: ''Crocodile clips terminations on battery chargers / PV Panels are only acceptable where the battery charger / PV Panel (and all associated cables) are permanently installed.

3.5.1

NABSE observation - Firstly it should be noted that there is no distinction of fuse type for use in ac or dc final circuits. While it is generally accepted that the device trip current will be about the same for either ac or dc, the majority of 'domestic' ac breakers rely on the voltage passing through zero twice per cycle to extinguish the arc drawn between the contacts by the fault current as the breaker trips. By contrast, a dc arc is continuous and needs other means to extinguish the arc (larger contact spacing, blow out magnets that push the arc out sideways from the gap and into contact some heat absorbing insulation). For dc applications, the dc voltage rating and the maximum fault current that the breaker is guaranteed to interrupt may also be a lot lower than the ac voltage and fault current interrupt ratings. Accordingly, normal 'domestic' circuit breakers should not be used in dc final circuits. A dc circuit breaker should be specified such that the fault current and applied voltage of a particular final circuit fall within the selected specification of the selected devices specs. The objective is to install a circuit breaker not a fire starter!

The wording of the 1st 'Applicability' paragraph has been amended to specify dc systems only. From the fire safety perspective ac and dc systems are equally capable of hosting over-current conditions which, if not protected by some form of circuit protection could result in an electrical fire. REMEMBER that circuit protection devices (fuses, circuit breakers etc only protect circuits from over-current situations - they DO NOT PROVIDE ANY PROTECTION FROM ELECTRICAL SHOCK by automatic disconnection of supply ! Any final circuit whose cable size and associated protective device is not adequately designed can be a source of an electrical fire under short-circuit or over-current conditions. A new item in the 'Checking items to be performed' box has been introduced: 'Fuses and fuse wire must be rated not greater than any rating marked on the fuse holder'

By contrast, the new 2nd 'Applicability' states: 'examiners are not to remove/unscrew fuses or fuse wire holders or remove circuit breakers. The checking action for fuses and circuit breakers which cannot be seen without their removal should be confined to the checks for completeness and condition'. The 'Advice for owners' provides a blanket recommendation to fit an RCD: 'to provide appropriate electric shock protection on ac systems'.

NABSE comment - The title should be amended to read: Are all fuses and circuit breakers fitted to the craft appropriately rated, complete and in good condition ?

The Second bullet point in the 'Requirements to be met for a pass' - ie:

• rated less than the current carrying capacity of the cable protected and; should be re-instated as this is the PRIMARY REASON FOR THE INCLUSION OF A CIRCUIT PROTECTIVE DEVICE (ac or dc application). These 2 statements are contradictory. How can the examiner establish if the fuse / fuse wire is correctly rated or even contains a fuse / fuse wire (as opposed to a nail) if the examiner is not permitted to remove or unscrew the fuse/fuse carrier ? As written, the checks will only establish if the fuse holder / circuit breaker is complete / incomplete and in good / poor condition.

While the cited amendments may 'help ensure examiner safety' they do very little to establish the absence of problems that could result in an electrical fire. For example, how should an Examiner deal with a 600W inverter mounted within a galley base unit whose only purpose is to provide an ac supply to power the 230v igniters on a cooker / hob ? Should this configuration be regarded as an ac system ? What if this is the only ac item aboard the craft ? If found, should the output from such an inverter be fed via a consumer unit (equipped with an RCD) ?

For completeness (and to assist with such a quandary), the glossary of terms needs definitions for:

• an electrical system

• ac system

• dc system

3.5.2

NABSE observation - While the title for this ECP CLI asks if the items listed are 'complete', this requirement is not tested in the 'Checking items to be performed' or the 'Requirements to be met for a pass' box' and is limited to checking for the presence of a lid or cover. While the check concentrates on enclosures designed to have a cover or lid which must be fitted to prevent / contain the travel of molten metal from a ruptured fuse, the check should also encompass the safe enclosure of inline fuse holders of the automotive type and those housing midi and mega fuse types - why are they not specifically considered ? What if a mega fuse holder is discovered within a battery box ? In the case of a rupture at cranking current rates, what risk analysis has been performed for such a situation when combined with a 'gassing' battery ? While the 'Applicability' box states that this CLI is for both ac and dc supplies, there is insufficient acknowledgement of the risks involved in relation to the 'completeness' of ac consumer units. From the ac electrical safety perspective, BS 7671:2008 2011 requires that all 'enclosures' - eg: consumer units must be 'complete' (eg: 'knock-outs' must not be missing as they fail to meet IP4X in that a person could access and touch a live conductor)

NABSE comment - The 'Requirements to be met for a pass' box should acknowledge that the checking criteria for dc fuse panels, boxes, holders and dc consumer / distribution boxes do not attract the same level of personal safety risks associated with ac consumer units. Accordingly, this aspect should be re-written as follows: All dc fuse panels, boxes, holders and dc distribution units incorporating fuse holders and circuit breakers should:

• be complete (including covers / lids where provided).

• be free from signs of deterioration, heat damage and physical damage'

All consumer units used for ac distribution must:

• be complete and free from signs of physical damage, heat damage and deterioration.

• have no open cable access points ('knock-outs') - if present,

Appendix A action is to be taken.

• be marked with a label indicating the system voltage ie: 230 V ac or 230 V 50Hz.

New applicability: Mega fuse holders are not to be located within battery boxes.

3.6.1

NABSE observation - See rationale in 3.6.2 below.

NABSE comment - The title of this CLI should be amended to read: 'Are isolators fitted to all sources of dc energy and are they fitted as close as possible to said source(s) of energy ?'

3.6.2

NABSE observation - The amended CLI has become cluttered by the mixing of sources of energy (PV panels, wind turbines) within the list of current taking equipment. Because there is the possibility that multiple sources of dc energy are fitted to a craft, consideration should be given to the introduction of a new title of this CLI which should make specific reference to dc sources of energy as it the source of energy that is isolated not the circuit being supplied.

NABSE comment - Re-word title to read: 'Is there a facility to isolate all sources of dc energy from the craft's dc electrical circuits while still ensuring that those services which require a continuous supply are alternatively protected ?'

3.6.4

NABSE observation - The wording of bullet 2 and the last paragraph of the 'Requirements to be met for a pass' box has been amended to remove the words: 'heat damage indicating an inability to carry the maximum current of the circuit.' Evidence of heat damage to an electrical / electronic component is invariably a pre-cursor to a (albeit localised) electrical fire. Such evidence should not be ignored !

NABSE comment - The wording of bullet 2 and the last paragraph of the 'Requirements to be met for a pass' box should be amended to read:

be free from signs of deterioration, heat damage and physical damage.'

3.8.1

NABSE observation - The whole objective of this CLI is to ensure that the craft employs electrical connectors suitable for use in conditions WHERE THE EFFECTS OF WATER WILL NOT IMPINGE ON PERSONAL SAFETY. While the argument regarding identification of a connector by its design standard (BS EN 60309 / equivalent) is accepted (primarily because identification by this means is largely not consistent), connector types of the class required are always externally marked with their IP Rating. To ensure the availability of adequate 1st and 3rd party personal safety, craft must employ (appliance inlet) connectors rated at IPX4 (or better). The amended words at ECP CLI 3.8.1 state: "Shore power and battery charging inlet connections must be of suitable proprietary manufacture and must be a plug (male) type" and "Shore power and battery charging inlet connections not obviously splash proof must not be located where they are likely to be subject to the weather / splashing"

NABSE comment - This CLI should be remain extant and be re-written without any reference to the design standard (BS EN 60309).and include sufficient words to signify the relevance of the connector's IP rating. (as stated in TN02.07 ECP01)

It is not appropriate for the Examiner to decide if a connector is "of suitable proprietary manufacture" It is not appropriate for the Examiner to decide if a connector is "not obviously splash proof". The availability of an externally-marked IP rating will provide the necessary assurance of compliance.

3.8.1

NABO - In the rationale for 3.8.1 you state that in moving away from BS EN 60309 that "instead reliance is placed upon products encountered being assessed as of 'suitable proprietary manufacture'. Expected markings can be covered in training and reference material"    Under the concept of a 'level playing field' the reference material and any assessments should also be made available to the boat owners who have to ensure compliance for the other 3 years 364 days.

3.8.1

3.8.2

3.8.3

NABO - Although these checks are currently advisory, the 'Applicability' suggests that if a shore connection cable is not presented to the examiner it is entered as 'not verified' and therefore an advisory failure. This is not a good situation. There should not be a requirement that there is a shore connection cable, only that complies if it is present. I equate this to the MOT rule about spare car tires, where you cannot fail for not having one.

In the applicability for these checks there is the statement 'do not disconnect shore power or battery charging leads, but if present the owner should be invited to etc.' I do not understand the purpose of this statement and think it will lead to misinterpretation. What if the owner does not wish to disconnect or the owner is not present? We have not said why disconnection is required and I cannot see a reason why it should be. I do not think it right that failure to disconnect is implying that an examination should stop. I suggest to delete the statement(s).

3.8.1

3.8.2

3.8.3

NABSE observation - See comments at 3.4.3 ...PLUS The new 2nd 'Applicability' states: 'if an obvious risk of electrocution is determined take the actions described in Appendix A' This is a classic case of the old electrician's joke: Question - "what is black and crispy and hangs from a ceiling fitting ?" Answer - " An electrician who failed to isolate the supply !" The risk methodology applied to this ECP amendment is FATALLY flawed (PUN INTENDED !). What interpretation / logic is the Examiner to apply to the proposed statement: 'if an obvious risk of electrocution is determined Noticing a non-energised exposed conductor is entirely different to discovering a LIVE exposed conductor. For everybody's benefit, the Examiner (whether accompanied by the owner or not) MUST disconnect any shore power or battery charging connection from the source of supply BEFORE boarding the craft !

NABSE comment - THIS PARTICULAR ECP CLI AMENDMENT WILL BE DISCUSSED BY NABSE AND THE HSE. PENDING THE OUTCOME OF THIS DISCUSSION ,  NABSE WILL OFFER NO FURTHER COMMENT ON THIS PARTICULAR PROPOSAL

3.9.1

NABSE observation - If a 'source of electrocution' is present, what level of risk is present if:

•  the Examiner fails to recognise / identify an 'additional power source' ?

• the 'selection' of an alternative power source is automatic ?

NABSE comment - THIS PARTICULAR ECP CLI AMENDMENT WILL BE DISCUSSED BY NABSE AND THE HSE. PENDING THE OUTCOME OF THIS DISCUSSION ,  NABSE WILL OFFER NO FURTHER COMMENT ON THIS PARTICULAR PROPOSAL

3.9.2

Unknown - I do not see the need for a consumer unit where the only means of power is through a single shore line 16A connector that is fed from a 16A industrial socket to a 13 A RCB outlet within the boat where all supply connections in the boat come from the 13A socket via a B 13A plug with fitted fuse.

The supply comes from a IET wiring regulation compliant shore supply which provides for a 16 supply via a ELCB. As written the requirement indicates that a consumer unit or additional incoming circuit protection needs to be fitted.

3.9.2

Professional marine surveyor/BSS examiner - Shore Power thru consumer unit. I have experience of a boat (built under RCD) that was 100% 240-v shore power. It was 4 years old and the hull was disintegrating due to residual current problems. I such cases should BSS not be recommending the fitting of other units such as a galvanic isolator. Those fitted in the BW pedestals are doubtful at best.

 

Part 5 - Outboard and portable combustion engines and portable fuel systems

Part 5 General

NABSE via the web facility - Please see our previous submission. for 8.1.2 read 8.1.1

5.1.1

5.1.2

NABSE observation comment - The 'Crossover Project' report appears to overly-complicate the issue. Fixed or permanently installed fuel supplies are adequately covered by Part 2 and portable fuel systems are also adequately covered by Part 5. A totally adequate set of words (used for cross-referencing between Parts 2, 3 and 7 already exists under the Applicability of ECP CLI 8.1.1) and these should be adopted to 'bridge' between Part 2 and Part 5 in regard to 'hybrid' fuel systems. Regardless of how the words / cross-referencing are constructed (fixed / portable or portable / fixed), the demarcation point that needs to be covered in Parts 2 & 5 and / or Parts 5 & 2 relates simply to the transition method from one fuel system to the other. The Examiner should only be concerned about the realisation of this transition - ie: does it configured from proprietary manufactured component(s) or is it engineered from acceptable components and is it installed in a manner that is compliant with extant ECP CLI's ?

 

Part 6 - Fire extinguishing and escape

Part 6 General

Private individual - The current document still refers to BS5306-3:2003. This has been BS5306-3:2009 for 3 years. Others may also have changed! The current document states "The requirements in this chapter have been informed by, and may refer to, the following technical references, codes and regulations".

BS5306-3:2009 at clause 4 now requires extinguishers to be commissioned as documented within the standard with a clear requirement that "Upon completion of the above procedures the extinguisher should then be installed and positioned in accordance with BS 5306-8".

The March 2012 draft for the revision of BS 5306-8 at 8.4.2 Minimum quantities of class C extinguishers required "None are required unless a trained fire-fighter is available (see 8.4.1)". Additionally, at 5.4.3 Use of powder extinguishers "The discharge of a powder extinguisher can cause a sudden reduction of visibility, which could temporarily jeopardize escape, rescue or other emergency action. For this reason water-based extinguishers should ideally be specified for use indoors".

To what extent will the revised BSS document be "informed by" these requirements? The visibility issue is especially relevant for narrowboats let alone the health risk implications for individuals with breathing related and /or mobility challenges in narrowboats which readily available / accessible to such individuals. Has the continued use of powder extinguishers in boats been fully risk assessed in the light of proposed changes to BS5306-8?

Could a Class F extinguisher be an alternative to a fire blanket and should fire blankets be Kitemarked or similar as are extinguishers?

Why are extinguishers on boats exempt from periodic (e.g. monthly) inspections by the user per BS5306-3:2009 at Clause 5 - Visual inspection by the responsible person.

"The responsible person should carry out visual inspections of all extinguishers regularly. These visual inspections should be carried out at least monthly. When circumstances require, inspections should be carried out more frequently". (The owner or boatyard being the responsible person and inspections could be recorded in a log created for this purpose). Nor are they required to undergo an annual service to BS5306-3:2009 by a competent person per manufacturer instructions e.g. for Chubb Fire product: "Extinguisher is to be installed and serviced in accordance with BS5306 Part 3 and Part 8" since failure to do so will invalidate any manufacturer warranty or claim for BSEN3 compliance.

Finally, Firemaster 1000PR B/C [Brass/Chrome] models marked without the 'Kitemark' have not been manufactured since the business was sold some years ago and thus no longer have manufacturer support and will almost certainly will have exceeded age requirements for continued suitability.

 

Part 7 - LPG installations

7.2.1

NABSE observation - The 'Checking action to be performed' box contains the words: 'Check the height of the LPG cylinder locker sides' 5th Applicability states: hatches and any similar temporary openings, however constructed or sealed, are not permitted within the area of LPG cylinder lockers and housings covered by this check. The LPG tightness Note that the BSS compliance of side-opening cylinder lockers compliant with ISO 10239 is covered at 7.2.3

NABSE comment - The term 'check' means 'measure' or 'compare to a known figure'. To ensure that the Examiner is presented with clear and unambiguous guidance, the intention of the first 2 paragraphs of the 'Checking action to be performed' should be combined thus: 'Visually determine that the sides of every cylinder locker extend above the height of the cylinder valves /high pressure components (whichever are located highest)'.

While it is appropriate to focus on the 'gas tightness' of any hatches or temporary opening found within the walls / floor of a gas locker, how should the Examiner react when finding a closure plate (especially in larger craft where access to another compartment / part of the craft's hull is achieved via an aspect of structure whose fit / removal is strictly controlled) ?

Suggest that the 5th Applicability be expanded to state: Gas lockers that contain a closure plate must be recorded as 'not verified' on the BSS Checklist, and it must be considered that the check has not been completed until such time as the status of the identified closure plate has been verified'.

7.3.5

BSS Office -the word 'hose' needs to be replaced by 'drain line' in the 3rd paragraph of the checking section, as follows:

'Where connections can be reached, pull using light manual force to check security of all drain line hose connections'.

7.3.5

NABSE observation - In addition to checking for the presence of any perforation in the craft's gas locker at ECP CLI 7.2.1 that would permit the passage of leaked LPG to the interior of the craft, does the BSSTC agree that the risk weighting of the integrity of the locker drain line is equal to that of locker structural integrity ? Unlike the information provided within the BSS Essential Guide (below), nowhere within this ECP CLI is there any requirement to establish the type of material that constitutes the drain line.

EG Ch 7 Page 12: Best practice We recommend you to fit, whenever possible, drain hose that complies with a recognised standard such as ISO 7840 for fire resistance or BS 3212 for LPG.

NABSE comment - While the ECP suggests that the Examiner may introduce fluid into the drain line to establish that it is 'free of blockage', what about the circumstances where the integrity of the drain line(s) is / are compromised thereby allowing a leaking drain line to deliver leaking LPG into the body of the craft ? This ECP proposal (along with ECP CLI 7.3.5) should be reconsidered by the BSSTC and an enhanced check formulated to mitigate against this previously unaddressed risk. Suggest that this enhanced check should include direction along the lines of: 'Where gas locker drain lines can be seen and reached, check for signs of deterioration. Where doubt exists, water should be introduced (with the owner's permission) into the gas locker to establish the integrity of the drain line'.

7.4.1

NABSE observation - The proposed change to the 1st item in the 'Requirements to be met for a pass' box states: The extent of any LPG cylinder movement must not cause any pulling of pipework or pulling tight of hose connections.

NABSE comment - The proposed wording is amateur. In engineering descriptive terms, 'pulling' = strain, and where strain is present, movement can occur. To reflect these fundamentals, the wording of the 1st item in the 'Requirements to be met for a pass' box should be amended to read:

'The extent of any LPG cylinder movement must not cause any associated movement of any connected pipework or strain on any connected HP pigtails or LP hoses'.

7.8.4

NABSE observation - The wording of the new 2nd 'Applicability' uses the term 'mounting plates'. The correct term for such 'integral fixings' is 'mounting foot'.

NABSE comment -  The wording of the new 2nd 'Applicability' should be amended to read: 'Bulkhead fittings and / or 'LPG joints / fittings with an integral mounting foot can be considered as meeting this requirement. The pipework adjacent to such fittings / joints does not need to be provided with additional securing fixing within 150mm of each joint connection.'

7.9.1

NABSE observation - Because the title of this ECP CLI now focuses on Low Pressure LPG hoses, the second bullet point in the 'Requirements to be met for a pass' box should reflect the applicability for both BS 3212 Type 1 and Type 2 hose.

NABSE comment - The second bullet point in the 'Requirements to be met for a pass' box should be amended to read: • Must be marked to BS 3212 Type 1, Type 2 or equivalent.

7.10.1

NABSE observation - This ECP change proposal changes what was a somewhat generic location (and therefore practically implementable) to a very specific point which, by default, introduces non-implementable restrictions (in terms of compliance with ECP CLI's 7.11.3 and 7.11.1) viz: ECP CLI 7.11,3 'Requirements to be met for a pass' box states: Appliance isolation valves or the means of operating the valves, must be readily accessible. If, as suggested by the proposed change, the isolation valve is to be fitted at the connection point to the appliance this means that isolation valves will be directly attached to hob gas rails or oven inlet points . However, this specific guidance is virtually negated by the 2nd 'Applicability' of ECP CLI 7.11.1: - ease of access takes precedence over the requirement for the valve to be located at the connection to the supply line.

NABSE comment - ECP CLI's 7.11.1 and 7.11.3 need to be re-written to present a practical, consistent and unambiguous message regarding the location of appliance isolation valves.

7.11.1

NABSE observation - In addition to the comments provided at 7.10.1, this ECP CLI contains a long-standing anomaly that needs to be addressed viz: The 1st Applicability states: '- for an installation with a single appliance connected by a hose the cylinder valve may be classed as the appliance isolation valve' If the craft only has one appliance fitted, the above applicability can be applied literally. However, if a craft has 3 appliances fitted (hob, oven / grill) and say an ALDE boiler, if the hob was connected by a flexible hose (and the oven / grill and the ALDE were hard piped) the craft would still only have 'a single appliance connected by a hose As currently written, the 1st applicability provides an arguable contradiction to the baseline requirement because, in the case cited above, this single hose-connected appliance does not need an isolation valve !

NABSE comment - To address this issue, the 1st   Applicability needs to be re-written as follows: '- for a craft with only one LPG appliance fitted and where that appliance is connected by a hose alone, the cylinder valve may be classed as the appliance isolation valve'.

 

Part 8 - Cooking, heating, refrigerating and lighting appliances

8.4.1

NABSE observation - The 'Requirements to be met for a pass' box states Appliances and all their surrounding surfaces must not show signs of:

• scorching, blistering or discolouration; or,

fuel leakage; or,

smoke or soot deposits; or,

• heat damage or deterioration to appliance structure

On the assumption that the Examiner fails the craft on one (or more) of the highlighted visual indicators, what approach should the Examiner take on a re-examination if the root cause of the problem has been 'cosmetically' addressed - eg:  The 'discoloration' on a cabin head lining has been sanded down and re-varnished or repainted. The 'evidence' of discolouration has gone but what about the cause ?  The ' fuel leakage' has been 'dried up' sufficiently to comply at the time of re-examination but no attempt has been made to rectify the cause of the leak. What if the fuel leak has stained the flooring beneath the appliance - should the Examiner be expected to decide if a fuel stain is old or new or should the owner be required to replace the contaminated flooring to achieve compliance ?  The 'smoke or soot deposits' have been wiped off the appliance cover / surrounding area - if a gas appliance, this could be a developing CO problem (but, as yet, of insufficient magnitude to affect flame pattern and only likely to be detected by a CPA).

NABSE comment - While visual indicators of past (or emerging) problems are valuable, in many cases, the owner can effect a very simple 'cure' that addresses the 'problem' but does nothing to address the cause. In such cases the applied risk mitigation intent has failed its purpose. To improve the quality of this ECP CLI , the wording needs to be re-cast to ensure that the Examiner is satisfied (on re-examination) that the owner has adequately addressed the cause of the reported noncompliance (and has truly de-risked the situation)..Training clearly has a part to play as interpretation is clearly an issue.

8.8.1

NABSE observation - The newly introduced 'Examiner Action' is inappropriately positioned within the CLI and has the potential to jeopardise the safety of the Examiner conducting this check.

NABSE comment - The intention of the proposed 'Examiner action' should be transposed into a new first action in the 'Checking action to be performed' box as follows: 'If open flued appliances are fitted, perform the checks at 8.10.2 and 8.10.3 before lighting any open flued appliance burner(s)'.

8.9.1

NABSE observation - The 'Checking action to be performed' box contains the words: Confirm that the total effective area of fixed ventilation area (at least up to the calculated fixed ventilation requirement) is divided as equally as practicable between high and low level. What does the phrase (at least up to the calculated fixed ventilation requirement) actually mean ? The first and second bulleted additions to the 3rd   Applicability are meant to be definitions of 'a significant shortfall' (in fixed ventilation):

• where the total effective area of fixed ventilation is 50%, or less, of the calculated fixed ventilation requirement; or,

• where the total effective area of fixed ventilation is less than the calculated fixed ventilation requirement for continuous-burning appliances; or, However, the wording of the second bullet provides more confusion than clarity in relation to the fact that it has little to no bearing on the definition of 'a significant shortfall' (in fixed ventilation).

NABSE comment - Excess ventilation present on the craft (however divided between high and low levels) is simply excess. Accordingly, the requirement should be re-worded (for clarity of purpose) or deleted to avoid unnecessary interpretation. While the original wording (for the second requirement) could be reemployed here viz;

• where the total effective area of fixed ventilation is 50%, or less, of the calculated fixed ventilation requirement; or,

• where there is ANY shortfall in the calculated fixed ventilation requirement for continuous burning appliances; or, A much more robust solution would be provided via a stand-alone requirement for 'continuous burning appliances' (to de-conflict and avoid confusion with the 50% criteria).

8.10.5

NABSE observation - If an 'unintended' gap exists in a surface, seam or opening of an operating SFA, checking with a smoke match / pencil will reveal that the smoke will be drawn into the appliance. If an 'unintended' gap (or a broken door glass) is found during the examination of a non-operating SFA, what action should the Examiner take ? (because the CLI does not provide guidance as to reporting / recording of this 'Advice' failure point)

NABSE comment - If the intention of the SFA risk review was to primarily mitigate against the effects of CO, perhaps more emphasis on the impact of an unswept SFA flue (which has a direct effect on combustion efficiency and CO production) should be included in ECP CLI 8.10.2 ?

 

Part 9 - Pollution prevention

9.1.2

Marine trade representative - Over the many years of marine engine design its very common for engine & gearbox oil coolers to be fitted in the raw coolant water circuit (heat exchanger cooled engines).

These can often fail, especially on the older boats and as the oil pressure is greater than the water pressure, this will cause the entire oil capacity (engine or gearbox oil) to leave the engine via the exhaust system.

This then contaminates the waterways, and as its a thick oil its much worse then a small diesel leak for birds & wildlife.

Keel cooled engines do not have the problem. The only way to stop this is to fit a 'bilge type filter' in the circuit or modify the engine to suit. However, cooling the oil is important so many engine manufacturers would find it impossible to modify.

9.2.1

Boat owner - Currently, discharge from toilet to river is allowed on the Great Ouse system. The wording of the requirements does not seem to include this exemption.

End of table

The BSS responses to these submitted comments can be read in this pdf download (186kb)