Does a re-built craft need to comply with RCR?
In the early days of the RCD I, there was widespread belief that if a craft was altered to a point where it may be considered a different or new boat, then it should be put through the Directive in its new form. Most people subscribed to this interpretation but not all. Some said that the RCD is intended to harmonise trade and a substantially refitted/rebuilt boat is not in the new-build market. Thus, they said, such a boat is not intended to be in the scope of RCD, in just the same way as a home-built boat. Who was right?
Well, the 2006 amendment of RCD I included a new trigger point, a “major craft conversion”. RCD II and UK’s RCR now define this as follows:
‘major craft conversion’ means a conversion of a watercraft which changes the means of propulsion of the watercraft, involves a major engine modification, or alters the watercraft to such an extent that it may not meet the applicable essential safety and environmental requirements laid down in this Regulation/Directive;
This definition is notably different from the 2006 edition which did not make reference to essential requirements. So it is now the case that if the modification changes the way the boat or its systems operate, the boat must submit to RCR/RCD compliance again. Let us give some examples:
- Changing the crew limit, load limits or design category certainly requires the boat to undergo reassessment since these parameters are critical in the application of most essential requirements.
- Replacing components, electrical conductors, fuel hoses, steering ram, etc does not threaten non-compliance with the essential requirements since only the ‘freshness’ has changed and thus does not trigger reassessment.
- Rearranging and/or re-designing a (regulated) system (eg electrics, fuel, gas, steering etc) does bring the possibility for non-compliance and reassessment is necessary.
For further details, contact HPi-CEproof;.