The Maritime & Coastguard Agency has requested comment by the Institution on its proposal for vessels operating in hours of darkness without a "permanent substantial enclosure".
By the MCA
There is a longstanding issue in the application of the Harmonised Code, in the context of vessels operating in the Category 3 without "permanent substantial enclosure".
It is quite obvious that the vessel will necessarily operate in hours of darkness but will not necessarily wish to operate to the limit of Category 3 operation at 20 miles. Beyond this broad statement there may be an identifiably "matrix of operational limitations" which can be relied upon to underpin the acceptance of such vessels for operation in hours of darkness without a "permanent substantial enclosure", and provide a consistence current lacking across all Certifying Authorities.
This issue has been the cause of much debate over the years and it is hoped the document "Acceptance Matrix for Restricted Category 3 without Permanent Substantial Enclosure" will provide an overarching structure or matrix within which "acceptance conditions" can be agreed. I hope the diagram is self explanatory. The nine coloured squares represent "operational limitation", divided into three ranges; up to 3 miles, up to 10 miles and up to 20 miles and into three "weather/seasonal" restrictions; "favourable weather/seasonal restriction", "favourable weather/no seasonal restrictions", "unrestricted weather/no seasonal restriction".
For discussion purposes, it is suggested that operation between 10 and 20 miles is "NOT Permitted"; Up to 10 miles and through the "weather/seasonal" restrictions increasing risk is indicated by the change in the background colour from green, through orange to red. "unrestricted weather/no seasonal restriction" up to 10 is "Not Permitted"
The text notation in each cell is indicative being shown in [square bracket], and is open for discussion.
The prime purpose of this issue is to establish whether the 3x3 matrix identified as described provides a reasonable framework to underpin yet to be identified "operational limitations". The "operational limitations" will be resolved at the second stage of the exercise but these will be a mix of prescriptive requirement and "risk assessed" requirement.
MCA would welcome comment on the proposal.
Small Craft Committee comments
1. The Harmonised Code under paragraph 4.5.1.2 states that inflatable or rigid inflatable boats may operate in Area Category 3 if fitted with ³a permanent substantial enclosure² subject to the approval of the Certifying Authority. But it also states that an alternative provision for enclosure may be considered with operational/seasonal limitations. We would suggest that perhaps better guidance should be given on the definition of what the MCA regard as ³permanent substantial enclosure².
2. We would suggest that the Acceptance Matrix appears to be over-complicated for what appears to be intended. The captions on the left and right of the Matrix do not appear to make sense in regard to the coloured blocks.
3. We would suggest that the restrictions would appear to be unduly onerous and we are not aware of any previous limitation requiring vessels to be twin screw. We would suggest that there are many single screw diesel water jet propelled RIBs operating commercially within the categories and it would be impossible to convert those vessels to twin screw.
MCA response
The issue here has been that for "247" operations up to 20 miles to sea the provision of the permenent substantial shelter for the protection the crew in the event of failure was considered appropriate by a drafting group representing all sector of the industry.
The provision of the matrix was exploring a frame work in which different levels of alternative could be considered and my request was whether the matrix provided a sensible framework. I note your response.
The distance limits were thought to be about right because they reflect types of service which are often the basis of enquiries. The weather, sea and seasonal limits are consistent with steps which exist in the regulatory framework.
The "coniditions" added to the blocks of the matrix were described as "indicative only". They were NOT firm proposals but do represent viable solutions.
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