1. Boats built before 1999 which do not have to comply with the Recreational Craft Directive (RCD);
2. Boats built subject to the RCD requirements that were built after 1999.

When Hurley a vessel is surveyed for insurance purposes the criteria of 'Best Practice' is applied. That is what is considered to be good practice by considering advice from Corgi and Calor Gas. This advice is not legally binding on vessels that are used in the sea as both Corgi and Calor Gas are private companies and their documents have not entered legislation. Also, your boat might have a Camping Gaz bottle.

Corgi and Calor Gas have helped create the much tighter regulations used for the Boat Safety Scheme which applies to boats used on the inland waterways.

The 'Best Practice' advice opted for by marine surveyors is largely based upon the advice given by Calor Gas and Corgi. It is a lot more detailed and demanding than what is actually required by the RCD standards. In my opinion standards of safety as regards to gas installations have been lowered since the introduction of the RCD. The RCD allows for British boat builders to build craft to a lower standard than they used to be. For example, Hurley boats were built to the Lloyds 100A standard. Bavaria Yachts of Germany used to be built to Deutsche Lloyds standards but Lloyds recently withdrew this award as standards of build had dropped.

The following is a brief list of details that a good gas system should include:

• The gas bottle should be stored, secured upright in a locker;
• The gas locker should be drained from the bottom and vented at the top outside the hull;
• The drain skin fitting should be at least 75mm above the waterline even when the vessel is healed over;
• The drain hose should have a continuous fall and be at least 19mm internal diameter;
• The gas locker should be dedicated for gas bottle use only;
• The flexible hose should be no longer than 1m. Copper pipe should be used, not flexible hose for longer runs;
• The gas bottle regulator and the join between the flexible hose at the bottle end and the copper pipe should be made within the gas bottle locker as if the gas system leaks it will most likely be at these points;
• The copper gas pipe should be secured to the vessels structure at intervals of no more than 300mm;
• The copper gas pipe should be protected by conduit where it goes through a bulkhead or piece of joinery to reduce fracture and chaff;
• Feeble hose should not be fed through a bulkhead;
• A gas shut off tap should be fitted into the galley if more than one gas appliance is present;
• Armoured flexible hose should be used at the cooker end if the cooker is gimbled to reduce chaffing.

The advice given by Corgi and Calor Gas go beyond the above as they advice fitting gas alarms and a bubble leak detector. Also, a Corgi registered gas fitter will not repair or install a cooker that does not have a flame failure device.

Some people disagree that armoured hose should be used at the cooker end as the rubber hose itself can't be seen.

A plastic after market gas bottle locker can be purchased from chandlery shops - Force 4 for example. They cost around £80 and can be fitted to most yacht cockpits. However, they are only useful for Camping Gaz bottles, as shorter bottles are needed to allow for a drop in the drain hose.

It is not always possible to fit a draining gas locker into boats, especially older yachts with low, deep cockpits and narrow transoms such as the Hurley 22 and 24. They were built without draining lockers and adding such a drain would cause problems in itself. The freeboard on older yachts is a lot lower than that of flat-bottomed beamy modern yachts. Many Westerly Centaurs and Pageants that I survey have a skin fitting fitted to the transom near to the waterline. This is usually a bit of an attempt to create a gas locker drain but is useless as the lazarette locker is deeper than the waterline and any spilt or escaped gas would just go into the bilge anyway. It is very problematic to fit aftermarket gas lockers into Pageants and Centaurs and it is my opinion best to leave as manufactured.
I recently inspected a Westerly Tiger, which had sunk on it mooring on the river Hamble. The only reason for the sinking that I could find was the feeble gas locker drain drilled into the transom about 1" above the waterline. The boat must have filled up slowly as ebbing tidewater lapped up its stern whilst on its fore and aft trot mooring.

You are able as a boat owner to repair, modify or repair your gas system and there are no rules about what qualifications you need to have if you work on private gas installations commercially. However, if you are paid to work on a gas system you have a duty in law to display a level of skill and knowledge, which usually means being Corgi registered.

The RCD (Recreational Craft Directive) is the standard that boats have to be built to be sold within the EU. It is a method of ensuring free trade between member states but has been compromised so often that its value of ensuring safety is debatable. Yachts and boats built outside of the EU must comply with the RCD standards and have to be inspected whilst being built or when they arrive in the EU.

The RCD is broken down into categories according to how the vessel should be used.

A: Ocean cruising/racing;
B: Offshore;
C; Coastal;
D; Inshore.

Boats within C and D categories can be self-certified by the builder and do not need to be inspected by a surveyor.
Surveyors are appointed by licensed bodies known as Notified Bodies. These Notified Bodies include the MCA and RYA.

Boats sold within the EU must have a certificate of compliance with the RCD and carry a plate in the cockpit stating that the vessel complies with Cat' A,B,C or D. The letters CE must be shown as should the registration number of the Notified Body that inspected it plus other info such as weight that can be carried and max number of passengers etc.

The RCD requirements themselves are broken up into standards. The standard appertaining to gas systems is EN ISO 10239. These standards should be available to the public at a modest fee but are in fact very expensive to get hold of. The RYA, MCA and BMF have joined forces recently to addressed this issue (supposedly) by launching a new website. This is to enable interested parties such as surveyors, boatbuilders, owners and brokers to gain easy access to all the standards in downloadable PDF form. It costs £400.00 per year to subscribe! Easy access? I think not!

The biggest grey area to me is that vessels built to category A or B only have to comply with local standards to be deemed to comply within the EU. For example, I recently surveyed an Italian luxury motorcruiser and found that its gas system fell short of complying with EN ISO 10239. After a great deal of debate between the vendor, purchaser, broker and importer of the vessel and after involving the BMF and RYA we came to the woolly conclusion that the vessels gas system satisfied the local gas regulations in Italy and as Italy was part of the EU the gas system of the yacht was deemed to comply within the rest of the EU. To me this is a scandalous farce and a loophole that has to be closed. This was a category B boat. The builders in my opinion were trying to cut corners and costs and took the easiest route that is the laxer Italian standards. The frustrating part was that no official body involved with the RCD would take ownership of the debate and give a definitive answer! I contacted the following organisations for advice but received nothing!

• BMF (British Marine Federation). Did not reply to phone call or email;
• RYA (Royal Yachting Association) Technical department - no reply to email or telephone message left;
• MCA (Maritime Coastguard Agency)

Quite rightly the broker and owner are not happy that the gas system needs to be changed, as this is how it was built. There are a few of these boats in the UK. The importer admitted that the gas system has had to be upgraded on boats used on inland waterways but none have been changed on sea going boats. I checked its RCD CE Mark certificate of compliance. The yacht was as manufactured and so is not technically at fault. The gas system has been revised on 2007 boats.

In my opinion the gas system failed for the following reasons:

• Gas locker drain was not fitted to bottom of locker;
• Gas bottle not strapped down;
• Gas locker was not airtight;
• Gas locker shared with electrical equipment such as 230-volt socket and fridge.

The gas pipes are all rubber. There is no copper section between. Apparently this is OK but you need to be able to access the hose along its entire length for inspection. The gas system does not need to have a copper pipe section according to the RCD.

I found out that the locker is not airtight when the water hose under the sink in the shared gas/cockpit locker broke and filled the cockpit with water. Water flowed through and under the door seal. I found loads of flammable stuff in the locker such as flares pack and meths. I recommended that the flexible hose be replaced by copper pipe. A short length of hose can be used at bottle end. An enclosed gas locker could be fitted inside the cockpit locker. The gas bottle should be strapped down and the new gas locker drain should be fitted to the bottom of the locker and not at 1" up the side.

According to the RCD it is permissible to have electrical items within the gas locker! Which was a big surprise to me! Also it is permissible to have hose longer than 1m as long as it is visible for inspection.

Clearly the RCD falls short of what we in the UK would consider to be good practice and falls a long way behind what is recommended by Corgi and Calor Gas. The problem is that the RCD is a method of breaking down barriers to trade within the EU. It is not intended as a method of ensuring safety. (my opinion).

Another area that I feel that we are being let down in as regards to the RCD is navigation lights. The standard that applies is ISO 16180 but this has not yet been ratified despite being published in 2003. That is to say there is no official RCD standard on navigation lights yet. I frequently get asked my opinion on LED lights when I suggest that navigation lights should be replaced if they are broken, cracked or crazed. LED lights are not yet included in the standard and are therefore not acceptable? So what happens if an owner of an older yacht replaces his crazed navigation lights (see MAIB report into the sinking of the yacht Ouzo) with new LED lights from a chandlery shop. Would an insurance company pay up if a collision occurred and the other vessels skipper said that he did not see the vessel and the LED lights were not of an 'approved type'?

Sorry if some of the above sounds like a bit of a rant but it should illustrate that there is no definitive standard as regards to private pleasure craft used on the sea. Insurance companies will accept recommendations from surveyors as being the bottom line. People often comment to me that the British marine industry is a bit shambolic. Yes I would agree with that as far a little legislation exists and there is no one particular body to oversee the industry. The RYA is voluntary, the BMF is a trade/marketing group paid for by its members and the MCA is dreadfully overstretched and mostly out of its depth.

The above applies to private yachts. Coding of yachts for commercial charter or sailing school use is a different matter.

Nick Vass
Marine Surveyor

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