Non-conformities

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What and how much?

Engine

The most serious potential non-conformity relates to engine emissions.  If certification for gas emissions does not exist then the options are:

  • replace with a new or recent engine for which emissions certification does exist.  Preferably an engine with a CE mark from the engine manufacturer
  • replace with an engine of similar/same specification which was supplied new to its first owner, within the EEA.  We're talking about a specific engine, not engines of a type which may have been resold in the EEA.  So if you find a used engine from a boat originally sold to its first owner in the EEA and you have evidence of this, then this may work.

Exhaust

If the drive unit does not have an integral exhaust (as found on most sterndrives) then for high speed craft a noise test will be required.  If noise falls outside the specified limits then action must be taken, for example fitment of mufflers, to achieve compliance.  Where a craft is fitted with 'Captains Choice', allowing the exhaust routing to switch between the drive leg and straight through exhaust, this must be disabled to prevent the use of the straight through exhaust (unless sufficiently quiet).

Pumped Outlets

Should be fitted with non-return valves.  This includes electric bilge pumps and sump box outlets.  Note that outlet hoses will be imperial size (ie diameter measured in inches not mm) and may range in size between manufacturers.  Common sizes are 3/4" (Bayliner), 1" and 1 1/8" (Monterey).  1 1/8" fittings are difficult to source in the EU (so get the seller to put some aboard in the US).  Non-return valves are approx EUR 7-12 each, plus jubilee clips.

Manual Bilge Pump

To be fitted by the helm (in theory to allow pumping and steering at the same time).  Inlet hoses to be fitted with a strainer.  Outlet hoses can use a separate skin fitting, or be joined to the outlet hose for an existing (electric) pump (joined outboard of non-return valve).  We use Whale Smartbail pumps with an integral handle (lid).  These are typically EUR 65 and require a 5.25" cutout.  These use 1" diameter hose, preferably reinforced to ensure that bends do not affect the flow.  Plastic outlet fittings (for topside) are remarkably cheap at approx EUR 3-5 and often fit a range of hose sizes.  In contrast, note that reducers (to enable say a 1" hose to connect to a 1 1/8" hose) are unbelievably expensive (EUR 15 each), so best avoided.

Fire Extinguishers

Though not strictly covered by the RCD there is a legal requirement for a boat owner to ensure that a craft is adequately protected before going to sea (so the effect is the same).  Typically, 1.5Kg (type 5A/24B) portable Powder extinguishers close to helm and in cabin space plus a suitably sized fixed automatic (preferably gas) extinguisher in the engine room space.  Where a boat is fitted with an existing Halon (1301) system this can remain if charged but must be replaced if discharged (as it is illegal to recharge within the EEA).  Portable extinguishers are cheap at about EUR 20 each.  Fixed gas extinguishers will range from EUR 200 upwards depending on capacity (we will advise).

Engine Space Insulation

Some older craft (<2003) may have absorbant sound insulation, commonly referred to as 'egg-box insulation' due to the nature of the surface pattern.  This insulation can absorb flamable liquids and is no loinger accepted for use in engine spaces.  Such insulation must be removed and replaced with a faced (eg foil faced) non-absorbant insulation material.

Separation of AC / DC Panel Boards

Where AC and DC wiring shares the same space, a barrier or partition must be fitted to prevent loose wires crossing between AC and DC supplies.  IN most cases it is common to find a backing box on the AC panel or if side by side a non-conductive partition between the panels.  In some cases (eg Glastron) this is not the case, even on late model boats and where not present this must be fitted.

Battery Isolation Devices

Each 12v DC battery must be connected to a battery isolator.  Some smaller boats don't come with these fitted from the factory.  Where always-on circuits exist (eg auto bilge pump, blower overun and stereo memory) these are normally connected directly to the battery, protected by suitable fuses/breakers.

Labels

For boats with petrol engines a 'Petrol Only' (or similar) label by the fuel filler (which will say 'GAS').  There may be other labels relating to watertight hatches, concealed extinguishers etc but we will identify and suplly as required.

Fuel Hoses

Generally not a problem.  Filler hoses are normally ISO 7840 A2 with supply and vent hoses ISO 7840 A1.  Often the hoses will also carry a CE mark.  It's in your interests to ensure the hose is up to the job.

Bilge Pump Hoses

As with fuel hoses, the bilge pump hose should be of a type which is both resistant to chemicals/heat and fit for purpose.  By this we mean unlikely to kink and thus restrict flow.  Clear plastic hoses with a string strengthener are not suitable nor are any hoses on the suction side which are likely to collapse in use (thus restricting flow).

Overboard Waste Discharge

It is a requirement that it be possible to prevent overboard discharge by locking closed a valve in the system, either a Y valve or the bilge valve.  Locking means being able to place a sealed tie such that to open would break the seal.  Some countries now ban the overboard discharge of waste and it is for this reason this requirement exists.  Electronic means of restricting discharge (eg key in control panel) are not sufficient.  remember the valve must be locked closed, not just closeable.

Overboard Cockpit Drains

Not a common issue, especially for Category C.  There are however instances where the volume of water contained within a cockpit (if drenched) cannot drain within the required time (calculated).  In such cases larger or more drains must be fitted.  This applies especially to sailing yachts with self-draining cockpits.

LPG

It is not allowable to store gas within the accomodation space, however small the container.  There have been some instances where craft (eg Sea Ray 260) have been fitted with stove units (Kenyan Kiss) fitted with an integral gas bottle.  These are not allowed and must be removed (typically replaced with a chopping board).

Gas (LPG) systems should be double checked by an approved Corgi engineer (UK) or equivalent.  Of all the dangers on a boat leaking gas is probably the most dangerous as the affect is immediate and uncontrollable.  Thankfully most US sports boats are not equipped with gas and rely on the significantly safer combination of AC power and Alchohol for cooker/stove use.  In reality, few people actually use either.

Other

120v AC circuits are accepted so long as installed correctly (as will be normally be the case with volume manufacturers).  Where a 230v AC conversion is planned it is important to note that the requirements may vary depending on whether the 230v source is only to supply a transformer, or is also used to supply additional 230v consumers (whether directly connected or via sockets).  We also strongly recommend the use of an ISOLATING transformer in preference to the cheaper yellow site transformers, often used.  Not only are the site transformers not designed for continuous loading, they provide no protection against earth leakage and galvanic corrosion.

There may be cases where hatches in the cockpit sole, which could lead to flooding if open may require the fitment of additional latches/bolts to make secure when underway.

Written By: Rowland Smith

Rowland Smith is a Naval Architect and founder of Gablemarine.  His industry experience includes Lloyds Register, British Shipbuilders Hydrodynamics Ltd, Cammell Lairds, BP Shipping Ltd & Conoco.  He has a degree in Naval Architecture, a Diploma in Marketing (CIM) and an MBA (Cranfield School of Management).  He has also held Director level positions in a number of technology and engineering companies, including CEproof, which provides RCD compliance software to builders. 

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