The consultation considered proposals to introduce two increased BSS Requirements and relax further BSS Requirements through 20 adjustments resulting in lowering stipulations or expanding compliance options within the Interim Review of the BSS Examination Checking Procedures.
Section 1 – Foreword and introduction
The Boat Safety Scheme (BSS) ran a public consultation on proposals related to a revised version of the BSS Examination Checking Procedures produced with and through its stakeholder and management committees.
Following a review amongst numerous other improvements to clarity, descriptions and information was the proposals to introduce two mandatory increased BSS Requirements by way of changes to two existing BSS Checks.
The two increased BSS Requirements are:
- on boats with petrol propulsion engines, requiring evidence of recent servicing for any Wilderness Boats conversion of an Electrolux RM 212 refrigerator (BSS Check 8.2.2R)
- clarification that ferrous/cast iron fittings, joints and components used in LPG pipework are not compliant with BSS Check 7.8.3R.
There were also proposals to introduce 20 relaxations by lessening some requirements or expanding potential compliance options.
The BSS changes were considered as necessary and proportionate risk controls.
The consultation closed on Monday 30 May 2022.
Section 2 – Background to the consultation
2.1 The BSS Examination Checking Procedures and the recent Interim Review
The BSS Examination Checking Procedures (ECP) set out how the BSS Requirements are to be applied by BSS Examiners during BSS Examinations on privately owned and privately managed vessels (as well as the relevant checks common to the Hire Boat Requirements 2017).
The BSS ECP were last revised in 2015 so a review was commissioned becasue quality assurance initatives, comments and updates to references needed to be taken into account. The aims of the improvements are to:
- ensure that the published ECP support the onward consistent application of the Checks by BSS Examiners; and,
- ensure that BSS Examiner training can be effective to deliver an individual’s understanding of BSS Checking actions, Requirements and Applicabilities, whether the training is for existing Examiners or new-entrant BSS Examiners.
Further information about how the Interim Review of the ECP was carried out is available here .
2.2 The various outcomes of the review of the BSS ECP
Increased technical requirements – Apart from the two changes outlined in section 1 above (affecting a tiny number of boats), it is important to understand that no other increased technical requirements have been introduced as a result of the Interim Review of the ECP.
Relaxations and increased compliance options – In a small number of checks, there are 20 adjustments resulting in slight relaxations of specific requirements and/or additional compliance options. A table of those relaxations and further compliance options is available to view in section 4 below. Boaters are encouraged to view this table to assess if any are relevant to planned work on their own boats (owners) or marine industry members planning to carry out work on boats to meet BSS compliance.
Editorial improvements and increased clarity – Around three-quarters of the 540 adjustments are editorial improvements or checking procedure amendments that will help everyone’s understanding and application of the BSS Checks, whether they are BSS Examiners, boat owners or members of the marine industry.
Improved consistency in the application of the published BSS Checks is one very important aim of the Interim Review. However, we recognize that, leading from the proposed improvements in clarity and recent extensive training of Examiners, there is the potential for situations whereby an item may be newly discovered as non-compliant and so could require some adjustments or work to meet compliance and improve safety.
Likewise, the greater clarity in the Checking Procedures and the improved Examiner training may also address the relatively uncommon situation of any previous over-application the published BSS Requirements.
Consultation douments
A revised interim edition of the ECP was published on 28 September 2021 - click on this icon 
, the final version will be available in early 2023.
Further information about how the Interim Review of the ECP was carried out is available - click on this icon 
Around three-quarters of the 540 adjustments are editorial improvements or checking procedure amendments - the full list is explained in a document called 'Every Change Explained' - click on this icon
A pdf formatted consultation document can be downloaded here for reference - click on this icon
Section 3 – Consultation outcomes
A pdf version of the consultation response can be downloaded here - click on this icon
Collation of the responses to the BSS Consultation on the outcomes of the Interim Review of the BSS Examination Checking Procedures (ECP)
The consultation ran for a 12-week period from Monday 7 March to Monday 30 May 2022.
There were 22 responses in total. The responses and any material comments, to the questions asked, are provided below.
The BSS Office has answered individual concerns where appropriate, or has forwarded technical/risk comments to the BSS Technical Committee, where relevant.
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Q1 – Do you agree that the increased BSS Requirement requiring evidence of servicing for any Wilderness Boats conversion of an Electrolux RM 212 LPG refrigerator is supportable? |
Agree
20 |
Agree, with suggestions 1 Providing it has been fully risk assessed and the risk assessments are made available on request. |
Disagree 1 I strongly disagree with this proposal unless there is at least one appointed Gas Safety Engineer in the North West who is willing to undertake the required service of the appliance as Wilderness boats is too far away. |
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Q2 – Do you agree that clarifying the disallowance of ferrous/cast iron fittings, joints and components used in LPG pipework is supportable? |
Agree 20 |
Agree, with suggestion 1 Are galvanised malleable steel fitting OK? Providing it has been fully risk assessed and the risk assessments are made available on request. |
Disagree 1 Should only require changing if after visual inspection there is concerns that deem the need for replacement |
Q3 – Do you have any comments to make concerning the relaxation of 20 BSS Requirements by lowering stipulations or expanding compliance options?
14 made no comment
These are the comments of the remaining responses
- Yes
- Agree with the relaxation
- Over the top
- These should be welcomed.
- They all seem reasonable
- Providing it has been fully risk assessed and the risk assessments are made available on request.
- Agree in all but 3.2.2R - Battery Cables. This seems to allow arbitrarily thin wires of any length to run from a battery without up-stream fuses or circuit breakers. This can't be acceptable practice, and is probably not what's proposed, so some clarification is required.
- Yes, will email an observation about CO alarms.
- Are there any other areas where the BSS is at variance with ISO standards? What would be very helpful for boatbuilders who necessarily follow ISO standards for Recreational Craft Regulations compliance, would be a table showing all variances to ISO standards in the BSS.
Q4 – Can you see any further unintended consequences concerning introducing the proposals beyond those already mentioned in this consultation?
16 – Could not foresee further consequences
4 – Responded Don’t Know
2 – Could foresee further consequences and made the following comments:
- Should "sealant" be stipulated as INTUMESCENT?
- If not properly risk assessed i.e. risk assessments carried out then liability issues could follow in negligence, or a negligence claim.
Q5 – All efforts have been made to make the BSS Examination Checking Procedures document as error free as we can, however, should you spot any typographical or grammatical mistakes we welcome any observations leading to potential corrections to the final version.
No material comments received.
Q6 – Do you have any comments to make about this consultation? Have we been clear? Have we given you the proper opportunity and adequate means to contribute your views?
No material comments received.
Q7 – Background of responders
All specified interests are recorded
12 – Boat Users on canals
2 – Boat Users on rivers
1 – Boat User on rivers and canals
1 – BSS Examiner
1 – Gas Safe registered engineer
3 – Boat clubs and associations
1 – Canal society
1 – Academic institution
1 – Boat designer
1 – Unspecified
Section 4 – Reference Tables
20 BSS Requirements relaxed by either lowering stipulations or expanding compliance options
Please read the amendment explanations in the tables below which describe the nature of the proposed relaxations.
Table of lesser requirements
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Check |
Check Text |
Amendment Explanations |
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2.4.2R Petrol Tanks |
Are petrol tank vent outlets fitted with a suitable proprietary flame arrester in good condition? |
The requirement on diesel tanks is removed – revision aligns the BSS Requirement with the ISO standard, which does not require flame arrestors on diesel tank vents. |
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2.4.2R Petrol Tanks |
Are petrol tank vent outlets fitted with a suitable proprietary flame arrester in good condition? |
The mesh size specification is removed – this is because boats are, as manufactured, very likely to have arresters of ‘suitable proprietary manufacture’ and to continue with specified mesh size may cause a conflict. The Check then becomes a check of condition of the proprietary flame arresters and their flame arresting gauze. |
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7.1.1R Gas stowage |
Are all cylinders and cartridges stored in a position where any escaping LPG vapour will be directed safely overboard? |
The minimum separation between cylinders in the open and ignition sources/openings into the interior of the vessel has reduced from 1m to 0.5m. This now aligns with ISO 10239 and PD 54823 |
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7.2.3R Gas locker |
Is the cylinder locker, up to the level of the top of the cylinder valves or other high-pressure components, free of any path for escaping LPG vapour to enter the interior of the vessel? |
Withdrawn: ‘Door seals… … or pass the smoke pellet test’ [Deleted] - That part of the existing Check relating to smoke pellet testing is removed. Examiners have never been trained to undertake the smoke pellet test, the test procedures are not set out anywhere. |
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7.5.1R Gas locker |
Is the cylinder locker opening outside of any engine or battery space? |
Revision: ‘electrical equipment space’ has been deleted because it was very difficult to define and because risk review did not support its continuation. |
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7.8.6R Gas Pipes |
Are all LPG pipes running through petrol engine spaces jointless and adequately supported? |
The original checking action included ‘Check for any LPG pipes running through petrol engine or electrical equipment spaces’ – has been amended to remove ‘electrical equipment space’, based on a risk assessment. Consequently, the BSS Requirements at Check 7.8.6 now only apply to petrol engine spaces. |
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7.8.6R Gas pipework |
Are all LPG pipes running through petrol engine spaces jointless and adequately supported? |
A revision for a gas line to be routed within a conduit or trunking, or supported by fixing clips which are no more than 300mm apart. The part of the Requirement mandating the presence of a gas-proof conduit is removed and replaced with a Requirement for the gas pipe to be in a conduit or trunking or otherwise supported. The new approach aligns the BSS Requirements with the specifications with ISO 10239. Although the change does reduce slightly the specifications any added risk is considered to be insufficient not to align the BSS Requirements with the ISO. |
Table of additional compliance options
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Check |
Check Text |
Amendment Explanations |
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2.1.4R Fuel filler |
Does the internal diameter of the fuel filling point meet the specified requirements? |
Revision aligns with the ISO and have the required i/d for filler pipes at 28.5mm and retain the BSS minimum i/d requirement for hoses at 31.5mm |
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3.2.2R Battery cables
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Are battery cables of a sufficient current-carrying capacity? |
New applicability – cables between batteries and battery isolators are permitted to have a cross-sectional area of less than 25mm² where it can be confirmed that the circuit only supplies low current domestic and/or navigation equipment (e.g. lighting, fridges, pumps, radios, etc) |
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5.3.4R Petrol stowage |
Are all spare petrol containers and any spare portable petrol tank, stored to ensure that any leaking fuel or escaping vapour will not enter the interior of the vessel? |
An applicability can take account of petrol stowage arrangements on CE Marked boats when assessed against BS EN ISO 11105 relevant to the boat build date |
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7.2.2R Gas locker |
Are the sealing arrangements on LPG pipework exiting the cylinder locker of the correct type to ensure LPG-tightness and in good condition? |
To better align with ISO 10239 - The revision adding ‘sealant’ as an acceptable form of sealing to the main bullet-pointed list of acceptable sealing arrangements. |
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7.2.7R Gas locker |
Are the sealing arrangements on LPG pipework exiting the cylinder housing of the correct type to ensure LPG-tightness to the interior of the vessel? |
To better align with ISO 10239 - The revision adding ‘sealant’ as an acceptable form of sealing to the main bullet-pointed list of acceptable sealing arrangements. |
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7.5.1R Gas locker |
Is the cylinder locker opening outside of any engine or battery space? |
Revision of a new applicability Examiner action - where a cylinder locker is found to open into an engine space the Examiner should contact the BSS Office to determine whether there is a known acceptable compliance option available for the model of boat. This is because it is likely that some of the boats that fail this Check will be of a class of boat where there is a known compliance route already in place (such as with the Seamaster 23). The new Examiner action therefore helps to ensure that boats are not failed unnecessary at this Check where relatively simple compliance options are available. |
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7.8.2R Gas pipe |
Is the LPG pipe protected where it passes through metal bulkheads or decks? |
The revision allows for equivalence - LPG pipes passing through metallic bulkheads or decks must be protected by the use of sleeves, grommets, cable glands, bulkhead fittings, or equivalent. |
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7.8.3R Gas pipe joints |
Are all LPG pipe joints accessible for inspection and of the correct type? |
New provision for ‘threaded’ brass joints on copper pipe included as acceptable. It is included in the relevant BS and ISO standards. |
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7.8.3R Gas pipe joints |
Are all LPG pipe joints accessible for inspection and of the correct type? |
New provision for welded joints on stainless steel pipe included as acceptable. It is included in the relevant BS and ISO standards. |
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7.9.1R Gas hose |
Are all low pressure LPG hoses accessible for inspection, of the correct material and in good condition? |
Revision in one Applicability to introduce EN 14800 which supersedes BS 669. For the foreseeable future both standards are referenced. |
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7.9.2R Gas hose |
Is all low pressure LPG hose protected against damage where it passes through bulkheads, decks or partitions? |
This revision permits a further compliance option without promoting it as normal practice: - Applicability; it is acceptable for hose to be protected by sealant provided the sealant is in good condition and that it completely seals the area between the hose and the surrounding material, and provided the sealant does not noticeably move or dislodge when the hose is subject to light manual force. |
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7.9.2R Braided gas hose |
Is all low pressure LPG hose protected against damage where it passes through bulkheads, decks or partitions? |
This revision represents a clarification in regard to gas hose which itself is covered by a proprietary metal braiding does not require additional protection. |
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7.11.1R Gas appliance valves |
Can all appliance supply hoses be isolated through individual appliance isolation valves? |
New applicability - individual appliance isolation valves in the same LPG pipework spur as the appliance connected by hose, can be considered as meeting this Requirement. |
The new BSS Requirements
The proposed new BSS Requirements are identified below in the bold text within the revised text for BSS Check requirement, scope 8.2.2R.
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[Check Item Text, the Compliance Goal] On petrol-engined vessels with a Wilderness Boats conversion of an Electrolux RM 212 refrigerator on board, are the burner enclosure and the flame arrestor at the ‘lazy tee’ in place, and is there suitable documentary evidence of recent servicing? |
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[Checking action to be performed] On petrol-engined vessels with a Wilderness Boats conversion of an Electrolux RM 212 on board, check for the presence of:
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[Requirements that must be met for a pass] On petrol-engined vessels with a Wilderness Boats conversion of an Electrolux RM 212 on board:
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[Supplementary information] Examiner action – Examiners must refer to section 1 of Appendix 8 for essential information on recognising the flame arresting components of Wilderness Boats converted fridges. Applicability – Examiners should take a photograph/retain a copy of the presented documentation to be kept on file with the Examination checklist. Applicability – if the flame arresting mesh on the ‘lazy tee’ and/or the burner enclosure cannot be seen, Examiners should mark their checklist ‘not verified’. In such cases, the fridge must be considered as non-compliant until such time as its suitability has been verified. Applicability – if any part of the flue appears damaged, record a fault at Check 8.10.2 and take the actions described in Appendix A and B. Applicability – in the event a fault is determined at this Check take the actions described in Appendix A and B. |
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The text introducing the clarification is drawn from BSS Check 7.8.3R below where the pipe material determined the specific joint material and joint type, ferrous/cast iron material is not included.
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[Check Item Text, the Compliance Goal] Are all LPG pipe joints accessible for inspection and of the correct type? |
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[Checking action to be performed] Check the accessibility and type of all pipe joints. |
[Requirements that must be met for a pass] All LPG pipe joints must be accessible for inspection. All LPG pipe joints used on copper or copper nickel alloy pipe must be:
All LPG pipe joints used on stainless steel pipe must be:
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[Supplementary information] Applicability – joints not accessible for inspection must be recorded as ‘not verified’ on your checklist, and it must be considered that the Check has not been completed until such time as their type has been verified. Applicability – brazed joints are also permitted, but Examiners must take particular care when endeavouring to determine whether such connections are brazed or soft-soldered (which are not permitted). If in doubt Examiners should contact the BSS Office for guidance. Applicability – the material of type of some appliance connection joints may not be identifiable. Provided such joints appear to be original to the appliance, Examiners should consider the joint material compliant. |
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Further information
Should you have any questions about this consultation, please contact the BSS Customer Service Officer at BSS.enquiries@boatsafetyscheme.org or call 0333 202 1000.
If you have any complaints or comments about the consultation process, please direct them to: BSS.enquiries@boatsafetyscheme.org or write to the address below.
BSS ECP Comment
Boat Safety Scheme,
c/o Canal & River Trust Registered office:
National Waterways Museum Ellesmere Port,
South Pier Road,
Ellesmere Port,
Cheshire CH65 4FW
If you have alternative access requirements for any element of the consultation process, please call or contact us by phone, email or through social media.