Post Construction Assessment

Följande text är ett utdrag ur Recreational Sector Group (RSG) Guidelines 2010 och omfattar RSG:s rekommendationer för efterkontroll (Post Construction Assessment) av fritidsbåtar och vattenskotrar.

General Comments
In accordance with Article 8 of the Directive, the Manufacturer shall, before producing and placing his products on the market, apply the conformity assessment procedure foreseen in relation to the boat design category and hull length. However, in certain cases, it is necessary for craft and PWC with their installed engines and components to be certified, in line with Article 8.1 of the RCD, after they have been built. These are those craft and PWC, where the Manufacturer does not want to take responsibility for placing it on an EEA market. These are not necessarily used craft or PWC, but also new ones, where imported e.g. by private persons. All Essential requirements are applicable for such craft and PWC. This includes design, construction, noise and exhaust. Where Essential Requirements require a harmonised standard to be used, this applies equally to PCA. The post construction assessment report issued by the Notified Body has to cover all these requirements and must be an individual assessment of each craft and PWC. In the Directive no modules are defined for post construction assessment.

As examples, the following boats are covered by post construction assessment, where the Manufacturer or his authorised representative does not fulfill the responsibility that the boat conforms with the requirement of the Directive:
• boats neither placed on the market nor put into service in the present EEA Member State territory prior to the full application date of the Directive
• boats intended solely for racing or experimental craft, subsequently placed on the market as recreational craft and therefore required to be CE marked in accordance with the Directive.
• Craft where the purpose of use has changed to recreational use (e.g. former commercial boats)

Attention is drawn to the responsibility and the legal aspects, having the owner, the importer, or the person placing the craft on the market or putting it into service in the EEA, as applicable, to assume the role of the Manufacturer and being identified as the responsible person in this context (not being the authorised Manufacturers representative).

For PCA assessment all requirements of the directive, i.e. design, noise and exhaust need to be covered. In case a craft has to be assessed, which obviously has provisions for inboard or stern drive engine installations or the propulsion engine installation has been removed, the PCA can only be completed and be valid after the engine installation has been fitted and the craft/engine installation has been assessed on its compliance with the exhaust and noise emission requirements.”

Procedure to be applied for PCA (assessment of requirements acc. Annex I):

A.1. Boat Design Categories: see chapter E of the Guidelines

A.2.1. Craft identification: The scope of the requirement is to identify each craft with some indications relevant to the Manufacturer. In case such information are missing or unidentified (e.g.: the date of build or model year when the builder is unknown) it becomes the responsible person’s duty to act as though he was the original builder and include such details in the CIN. The NB should assign the MIC for Recreational craft which are subject to PCA in combination with a digit code to allow unique identification. ESR A.2.1. requires the use of EN ISO 10087 for coding.

A.2.2. Builder’s plate: the responsible person takes the role of the Manufacturer and includes his name on the plate.

A.2.3. Protection from falling overboard and means of reboarding: see chapter E of the Guidelines

A.2.4. Visibility from the main steering position: see chapter E of the Guidelines

A.2.5. Owner’s manual: the responsible person shall ensure that the manual is provided in accordance with chapter E of the Guidelines

A.3.1. Structure: in order to assess the strength of the structure it is recommended to obtain as much information as possible concerning hull construction and scantlings (e.g.: past acceptability by Certification Bodies or Local Authorities or declaration of conformity in accordance with the Annex III of the Directive) and any possible empirical data (e.g.: details of voyages undertaken or record relevant to adequate experience of safe operation in an area where the sea and weather condition are not less than those applicable in the Design Category). If there is insufficient documentation to assess construction of the boat or insufficient empirical data to demonstrate adequate strength compliance, then tests may also be carried out. A hull inspection should then be carried out in order to assess satisfactorily the conditions of the boat.

A.3.2. and A.3.3 Stability & Freeboard and Buoyancy &Flotation: see chapter E of the Guidelines. For all design categories, a Notified Body
is required to have assessed this Essential Safety Requirement
For A & B category boats, if there is insufficient documentation to assess stability and buoyancy with the harmonised stability standard, it is required to obtain as much information as possible concerning stability and buoyancy (e.g.: past acceptability by Certification Bodies or Local Authorities) or any possible historical data (e.g.: record of voyages undertaken in safe operation in an area where the sea and weather condition arenot less than those applicable in the corresponding Design Category) which may permit to define the design category, the maximum number of persons and the maximum load capacity. For C & D category boats, if there is insufficient documentation to assess stability and buoyancy, tests have to be conducted to assess stability and buoyancy and to define the design category, the maximum number of persons and the maximum load capacity.

A.3.4. Openings in the hull, deck and superstructure: Tightness degree test and strength assessment relevant to the installation of the appliances according to EN ISO 12216:2002 is required. This test may be omitted provided that a visual inspection is carried out satisfactorily and adequate experience in the use may be demonstrated.

A.3.5. Flooding: see chapter E of the Guidelines.

A.3.6. Manufacturer’s Recommended Maximum Load: see chapter E of the Guidelines. The maximum load, crew limit and design category are strictly linked. The relationship between the three items is given in the Stability and Buoyancy Standard

A.3.7. Liferaft stowage: see chapter E of the Guidelines

A.3.8. Escape: see chapter E of the Guidelines

A.3.9. Anchoring, mooring and towing: see chapter E of the Guidelines

A.4. Handling characteristics: see chapter E of the Guidelines

A.5.1. Engine and engine spaces: see chapter E of the Guidelines. In the absence of satisfactory information insulating materials may be tested and the relevant results included in the Technical Documentation

A.5.2. Fuel system: compliance of the fuel system may be assessed by mean of an inspection of the fuel system and parts of it as installed on the lines, including filling, venting and return hoses, connection to the tanks, fuel filters, any shut-off valves or auxiliary equipment. In case of petrol system, non-ignition protected components are required to be replaced in the engine compartment. Fuel tanks are to be inspected as installed to
ascertain any corrosion or leaking areas, tests may be required.

A.5.3. Electrical system: inspection of the installed system including batteries, generators, switches, battery chargers is to be carried out as applicable. Information is required to verify the characteristics of the electrical cables and protection systems

A.5.4. Steering system: compliance with the relevant standards is to be assessed as applicable. A functional test is required.

A.5.5 Gas system: a general inspection of the system including gas storage, gas cylinders, piping hoses, pressure devices and ventilation is
required, tests may be required.

A.5.6. Fire protection: see chapter E of the Guidelines

A.5.7. Navigation lights: see chapter E of the Guidelines

A.5.8. Discharge prevention: see chapter E of the Guidelines

A.6. Inflatable boats and ribs assessment procedure should be similar to craft assessment, but with additional application of the harmonized standard for ribs as far as practical. See chapter E.A.6 b)

A.7. Personal Watercraft (PWC) assessment procedure should be similar to craft assessment, but with additional application of the harmonized standard for PWC (EN ISO 13590: 2004. See chapter E.A.7 b). Equivalent conformity can also be achieved by certification against all of the following SAE Standards:
J2566 : Personal Watercraft–Display of Persons Capacity Information
J2034 : Personal Watercraft Ventilation Systems
J1973 : Personal Watercraft–Flotation
J2120 : Personal Watercraft–Electrical Systems
J2046 : Personal Watercraft Fuel Systems
J2608 : Off Throttle Steering Capabilities of Personal Watercraft

B. Exhaust Emissions:
The Notified Body is fully involved in post construction assessment. The Notified Body has to use tests and procedures according to the Directive unless the technical file submitted provides evidence that the engine
complies with one of the regulations listed below. These regulations were either in place before the amendment of the directive came into force and represent exhaust emission limits, which are at least as stringent as the requirements set by the amended directive, or are more recent non EU regulations that provide evidence of equivalent conformity. Engines not complying with one of these regulations shall be submitted to exhaust emission testing in accordance with the harmonised standard. For PCA of used craft the Notified Body should take additionally into account the history of the maintenance and use of the engine and should assess the condition of the craft and the engine in order to be ensured about the craft’s equivalent compliance with the exhaust emission requirements. Compliance has to be shown according to the list as shown below or by equivalent confirmation drawn up by the engine manufacturer.

Regulation Comparison for CI Engines
• EU Directive 97/68/EC [stage 2 and if P >37kW], compliance shown by label on engine acc. to Annex I Subclause 3 & type approval certificate
• EU Directive 97/68/EC as amended by EU Directive 2004/26/EC [stage IIIA, IIIB, IV and if P >37kW], compliance shown by label on engine acc. to Annex I Subclause 3 & type approval certificate
• US Environmental Protection Agency (EPA) 2002 Recreational Engine Rule, signed on September 13, 2002, compliance shown by label on engine acc. to 40 CFR § 94.212 [40 CFR Part 89 et al.][67 FR 68241-68447, 8 Nov 2002],
• US Environmental Protection Agency (EPA) 1999 (Commercial) Marine Engine Rule, signed on October 23, 1999, compliance shown by label on engine acc. to 40 CFR § 94.212[40 CFR Parts 89, 92][64 FR 64 73300-73373, 29 Dec 1999]
• US Environmental Protection Agency (EPA) 2008 Category 1 and 2 Marine Engine Rule, signed on March 14, 2008, Recreational Craft up to a displacement of 7 l/cyl covered in Category 1, compliance shown by label on engine acc. to 40 CFR § 94.212 [40 CFR Part 9, 85 et al.][73 FR 88 25098-25352, 6 May 2008]
• EU Directive 88/77/EEC as amended by 2001/27/EC, compliance shown by label on engine acc. to EU Directive 88/77/EEC Subclause 5& Annex 3
• UN Regulation ECE-R96 as amended by Series 01, compliance shown by label on engine acc. to UNECE R96 Subclause 4

Regulation Comparison for SI Engines
SD/I Engines:
• Lake Constance Shipping Ordinance (BSO – Bodenseeschiffahrtsordnung) [stage 1 and if four stroke engines greater 10 kW], compliance shown by numbered, individual type-certificate for exhaust coming with the individual engine acc. to BSO Annex C
• Lake Constance Shipping Ordinance (BSO – Bodenseeschiffahrtsordnung) [stage 2], compliance shown by numbered, individual typecertificate for exhaust coming with the individual engine acc. to BSO Annex C
• Marine engines covered by the US Environmental Protection Agency (EPA) 2008 Non Road SI rule – Source: Control of Emissions from Nonroad Spark-Ignition Engines and equipment; Final Rule – 40 CFR Parts 9, 60, 80 et al.][73 FR 59033-59380, 8 Oct 2008] Relevant part: Marine SI engines under 40 CFR part 1045, pages 59194-59231 Exhaust emission limits: SD/I engines 40 CFR part 1045.105, page 59197-59198, Compliance shown by label on engine acc. to 40 CFR part 1045.135
• BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS, TITLE 13. MOTOR VEHICLES, DIVISION 3. AIR RESOURCES BOARD, CHAPTER 9. OFF-ROAD VEHICLES AND ENGINES POLLUTION CONTROL DEVICES, ARTICLE 4.7. SPARK-IGNITION MARINE ENGINES. This article consists of section 2440-2448 SD/I Rule (1 to 4 Star rating), compliance is shown by the emission control label on engine acc. to 13 CA ADC § 2443.1 Clause C

OB/PWC Engines:
• Lake Constance Shipping Ordinance (BSO – Bodenseeschiffahrtsordnung) [stage 1 and if four stroke engines greater 10 kW], compliance shown by numbered, individual type-certificate for exhaust coming with the individual engine acc. to BSO Annex C
• Lake Constance Shipping Ordinance (BSO – Bodenseeschiffahrtsordnung) [stage 2], compliance shown by numbered, individual typecertificate for exhaust coming with the individual engine acc. to BSO Annex C
• Marine engines covered by the US Environmental Protection Agency (EPA) 2008 Non Road SI rule – Source: Control of Emissions From Nonroad Spark-Ignition Engines and equipment; Final Rule – 40 CFR Parts 9, 60, 80 et al.][73 FR 59033-59380, 8 Oct 2008] Relevant part: Marine SI engines under 40 CFR part 1045, pages 59194-59231 Exhaust emission limits: OB and PWC engines 40 CFR part 1045.103, page 59197, Compliance shown by label on engine acc. to 40 CFR part 1045.135
• BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS, TITLE 13. MOTOR VEHICLES, DIVISION 3. AIR RESOURCES BOARD, CHAPTER 9. OFF-ROAD VEHICLES AND ENGINES POLLUTION CONTROL DEVICES, ARTICLE 4.7. SPARK-IGNITION MARINE ENGINES. This article consists of section 2440-2448 OB/PWC Rule (3 Star rating), compliance is shown by the emission control label on engine acc. to 13 CA ADC § 2443.1 Clause C

C. Noise Emissions: see chapter E of the Guidelines
The Notified Body is fully involved in post construction assessment. All inboard powered craft and PWC shall undergo individual noise assessment according to the harmonised standard EN ISO 14509 Part1. For PCA of used craft the Notified Body should take into account the history of the maintenance and use of the engine and should assess the condition of the craft and the engine in order to ensure compliance with the noise limit values.
In case there is more than one craft of a production type having identical engines, exhaust and propulsion arrangements being subject to PCA, the NB may identify and assess one craft as a master craft and take this as a reference for assessing the other craft on their equivalent conformity with
the noise emission requirements.

Other procedure to be applied for PCA:
Components listed in Annex II:
Components not CE certified in compliance with the RCD are to be inspected according to the relevant standards as applicable. In case such components are found not in compliance they are to be replaced.

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