12 December 2024
MGN 627 amendment 2 released
Following industry consultation back in September and several further meetings between the MCA and British Marine, the MCA has now released MGN 627(M) Amendment 2 - Guidance on changes and available exemptions against requirements introduced by the Merchant Shipping (Safety Standards for Passenger Ships on Domestic Voyages) (Miscellaneous amendments) Regulations 2022.
This notice replaces MSN 627(M) Amendment 1 and should be read in conjunction with The Merchant Shipping (Safety Standards for Passenger Ships on Domestic Voyages) (Miscellaneous Amendments) Regulations 2022, MSN 1699(M) Amendment 3 and MSN 1670(M) Amendment 2.
This Amendment 2 gives clarifications in the following paragraphs:
- 2.4 on fire detection requirements
- 2.5 on the application of fixed firefighting requirements.
- 2.6 on the requirements for powered bilge-pumps.
- 2.7 on the requirements for bilge alarms.
One of the largest changes within the amendment is on paragraph 2.7 on the requirements for bilge alarms. Due to the way the legislation is written the MCA has had to re-remove the section that stated latching alarms are not required i.e. restating that latching alarms are a requirement. However after consulting with British Marine and the PBA, they acknowledge that latching bilge alarms are not readily available on the market and actually for the size and type of vessel these are being fitted to there would be a disproportionate cost to industry with no discernible increase in safety.
Due to the discussions between British Marine and the MCA a solution has been found with the following wording found within section 2.7:
For vessels where a non-latching alarm has been installed in accordance with the previous advice given in MGN 627 Amendment 1, there are two options:
- Fit a simple relay to the audible alarm, which will cause the audible alarm to latch on when activated. In many cases, this will not require changing the existing alarm system.
- For vessels under 24m load line length, seek an exemption from this requirement from the local Marine Office.
This issue will be explored further in the post implementation review required for all new Regulations, in this case in 2027.
So what does this mean for operators? Effectively this means that operators of vessels of under 24m LLL that fit the non-latching alarm systems that are readily available on the marketplace they will need to fill out an exemption form, it is our understanding there will be no cost for this exemption form, we suggest text along the following lines is included in the exemption form:
Description of non-compliance:*
Non latching bilge alarms fitted as per MGN 627 amd 1
Explain why the vessel cannot be made compliant:
Bilge alarms have been fitted as per MGN 627 amd 1 and are of the non latching standard. As a vessel of under 24m in size as per MGN 627 amd 2 these regulations are likely to be reviewed and changed to allow non latching alarms for this size of vessel when the regulation is reviewed. Until then as per MGN 627 amd 2 I am applying for an exemption to the latching requirement.
Explain what arrangement/provisions are in place as an alternative?*
The alarms have been fitted in line with the MCA's guidance in MGN 627 amd 1 which states latching alarms are not a requirement. The vessels is sub 24m in length with the alarm panel and buzzer directly at the helm position. If the alarm goes off, regardless of if the system is latching or not the skipper will be aware that it has gone off. Further training will be given to skippers on how to react to the bilge alarm sounding will be given and documented in the DSM.
Full details for MGN 627 amendment 2 can be found here - MGN 627(M) Amendment 2 - Guidance on changes and available exemptions against requirements introduced by the Merchant Shipping (Safety Standards for Passenger Ships on Domestic Voyages) (Miscellaneous amendments) Regulations 2022 - GOV.UK
For any questions or clarifications please contact the British Marine Technical team via techincal@britishmarine.co.uk.