19 September 2024

The MCA has launched a short consultation on proposed changes to MGN 627. This MGN provides an overview of the changes made by the Merchant Shipping (Safety Standards for Passenger Ships on Domestic Voyages) (Miscellaneous Amendments) Regulations 2022 (colloquially known as the “Grandfather Rights Regulations”) and its associated Marine Notices. One of the major changes in the wording is under the bilge alarm section which has now removed the section stating latching systems are not required and has replaced this with the following.

Alarms shall include an audible, and a separate visual, warning at the control position for each space in which an alarm is fitted. Such systems facilitate the detection of water ingress and hence can help to prevent catastrophic flooding or foundering. Once activated, the audible alarm must continue to sound until acknowledged by positive action, and shall not automatically cease sounding of its own accord. A non-latching alarm, i.e. an alarm that stops sounding automatically when the water level drops back down, may be permitted in some scenarios. These will be assessed on a case-by-case basis. When vessels are not carrying passengers and are not in use, the alarm may be isolated. The Domestic Safety Management system must clearly state the circumstances in which the alarm may be isolated, and the action that must be taken by the crew to reinstate the alarm prior to operation.

Other clarifications include:

1. Additional text in paragraph 2.3 to clarify that lifejackets (and, where applicable, Buoyancy Aids) on all relevant passenger vessels operating on Category C and D waters be fitted with approved, automatically activated lights;

2. Text in paragraph 2.4 on fire detection requirements is amended to align more closely with the Merchant Shipping (Fire Protection: Small Ships) Regulations 1998;

3. Text in paragraph 2.5 on fixed firefighting amended to clarify that, where the requirement for a fixed firefighting system is satisfied by the use of an aerosol fixed firefighting system, the system shall be installed in accordance with section 5 of MGN 657 (M/F) - Requirements for fixed aerosol fire extinguishing systems for use in small vessel machinery spaces, as amended;

4. Text in 2.6 amended to clarify that, although a second means of powered bilge pumping must be powered from a source independent of the main engine pump, the sources of power are not required to be in separate locations;

5. Text in paragraph 2.7 amended to align the bilge alarm requirements more closely with the Merchant Shipping (Passenger Ship Construction: Ships of Classes III to VI(A) Regulations 1998. Additional clarification added to confirm that an alarm may be isolated in certain circumstances.

6. Text added to paragraph 2.9 to clarify that a risk assessment is required before some types of vessels may be exempted from the damage stability requirements detailed in Merchant Shipping Notice 1699(M).

It is our understanding that there are negative supply and cost implications of this change in particular, as such please review the full consultation and associated documents which are found attached and respond with any comments and or concerns you have with any of the changes to both British Marine via technical@britishmarine.co.uk and directly to the MCA. 

As a reminder the changes to the vessels under the 'grandfathering legislation' must be complete by the first survey after the end of the implementation period i.e. by the first passenger ship renewal survey after 28 December 2024.  This consultation ends on the 4 October.

Please send responses either directly to dpv@mcga.gov.uk or via the British Marine technical department technical@britishmarine.co.uk 

The draft MGN 627 amendment 2 text can be found here and the response form can be found here.