MCA publish short industry consultation on Grandfathering guidance amendments

Published on: 08 August 2023

The MCA has released a new industry consultation document on Marine Guidance Note (MGN) 627 amendment 1.

MGN 627 provides an overview of the changes made by the Merchant Shipping (Safety Standards for Passenger Ships on Domestic Voyages) (Miscellaneous Amendments) Regulations 2022 (“the 2022 Regulations”) often known as the “Grandfather Rights Regulations”.

Since the publication of the original MGN 627, queries on the requirements contained in it and the rest of the legislative package requirements have been raised by various individuals. While these have been addressed on a case-by-case basis, it is believed that benefit would be gained from updating MGN 627(M) to provide extra clarity on the issues which have been brought to light.

Industry views are sought in respect of the proposed changes to the original version of MGN 627(M) which are designed to provide additional clarity and enable the MGN to better reflect the legislative changes implemented by the “Grandfather Rights Regulations” and its associated Marine Notices.

The main amendments to the text of the MGN are on the following points:

• Further clarifications on what the surveyors will request/expect when considering the exemption to the carriage of lifejackets on cat B waters.
• Further clarification on the fitting of fixed fire fighting equipment and the applicable standards likely to be accepted.
• Clarification on the minimum outcome which must be demonstrated by ships brought within scope of the buoyancy test by the “Grandfather Rights” Regulations.
• Clarification that the exemption from stability requirements for passenger vessels operating on tidal Category C Waters based on a Risk Assessment to evidence that it is an area of Lower Operation Risk, is available to vessels operating in daylight hours only.

Full consultation details can be found on the gov.uk website here. The consultation will run until the 28 August 2023, responses need to be sent to dpv@mcga.gov.uk or via the British Marine technical department via technical@britishmarine.co.uk.