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BARGES: All about barges and barging - building, buying, maintaining, equipment, handling on the water, etc.
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TOPIC: ES-TRIN 2020

ES-TRIN 2020 12 May 2020 09:33 #115899

Just to throw another layer of confusion on top of all this. You can get a Dutch surveyor when in a Belgian dry dock (provided the person will travel to Belgium, of course) and thus your hull survey will be valid 7 years not 5..... πŸ˜‚for example: Register Holland, an official Dutch surveyor company, work across Europe.

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ES-TRIN 2020 08 May 2020 20:09 #115800

To pick on the inspection periods for hulls and extinguishers as examples of a no-level playing field is to ignore the huge agreement on standards in the vast majority of regulations in ES-TRIN, CEVNI, etc. Be thankful that if your boat is cerified in one country it is acceptable in others, despite anecdotes of odd police checks. Be thankful that the same extinguishers are acceptable in all countries.
Rolling a powder to shake up the powder is NOT an inspection! A proper inspection doesn't take much more effort or skill but it MUST be done correctly to be useful.

Differences in surveyors is quite another matter and largely anecdotal as far as I can deermine.

Likewise police inspections, which in my limited experience of them are largely concerned with having the right paperwork. There's really NO excuse for not having the last hull inspection, gas insection, extinguisher inspection, etc ready in a file for inspection, especially for a permanent liveaboard - and as for not having insurance! I have little sympathy.
No doubt some police are excessive but if you give then a file of up-to-date papers to flick throug they will probably move on to the next boat.

Pete

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Pete Milne, Quo Vadis , Gent.

ES-TRIN 2020 08 May 2020 17:51 #115799

I don't see how 5 years, 7 years or 10 years can be described as a level playing field. I agree that fire extinguishers should be checked regularly, the powder ones need a good shake regularly to avoid any compaction due to vibration. My point was that if your extinguishers checked every 2 years are acceptable for Belgium (and the Rhine apparently), when you get checked in France they are not. When I was checked last year in France they wanted a certificate also. There are no doubt plenty of other examples.
Where I think some of the variations and anomalies lie are with individual surveyors in various countries (as already pointed out), but also by the Police Regulations in each country. It is the Police, generally, who are going to do the spot checks and they have their own regulations, varying from country to country. The Brigade Fluvial from Metz have a habit of descending on Verdun in the Spring and going over all the boats. Apparently they collected more than €3000 in fines a couple of years ago. My friend was moored there but strategically not on board at the time they visited to query the size of his registration numbers. His wife professed absolutely no knowledge of anything, and said they needed to ask him. The same brigade also descended on the Port de Plaisance at Nancy and went through all the boats (many of which are permanent liveaboards). Many were fined or warned for not having any papers, insurance, black tanks etc etc.
The important thing is for us to keep our boats safe for us and for other waterway users. Increasing regulations with their anomalies and associated cost are something we have to live with.

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ES-TRIN 2020 07 May 2020 19:53 #115785

With any EU legislation it has to be remembered that the EU only ever proposes and implements legislation. Approval of what actually comes through the mill to legislation is by the individual member countries.
For hull inspections (and hence Es-TRIN certification),, each country already had standards, most that could be rolled into shared EU law - and some they weren't prepared to. As France requires 10 years, ES-TRIN says 'maximun 10 years. Why would a country with a long-standing 5-year rule for hull inspections (BE) or 7 years (NL) agree to extend this to 10 years?

For extinguishers, I don't think there is an EU inspection timing standard, However, the only sensible thing (in barge or house!) is to inspect them at least once a year, to be sure they'll work when you need them. I don't care what the local law is; I just want to be safe so I check mine every spring - and record the results for a possible police inspection.

My view is that the EU has created a pretty good level playing field for barges - but there are a few local variations.

Pete

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Pete Milne, Quo Vadis , Gent.

ES-TRIN 2020 07 May 2020 19:23 #115783

Hello John,

It is one of the delights of EU legislation that all countries must implement Directives but are free to add their own requirements on top. We try to make this known whenever there are new issues.
To your specifics:
ES-TRIN certification has always been for a maximum of 10 years and countries have been able to choose a lesser period.
Fire extinguishers - yes France has more strict inspection regimes - see above
Size of lettering - not aware of anyone being fined - do you have further details?
The government inspector is effectively checking authorised surveyors work - quite a sensible arrangement as that provides a more even standard - we hope!

Yes it would be great if EU legislation levelleld the playing field but sadly that is not the reality.

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Best Wishes
Andy Soper
DBA Director Representation and Treasurer
mv Neeltje
Coookham
0044 (0) 303 666 0636

You don't need a barge to join - a dream of boating in Europe will do'. See www.barges.org

ES-TRIN 2020 07 May 2020 09:27 #115772

Balliol and Andy have mentioned the different interpretations of ES-TRIN by surveyors. This also applies to the application of the same rules by each country. The validity of the certificate is 5 years in Belgium, 7 years in the Netherlands and 10 years in France! As regards fire extinguishers, it is every 2 years in Belgium, but every year in France (except the Rhine where it is 2 years!). Similarly the size of name and number lettering is contentious, people have been fined in France. Some of these things are not mentioned at all in ES-TRIN as far as I know, but the inspectors and especially the marine police, seem to be adding their own rules. In Belgium after the hull and mechanical survey, a government inspector comes and checks over things (including engine number) and issues the certificate. I asked them about a minor point last time and they said "for us it is no problem, but the marine police may not like it!)
It is a pity that European legislation is not implemented to exactly the same standards throughout Europe.

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ES-TRIN 2020 06 May 2020 15:00 #115756

We are in danger of confusing two sets of regulations here. ES-TRIN does not require recreational craft to have AIS. CEVNI – the navigation regulations – requires craft over 20m to have and use AIS on Class 1 waterways. See more here in the Knowledge Base: barges.org/knowledgebase/regulations/ais

In the Netherlands the government has charged ES-TRIN recognised surveyors with ensuring that ships over 20m do have a functioning and certified AIS.

Only commercial craft are required to have routine repeat testing for ES-TRIN.

The NRC clauses were helpful in indicating which issues should be classified it as manifest danger – if existing craft were exempt for 20 years then it was a good negotiating point with your surveyor not to apply that standard. NRC clauses still exist in ES-TRIN 2019 – but have never applied to recreational craft.

There are a number of examples of the surveyors using discretion and coming up with different interpretations and I share Balliol's anxiety with the current certification regime which I am raising with the European Boating Association (EBA) and RYA (the latter attend ES-TRIN / CESNI meetings on behalf of EBA).

There is a useful flow chart on the lvbhb website: www.lvbhb.nl/wat-is-cvo/ which translates fairly well if you are using Google Chrome translator.

A bigger issue is replacement engines as the rules stand today only emission certificated engines can be fitted and if you have an old engine then it must be replaced before an initial certificate can be issued. Renewals of certificates issued before the 2018 cut-off do not require replacement engines – but somone in Brussels has spotted that certificates already issued do not carry an engine number and action is being taken to cover that loop-hole.

I am told that CESNI is beginning to question whether it is worth worrying about a 'few' recreational barges with a separate chapter – we may be in to some hard bargaining to ensure that we don't just get swept in with the full commercial regulations which some navigation authorities would like to see.

As ever the more fulsome the legislation the more problems and discontinuities that arise!

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Best Wishes
Andy Soper
DBA Director Representation and Treasurer
mv Neeltje
Coookham
0044 (0) 303 666 0636

You don't need a barge to join - a dream of boating in Europe will do'. See www.barges.org

ES-TRIN 2020 06 May 2020 12:42 #115753

  • Balliol Fowden
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I would beg to answer the question slightly differently.

Prior to 31st. December 2018 the (then) new TRIWV standards were largely retrospective, but there were numerous derogations for existing craft, often based on various age cut-off dates, whereby various lesser requirements which were of NON-manifest danger were derogated, in some cases indefinitely as I recall but in most cases with end dates, often substantially in the future. These items were listed as "NRC", i.e. applicable only to New builds or where vessels were substantially Repaired or Converted.

All that was swept away by ES-TRIN 2019, although the certification end date under the old rules date was deferred during 2019 for vessels already in the system for first inspection by November 2018, to cope with demand from those who had seemingly been hitherto unaware of the new standards.

From 1st. January 2019 those derogations were swept away and all new or existing pleasure craft of any age entering the system have to comply with the standards listed in Chapter 26 (1) if not CE marked, or a lesser set as listed in 26 (2) if CE marked.

So long as those standards remain the same then, in accord with Peter's original enquiry, boats will be re-inspected in accordance with those standards. If standards are revised, or new standards are promulgated, then hopefully there will be some consultation and perhaps some grandfathering or some lead in time, but I have seen nothing to suggest that there are any automatic grandfather rights.

Of more immediate concern is the evident high level of interpretation (or should we say "discretion") that is allowed to individual surveyors, or to put it in yet another way, a lack of uniformity in the application of the often vaguely worded standards, which might suggest that careful preservation of records and continuity with the same inspector might be prudent.

What is also yet to be seen is whether the end dates for NRC derogations under the old TRIWV will be applied rigorously. Peter Voerman may be able to comment.

Balliol.

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ES-TRIN 2020 05 May 2020 19:37 #115740

Hello Peter,

ES-TRIN (was known as TRIWV) was entirely retrospective for recreational craft over 20m . Up until its introduction we only needed certification to travel on the Rhine in Germany and beyond. Luckily the 'manifest danger' clause softened the blow for existing craft and exempted clauses were noted on certificates issued up to December 2018 (and some issued after but started before).

We monitor the activities of CESNI ( www.cesni.eu/en ) which is the delegated EU and CCNR (Rhine Commission) body that is empowered to make changes to ES-TRIN through the European Boating Association (EBA). We did apply to become an observer member but were turned down as we are members of EBA.

Currently the biggest issue is a new Chapter 9 which reflects another EU Directive on diesel engine emisions - this means that exisiting uncertified barges can be required to fit a new engine to meet emission regulations. This is still being challenged.

So - NO - standards are not grandfathered, except the manifest danger items already included on the certificate, and we will have to comply with changes as they are dreamt up by CESNI bureaucrats. This is usually pushed by CCNR bureaucrats - ' if it isn't permitted it is forbidden' and Rhine standards are the best!

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Best Wishes
Andy Soper
DBA Director Representation and Treasurer
mv Neeltje
Coookham
0044 (0) 303 666 0636

You don't need a barge to join - a dream of boating in Europe will do'. See www.barges.org

ES-TRIN 2020 05 May 2020 09:49 #115722

I'd be very surprised if there is anything to that effect as it's talking of future events, and the regulations are only written based on current thinking. The regulators have no way of knowing e.g. if tomorrow all engines will be atomic powered, or if engines will be banned altogether and horses become the motive power.

If 'grandfather rights' are ever introduced it is at the time new or modified regulations come into force. At that point they may well be extended to vessels then in existance, though it might introduce some clause such as 'existing vessels should not present manifest danger'.

Tam

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ES-TRIN 2020 05 May 2020 03:02 #115721

  • Peter Smith
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Can somebody assist with a clarification of the status of ES-TRIN. In the event of a 'new built' achieving a compliance certificate are the standards the ship need's to maintain grandfathered to those applicable at the time of compliance or will they change in the event ES-TRIN requirements are changed / upgraded?
I assume the there will be a slow change in ES-TRIN and the vessel will be required to meet the 'new' requirements.

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