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Wednesday 25 October 2023

Failed your MCA roll test? One man's story.

Yesterday, the Fisheries All Party Parliamentary Group (APPG) discussed a range of fishing industry safety issues - from crew working practices to seaworthiness. Much of the discussion in relation to every area related to criticism of the competence of surveyors for bodies like the MCA, Defra and the MMO. 

In particular, much was made of the lack of awareness by surveyors of small, especially under 10m vessels and the severe consequences of falling foul of the rules. A perfect example is that of Tristan below, who is in the process of righting (pun intended) what they perceive is a great wrong. A full report on the APPG meeting will be made on TtGaps soon.




Tristan tells the story so far:

"Afternoon everybody I'm sorry for posting these lengthy posts but I want to realise the position I'm in and many other fisherman who fish inshore on thier vessels and have come each night due to thier trusty vessel, to then be told its not safe. On the 20th of October, under the clear sky with dry and sunny weather, I conducted my own roll test. I want to clarify at the outset that I consider this test insufficient to depict my vessel's true behavior at sea - It is my firm belief that the most qualified judge of a vessel's seaworthiness is the individual at the helm.

However, given the circumstances, I felt compelled to undertake the test to alleviate any doubts about Adela's safety. The test was conducted using a reference mark on the hull, which was derived by dividing the widest part of Adela (3.8m) by 8, resulting in a mark of 0.475m. Three sets of rolls were executed, ensuring that the vessel was away from the pontoon and ropes were loose. The average results of the three sets were 3.8, 3.7, and 4.1. Adding these averages together and dividing by 3 gave an overall result of 3.8.

To ensure the accuracy of my findings, I conducted another set of rolls with similar methodology, which yielded an overall average of 3.9. To be extra sure, I went live and did a live set of rolls, which gave an overall average of 4. Adding all of these average results together and dividing it by 9 (as there were 3 sets of 3 results) resulted in a final average of 3.9. This is significantly lower than the 4.7 that the MCA test produced. What's more, I noticed that Adela nearly stopped rolling before the last roll, indicating a natural stability that may not be captured in the test's static measurements.

Granted, these tests do not perfectly mirror the way Adela rolls at sea, and I don't believe they should be used to disrupt someone's livelihood, especially when the vessel has proven time and time again to be seaworthy--a testament to her return home each night and her enduring presence even after 50 years.

Yes, Adela rolls, but she has never given me cause to question her safety. It is difficult to accept that a vessel that has served as a trawler off Brixham for over 30 years is suddenly deemed unseaworthy due to a blanket testing approach applied to the small inshore fleet.

Adela is a vessel of heritage and craftsmanship, constructed by master shipwrights who had built thousands of boats before her. She was built in a time when the rules were different, but that does not negate her safety or the skill with which she was constructed. Her robustness and durability are evident, having returned home safely each night for more than 50 years.

To suddenly deem such a vessel unseaworthy based on a test that does not take into account her unique construction and the expertise of those who built and operate her, seems to me to be a grave injustice. It is an imposition of a one-size-fits-all mentality that does not reflect the reality of the small inshore fleet like ours.

While Adela does roll, as any boat at sea does, never have I felt that she was unsafe. I am confident that many others familiar with her would agree. It is my hope that these findings and my experience with Adela will be taken into consideration in any future evaluations of her seaworthiness.The extensive and meticulous research conducted has provided a wealth of evidence that overwhelmingly supports my findings.

On another note the tests were carried out with the Adela fully equipped with all on-board gear, thus mimicking the real-life conditions the vessel would encounter "steaming to grounds." The vessel's performance, when the gear is offloaded or "shot", differs significantly, which is a crucial factor that needs to be taken into account. The vessel's behaviour and operational efficiency have been observed to alter noticeably once the gear is deployed. The testing conditions, therefore, do not fully encapsulate the range of scenarios the vessel might face in its day-to-day operation. In this regard, the tests have certain limitations, and it is essential to approach the results from a nuanced perspective. The test results should be used as a guide, a reference point, and not as an absolute determinant of operational feasibility or the vessel's effectiveness.

It is also crucial to remember the impact these findings can have on the livelihoods of those involved. The tests should inform us, guide us, but they should not be used as a hammer to indiscriminately crush the livelihoods of hardworking individuals who depend on the vessel for their survival. The objective, after all, is to optimise operations and improve safety, not to halt them entirely. Therefore, while the tests provide valuable insights, they should not be viewed as the ultimate authority. They are a tool for improvement, not an instrument of cessation. Recognising the tests' inherent limitations and their potential impact on livelihoods, they should approach the results with a balanced perspective, using them as a guide for improvement rather than a mandate for cessation. 

Time for a cup of tea methinks."

Tristan posted an update yesterday: 

"Afternoon Everybody.  I wanted to provide you with an update on my ongoing efforts to raise awareness about the U15M regulations and the impact they are having on both myself and the entire inshore fleet. As many of you are already aware, the U15M regulations have been a cause of concern for me and others. These regulations, implemented by the Maritime and Coastguard Agency (MCA) and enforced by their surveyors, have introduced significant changes and requirements that directly affect my operations. They have imposed limitations on vessels under 15 meters in length, and navigating the complexities of these regulations has proven to be quite challenging for me. In response to these challenges, I have taken proactive steps to address the situation and highlight its consequences. One of the actions I have taken is reaching out to various individuals and organizations to voice my concerns and seek support.

 

One notable contact I made was with our local Member of Parliament, Anthony Mangnall. I am pleased to inform you that Mr. Mangnall has been receptive to my concerns and has acknowledged the importance of discussing this matter further. Despite my current uncertainty regarding the outcome of a retest, Mr. Mangnall has kindly extended an invitation for a telephone call next week. This call will provide a valuable opportunity for me to delve deeper into the issues surrounding the U15M regulations and explore potential solutions. During our conversation, I intend to provide Mr. Mangnall with a overview of the challenges faced by the inshore fleet as a result of these new regulations. I will highlight the adverse effects these regulations have had on our day-to-day operations, the financial burden they impose on us, and the potential long-term implications for the sustainability of our industry. It is my hope that by sharing this information, we can foster a greater understanding and gather the necessary support to address these concerns effectively. I will keep you updated on the outcome of the telephone call with Mr. Mangnall and any subsequent developments."

Cheers Everybody