TALKING POINT on IBIJAHARP 18 - a sad result for the RCD
You probably don’t know the acronym. It means “Joint Action on HARmonised Products 2018” and is a European Union project designed to check compliance with the Recreational Craft Directive.
It involved the random purchase of 30 inflatable boats (14 models from 13 manufacturers) and conventional boats (16 models from 15 manufacturers) up to 6 metres in length from a consortium of seven EU market surveillance authorities. All boats were suitable for use with outboard motors. The manufacturers are based in Asia and in Europe.
All but one boat in Module B were in Module A or A1. 19 boats fell into category C and 11 into category D. As a reminder, Notified Bodies are not involved in the approval of boats in Module A at all. In Module A1, only stability and buoyancy are assessed either by tests or on the basis of calculations by the certifier, nothing else.
Two Notified Bodies were commissioned with only some selected physical tests. The market surveillance authorities themselves concentrated on more formal matters.
And here is the result of 30 examinations:
- For 20 boats, the declaration of conformity was defective.
- 26 boats had deficiencies with regard to the owner’s manual 8 watercra had a faulty manufacturer’s plate
- 12 boats did not have a proper manufacturer’s number
- 17 craft lacked re-boarding aids or handholds.
- In the stability test, 2 GRP boats did not have the required freeboard height
- 5 GRP boats failed the O‑ set Load Test
- 9 GRP boats failed the Level Swamped Flotation Test. One boat sank during the test.
- All the inflatable boats had sufficient stability, but some of them showed great weaknesses in the number and quality of the handles.
A sad result, I think. After all, the directive was written in 1994 and still does not work properly in terms of safety. There are certainly various reasons for this. As a result of the JAHARP 18 investigation, corresponding adjustments are to be expected both on the part of the RCD and the ISO standards. Does the industry really need modules A and A1? In both modules, the manufacturer is pretty much le alone! Some Notified Bodies seem to have knowledge gaps regarding the stability and buoyancy requirements.
The market surveillance has also learned something and will probably pay more attention to Module A and A1 boats in the future.