|The Technical Requirements for Inland Waterways Vessels (TRIWV) directive from the European Union is intended to harmonise all the EU countries regulations for vessels over 20 metres long. It is a complex document that is daunting to the uninitiated but can be condensed into a set of very basic requirements for recreational vessels like ours. Above all, do not be put off getting your vessel certified or perhaps not purchasing a larger vessel because the regulations as they apply to most barges are not onerous and you will miss the extra space, especially if you intend to live aboard for long periods.|
We have gone through the process of obtaining TRIWV certification through the Dutch system which will provide us with a seven year certificate. Our trials and tribulations were monitored and this page updated as we progressed. Please feel free to fire any questions at us via our contact page and we will try to help.
If you are a DBA member (and you should be) you should first read though the excellent distillation on the regulations by Andy Soper for an overview. This DBA page is kept up to date with the latest developments. The regulations themselves can be downloaded here and are in the form of a 260 page PDF (portable document format) file with which you will need Adobe Reader software which is freely downloadable here.
The first thing to understand is that the older your vessel the more you are exempt in complying with the full regulations but a 'N'ew build vessel or the 'R'eplacement of something or the 'C'onversion of an existing vessel must comply with everything. Existing vessels that don't get certified before the due dates could be regarded as "New" and made to comply fully with all regulations so it pays to do it sooner rather than later.
To navigate its waterways, Belgium requires all vessels built before 1912 to be certified by the end of 2010, before 1930 by the end of 2011 (which is us), before 1951 by end 2012, before 1976 by end 2013 and before 2009 by end 2014. The EU only specifies that everyone must comply by 2014 so Belgium has jumped the gun. Not bad for a country that has just broken the world record for being the longest time without a government. Just shows you what the bureaucrats can do in the absense of a government!
The regulations specify navigation zones and our objective was to obtain a Dutch certificate for Harmonie for all zones with the exception of The German Rhine, Elbe and Danube which is Zone R and the Dutch Waal. Below is some information that might help those owners with the same objective and things we have gleaned during the lead up to our survey:
- Hull Survey:
A requirement for the Dutch certificate is that you must have had a hull survey within the last two years.
The hull survey is straightforward and the surveyor will carry out an ultrasonic test to measure plate thickness at various points. I am told that the minimum plate thickness allowed is 3mm although your insurance company (and you) might want to see a little more. If there is any doubt then a double plate welded on while the ship is on dry land will always be better than fixing a leak at short notice later. The surveyor will look at every piercing of the hull like suction and discharge pipes as these are vunerable places for water ingress. He will also look for propeller induced cavitation damage in the stern section and recommend any repairs. It is a good idea to disconnect all your batteries on board if any welding is required to, in theory, protect your alternator diodes being damaged by stray currents.
- Collision Bulkhead:
A watertight collision bulkhead is only a requirement if you intend to navigate the German Rhine, Elbe and Danube which are classified as Zone R. It can not be placed aft of any fuel tanks and the distance from the stem must be within a specified amount calculated by a formula. It can be a greater distance away but then bouyancy calculations must determine that the vessel will stay afloat and will not capsize as a result of reduced freeboard or free surface effect. The only reason you might have to install a collision bulkhead is if you are actually in a collision and your bow section is replaced when the "replacement" rule comes into effect. We do not want to navigate these rivers where you are required to carry a pilot so most recreation vessels of our size avoid them. Busy commercial fast flowing rivers are in our opinion not for pleasure!
The safety survey is new to us but we have discussed it with other owners and with TRIWV qualified surveyors and think we have a good idea of what they are looking for. Bear in mind that if you do not comply then the surveyor will list those items where you do not comply for future rectification.
The foregoing are common requirements that owners have needed to address.
- Fire Prevention:
At least three 6kg fire extinguisher, purchased or inspected within the last two years must be on board at specific entry positions where fire could occur. Extinguishers should be to EN3 specification and UK suppliers (who are much cheaper) are acceptable.
- Man Overboard:
A proceedure notice should be displayed so all crew know what to do if a person goes overboard. Things like what warning to shout, making sure the helmsman is aware and marks the position on the GPS navigator, throwing a lifebouy, positioning the vessel downwind etc. etc. should be included. Here is our man overboard notice.
- Life Saving:
Life jackets should be within date and lifebouys should be to EN standard with reflectors. You will also need one lifebouy light.
A Blue board with a flashing light is a requirement but always was for CEVNI. An emergency battery operated anchor lamp should be on board.
Bilge pumps should operate on float switches with a switch to operate a wheelhouse alarm at a higher level although we are exempt this requirement for TRIWV. Main engine fuel tanks are to have a water drain and shut off valve (exempt for existing vessels until certificate renewal) that can be operated from deck level or fuseable link on a spring valve will do. I do not like this latter idea as if the valve failed or even if there was an engine room fire, navigational requirements might require you to keep the engine running to get the vessel out of danger before isolating the fuel supply.
- First Aid:
A certified first aid kit is required on board. I have yet to discover who certifies or what exactly is required.
For existing vessels built before 1st January 1985 the following articles are among those that will not apply:
Watertight collision bulkhead:
You don't need it unless you are in a collision and that section of the ship is repaired.
Sound levels in wheelhouse:
This only applies if your vessel has open holds and relates to a minimum freeboard. It will apply to all vessels on renewal of the certificate but you are exempt until then.
Requirements of steering system:
Engine exhaust system:
Exempt until next renewal.
Battery installation and ventilation:
Exempt until next renewal.
Electrical switches and protective devices:
Exempt until next renewal.
Electrical cables, lighting, power supply for navigation:
Anchor windlass, dinghies, lifebuoys and life jackets to standard:
This is the European Identification Number which the British MCA have devolved to the RYA to administrate who make an excessive charge to issue. A EIN is supposed to be a requirement to obtain a Dutch certificate but we did get the certificate pending the EIN being issued. We have now paid the excessive fee to the RYA for our EIN number which is 14000047 and is now plastered on each side and stern of the wheelhouse in regulation height letters at even more expense. Dutch built vessels like us do have an identification number which is cut into the steel of the hull or on the aft cabin. The number is marked on the aft cabin of Harmonie and is "2586B Amst.1951" which helped to discover Harmonies history. This is in the format that all Dutch commercial vessels were given. It is no good for us however as it is "doorgehaald" which I think means "expired" so to get another Dutch EIN we would need a Dutch shipbroker to provide a Dutch address for us and to arrange for us to be Dutch registered and a new number to be cut. We could have gone down the Dutch route which means the vessel would have been flagged in to the Dutch register. The Dutch do not have a small ships register like the UK so it is just like the UK ships register for larger vessels over 24 metres. This would be a more costly alternative but does have the advantage of providing legal proof of ownership.
Two radio sets are required one of which must be ATIS. This was already an EU requirement.
An Automatic Identification System (AIS) transponder is already a requirement in places like Antwerp and may become so elsewhere in the future which is serious money but grants are available and this is not a TRIWV requirement at the moment. The AIS is a GPS device and, with the right software, can be also connected to a laptop which can then display your position and that of any other vessels within VHF range. One question, as yet unresolved is what type of AIS is acceptable. The big ships use one costing €2000 but there is a simpler system costing about €500 intended for pleasure boats which may suffice.
- Domestic Gas Installations:
An installation certificate is required from a recognised authority and the gas used must be propane. Harmonie has a Belgian certificate.
Harmonie was inspected in Gent, Belgium by a Dutch surveyor. He issued an inspection report detailing the items we should attend to as follows:
a) The ships (EIN) number should be displayed on the aft and sides of the wheelhouse which has now been done but did not prevent the Dutch certificate being issued. The Dutch certificate number is the important one for TRIWV purposes.
b) Various signs like for example "ear defenders must be worn" should be displayed in machinery spaces but the surveyor acknowledged this was nonsense on such a small ship!
c) A fixed water pump should be mounted in the focsle. A submersible deck pump would make more sense as the idea is the focsle could be pumped out in the event of a leak and should be self priming. We need to take this up with the surveyor at the next survey.
d) The fuel pipe to the main engine should be copper and not rubber. Surveyors dislike rubber hose in engine rooms on principle and there are rubber hoses all over the engine which would feed a serious E/R fire but a remotely operated fuel shut off valve is provided to isolate the fuel tank in case of fire.
e) The short length of exhaust pipe between the water cooled exhaust manifold and the point where water is injected should be lagged and this has been done.
f) A lifebouy floating light should be provided and this has been provided.
The hull was inspected by a Dutch surveyor approved by our insurance company contributed towards the survey cost. His report was submitted to the TRIWV surveyor who then arranged for the Dutch community certificate to be issued. He also provided a Dutch address for this purpose.
The hull survey found one rivet head sheared and the hole was sealed with a spot of weld, otherwise no work was required. The anodes were all working but were good for a further period without renewal and the sterntube bearing had no further wear since the last survey four years ago. The sterntube greaser was tested and worked satisfactorily.
The issue of the Dutch community TRIWV certificate was now a formality and just to prove it, here is a picture of the piece of paper that has caused us and others so much anxiety and not inconsiderable expense to the extent that we met a Belgian skipper who had cut off the bow of his ship to get it under 20 metres!
At the TRIWV forum held as part of the DBA rally in Namur, it was suggested by the Dutch shipbroker and surveyor present that we should consider it added value to your ship and that even vessels under 20 metres in length should consider getting certified. It should provide you with added safety on board, trouble free passage through all EU countries and is further proof, if needed, that you own the vessel if it is not registered with the Dutch kadaster. The surveyor should check the Dutch kadaster records for proof of ownership if your vessel was once registered in Holland.
Registering the ship under the more costly (than the small ships register) British ships register would be comparative with the Dutch kadaster and would cost a similar amount of under £1,000 but would not be proof of ownership under British law but neither would the Dutch.