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Anger at Seawork over Workboat Code 3

Anger over MCA coding rules



Anger at MCA consultation process spills over at conference – with accusations that the MCA is not communicating over coding that could have disastrous consequences for small workboats.

There was standing room only at the UK’s Maritime & Coastguard Authority (MCA) Workboat Code 3 update presentation at Seawork as the Workboat Association teetered close to expressing a vote of no confidence in the UK’s statutory body.
Something of a showdown with industry stakeholder groups was widely predicted and nothing draws the crowds more than a regulatory update that could threaten significant operator costs.
As part of the MCA’s system for designing new regulations, although we learned not actually a statutory component of it, the body includes a Technical Working Group in the early stages of the consultation process, to ensure that the regulations are realistic and workable for the people who ultimately will need to code and operate vessels under them.

Opinions vary as to precisely what happened with this working group in 2022, but things clearly did not go well. Kerrie Forster, CEO of the UK’s trade body the Workboat Association, who was a member of the group, recalls it as a substantial breakdown of the group as multiple key members left the process in protest concerning the direction that the MCA was taking the new regulations in, particularly the plans for applying the new regulations to vessels already operating under older codes.
“I have to report to the wider industry that many original members of the working group stopped attending throughout the process, due to the disagreement with the process,” he said. “And the draft was delivered by a small skeleton group of industry and small commercial vessel experts together with the MCA Codes team.”

The MCA’s Code Vessel Lead, Rob Taylor, remembers it slightly differently, citing the unexpected length of the process and some members’ dissatisfaction that it was taking place via remote conferencing, but did corroborate the fact that a number of members left the process leaving the working group ’a little thinner’ than the MCA would have liked.

This was all in the second half of 2022, and was further underlined by a huge response from the industry to the MCA’s online consultation, with MCA responses to these queries, it is claimed, often resulting in disappointing holding replies and scant information that some commentators suggested indicated that the MCA was struggling under workload issues. WA has stated that the public consultation of Workboat Code 3 received one of (if not the) largest feedback from any UK domestic maritime legislation to date.
The MCA is certainly in an unenviable position and responding to unexpectedly massive volumes of feedback clearly isn’t coming at a good time for them. Both the Workboat Code update and their other current significant body of work, an update to the SCV (Small Commercial Vessel) code, are un-shuntable statutory pieces of work that have fallen concurrently at the MCA’s feet.

Question Time
The MCA’s Rob Taylor presented some tweaks to the process, and another minor extension to timelines to a conference room bursting at the seams.
As is often the case at a good conference, the presentation was all of the expected party-line fodder, with the real meat in the sandwich coming in the shape of the questions that followed.
Kerrie Forster began the questions with a long and pre-prepared set of questions/statement citing the Workboat Association’s (WA) issues, and was followed up by several experts, particularly from Certifying Authorities who also believed their issues with Workboat Code 3 are not being adequately addressed.

Of the several issues expressed by these industry stakeholders, a major one is the lack of clarity on how workboats operating under earlier codes such as Brown Code can meet the updated code without, in certain cases, prohibitively expensive structural work. If this is the case, part of the issue was that this was not being adequately communicated to the industry.

The MCA has estimated the cost of changes to existing vessels to meet the new code at £800,000 for the entire UK workboat fleet, but the WA suggests that this is miles short of the mark with the overall fleet cost as upwards of £1 billion. Kerrie Forster even predicts that a single vessel requiring structural work such as repositioned and additional bulkheads or lined tanks could attract a bill north of the MCA’s mooted £800k- for a single vessel. The massive discrepancy, as explained by WA, is due to some significant omissions on the MCA’s part.

One simplified example Kerrie cites is that the new code in some cases may stipulate a larger size and weight for the vessel’s main anchor. WA says that the MCA has just calculated the price of an anchor for such an upgrade, but the WA has factored in the potential cost of engineering consultancy, reconfiguring chain sizing, windlass capability, anchor locker enlargement, time in dry dock, ie, the total cost of ‘a heavier anchor’.
If these are the sort of errors that have been made this is a major attack on the MCA’s credibility from a key industry body, as it suggests a fundamental lack of practical knowledge within the MCA of how workboats are built, refitted and operated.

Kerrie’s statement posed the following asks:
1) There needs to be a correct Demin Amis Assessment made and publicly shared, otherwise parliamentarians and public are being knowledgably, falsely informed, to make their judgement.
2) The new draft should be shared for further comment publicly or back to the TWG to steer the direction of the content, following the first round, and unexpectedly large feedback from the public consultation.
3) The final draft needs to be shared with industry before becoming law, to allow industry time to react to the incoming changes
Until these changes are made, for the first time since our origination, we do not stand behind the UK flag and new workboat code as it currently stands.
“Taking a workboat from Brown Code up to Workboat Code 3 presents a seriously steep hill for some vessel owners and operators to climb,” said Ben Sutcliffe, chairman of certifying authority YDSA.
“The MCA has calculated upgrade costs primarily from Workboat Code 2 to 3, but this actually represents the minority of the fleet. Where Brown Code consisted of 70-odd pages, workboat Code 3 is over 200 pages. It’s also littered with more complex and daunting language and double negatives that almost look designed to trip up or confuse the unwary operator.”
The MCA was quick to counter that there is a grace period, so that vessels could continue to operate under their existing coding until it runs out, but ultimately vessels being recoded after the end of December 2023 would need to meet the new system of regulation.

New normal?
Stuart Gladwell, CEO of SCMS, another certifying authority, asked why the MCA had not engaged the certifying authorities (CAs) more closely in the process. According to Gladwell, the CAs had more specific detailed sector knowledge concerning key aspects that the new framework seeks to address, such as un-crewed operations and future fuels, and had seen the MCA was struggling in some areas and had offered to take on some of the work, to no avail. In short, the CAs could see the MCA was drowning, had offered to help, but to no avail.
Gladwell also expressed his concerns about the lack of communication concerning his organisation’s specific queries to the MCA concerning Workboat Code 3. He had two outstanding issues that were timing out fast and potentially going to attract cost to rectify that the MCA was not responding on. One has been outstanding for several months, and relates to regulations that are coming in fairly imminently. Gladwell concluded with a rather pointed question that dangled in the air for a few moments: “Is this lack of communication the new normal for the MCA?”

Summing up
The mic returned to Kerrie Forster for what became an impactful summing up of the industry’s issues with the code, and before we look at what he said it’s important to consider WA’s past relationship with the MCA.
The WA originated in 1994, as a representative of industry to formulate the original Workboat Code, Brown Code. Since then the WA has been a key global ambassador of the UK flag and the Workboat Code.
WA has been on numerous MCA working groups since and is a powerful industry body. Not only did Forster “beg” the MCA to recommence the consultation process from scratch with more complete stakeholder engagement, he also reminded the MCA and the audience that part of the WA’s remit was to offer advice to its members concerning flagging and coding.
For the first time in its history, WA was not only having to consider whether it should continue to sit on MCA working groups, but also whether to even continue advising its membership to code vessels under the UK flag state. While it wasn’t quite an official WA statement of no confidence in the MCA, it was just about as close to this bombshell as you could get and clearly suggests some stormy waters ahead for UK workboat industry.

WA Seawork Dinner Quiz!

Smiles and good food at this year’s annual WA Seawork Dinner


It was a fantastic night for the 150 people that attended ‘The Grand’ in Southampton on 14th June. As ever, the food was delicious and the entertainment ‘The Illusionists’ were brilliant!

Thank you very much to the evening’s sponsors: CTRL Marine Solutions, ShipOwners Club and Campbell Johnston Clark.

We can’t tell you how they made the lady disappear 3 times, but we can tell you who won the ‘bragging rights only’ annual quiz (and what the answers are)!!

This years winner is….


Dave McNaughton, Anna & John Percival-Harris, Bobby Mitchell, Michel Radjiman, Sarah Leonard, Bert de Ruiter, Noor Kimmit, Susi Miller

Congratulations, you win one of the workboat sector’s most coveted prizes, the chance to gloat to everyone else that you are the most intelligent.

Team Points
13 46
5 41
TMS 40
Anonymous 40
12 38
15 38
3 37
6 37
11 36
Jaws 34
9 33
4 22

Try the quiz for yourself here:

>>>WA Seawork Quiz Questions<<<

Answers to the quiz are here:

>>>>>WA Seawork Quiz 2023 Answers<<<<<


WA Quarterly meetings

This week we hosted The Workboat Association Safety Forum, Training and Technical Workgroups in London at The Seafarers’ Charity and the Port of London Authority respectively.

Actions and highlights taken from the meetings include;

  • To create guidance on charitable aid available to companies and seafarers,
  • A new safety tool idea to launch at Seawork,
  • The need to get more apprentices in Scotland,
  • Debriefs from 2 x successful engagement sessions with the Maritime and Coastguard Agency,
  • To create some guidance for on board crane inspection, and
  • To host another technical day this year

Agendas, Minutes, Meeting recordings and presentations will be shared via WA on demand shortly.

If you are interested to get more involved with our activities, let us know via our contact page

Workboat Association supports the Riviera OWJ and DP Conference

Member discount!

Riviera Media are delighted to once again welcome The Workboat Association as a supporting organisation of the upcoming Offshore Wind Journal Conference 2023 and European Dynamic Positioning Conference 2023 and to extend a 20% discount to all members.

Simply contact the Workboat Association team before purchasing your ticket to get your 20% discount code.
Your ticket is an access-all-areas pass, allowing you to move freely between events, explore shared exhibition space and enjoy networking and refreshment breaks with all participants.

Find out more here:

Programme and Invitation




Iain MacKinnon – Awarded MBE

The New Year has begun with celebration as long-serving Workboat Association ally and previous Secretary to the Maritime Skills Alliance Iain MacKinnon’ is awarded an MBE in the UK New Year’s Honours list 2023.

The award  citation reads;  ‘For services to the Maritime Sector’.

Iain has provided a large amount of time, effort and experience to the benefit of the Workboat Association and the wider maritime community since he began his role with the MSA 10 years ago. Most notably for us, his help with the Workboat Apprenticeships and the Maritime Skills Qualifications. Iain retired from his role with the MSA last year and handed over the reigns to David Tournay, he is however still within the industry working as a freelance consultant within maritime education and training – we are sure it is not the last we have seen of him!

Bill Walworth, Chair of the MSA commented “This award is richly deserved and it is fantastic to see maritime skills and the MSA on the list, Well done Iain and thank you, this news has started the year off on a great note”


Congratulations Iain and thank you

Recovery of Persons in Water (PIW) Guide to Good Practice for Small Vessels

The British Tugowners Association are pleased to release to industry is latest guidance release, Recovery of Persons in Water (PIW) Guide to Good Practice for Small Vessels.

The Guide to Good Practice is available as a free pdf for use across the industry.

The BTA Chairman, Scott Baker from Svitzer, when releasing the Guide at the BTA’s Annual Safety Seminar on 10 November, stated that

“The guide looks to debunk and demystify various myths and fallacies within the industry, spurring on open debate and discussion with the intent being to save lives. For their expertise and input the BTA extends special thanks to Paul Savage OBE, Managing Director Saviour Medical Ltd, Professor Mike Tipton MBE from University of Portsmouth, and the Workboat Association Safety Forum.”

The intent of the guide is not limited to tugs but applicable across the small boat sector, whether crew transfer vessels, pilot cutters, workboats or tugs, many of which share similar characteristics and equipment.

The BTA’s Technical Committee has for over a year been working on reviewing the task of recovering people from the water to small vessels and appraising the equipment typically found in the small vessel sector. The end goal being to arrive at a complementary suite of equipment which can be used to effect a rescue across the four stages of recovery.

  1. Making a connection to the casualty
  2. Getting the casualty under control
  3. Recovery of the casualty to the deck
  4. Medical care and post rescue support on board

Key areas of discussion:

  • the ineffectiveness and potential of lifejackets without crotch straps
  • Cold Water Immersion, its effects and incorrect confusion with hypothermia
  • the truth around vertical and horizontal rescue
  • protection for the rescuer(s) on board
  • demystifying Automatic External Defibrillators (AEDs)
  • post recovery trauma and support
  • standardising the handover/transfer of the casualty to emergency services (ATMIST)

The guide stresses the importance of effective and realistic drills and training, a historical idea captured by Archilochus c. 650 BC who wrote, “We do not rise to the level of our expectation; we fall to the level of our training”,  yet repeatedly is found to be wanting in accident reports and investigations.

Professor Mike Tipton MBE, FTPS, from the Extreme Environments Laboratory, at the University of Portsmouth provided the foreword, commenting:

“Immersion in cold water represents a serious threat to life. But this threat can be significantly reduced with the correct knowledge, procedures, equipment, and training. This comprehensive guide provides the information needed to significantly reduce the chances of a tragedy if an individual goes overboard. It follows that reading this guide, and implementing the recommendations contained herein could, quite literally, be lifesaving. 

In the area of cold water survival, knowledge = survivability. 

I commend this Guide to Good Practice to you, and the knowledge it provides.”

Download the Good Practice Guide here

The BTA wish for the Guide to be an iterative document, which will be reviewed and updated over time. As such, feedback and comments are invited to the Secretariat at

The GTGP follows earlier publications for the BTA Technical Committee which include the Second Edition of the Pilot’s Pocket Guide and Checklist, released January 2022 (available here), and the BTA’s Rope Selection, Procurement and Usage Guidance for Tow Ropes, released July 2021 (available here).

Mark Ranson – 2022 Merchant Navy Medal Award


Mark Ranson has this weekend, on International Merchant Navy day (Sep. 3rd), been awarded the 2022 Merchant Navy Medal for Meritorious Service.

The award was made to Mark for his services to workboat safety standards and training, he will be 1 of a group of 14 persons who collectively have been awarded the 2022 award, to be presented on the 22nd November.


Read the Gov.UK announcement here

Mark Ranson became the Workboat Association’s Secretary in 2011, later becoming the CEO, before taking over the reigns as Chairman for a year from 2019-2020.

He was previously awarded the 2019 European Commercial Maritime Awards ‘Maritime Professional of the Year’ for his work with the Workboat Association.

This latest award signifies a large number of safety and training related activities that Mark has been a part of thought his career. From; developing the first ISM system in the wake of the Herald of Free Enterprise Capsize, to nurturing Mass Evacuation Systems. A dedicated, long-serving, stalwart of the WA and his local maritime training centre HOTA, to working many years within the towage sector as a safety expert (and many more to list).


Mark retired from the WA in 2020, though he continues working in his role on the board of HOTA and looking after his small-holding;

Clémence Barbey wins 2022 John Percival Memorial Award

The Workboat Association is proud to announce that Clémence Barbey of the Port of London Authority has won the 2022 John Percival Memorial Award.

The Award was announced by Workboat Association Chair, Mark Meade. during a surprise ‘hybrid’ presentation ceremony held at the Port of London Authority‘s Headquarters alongside the River Thames.

This award was set up by the Workboat Association to commemorate John Percival, the founder of the Hoylake Sailing School. The annual award is to recognise the best industry trainee.

Clémence Barbey, the winner of the 2022 John Percival Memorial Award, was trained and then nominated by SeaRegs Training for her commitment and enthusiasm to make sure that she completed her apprenticeship throughout adversity and did so with flying colours.

Clémence, who works as a deckhand on the Port of London Authority’s lower river harbour launch, said: “I want to thank everyone, especially the PLA, for the opportunity I have had to work on the Thames, my dream job.”

Learn more about the John Percival Memorial Award here: