Consultation outcome
A new MGN on media, other organisations and persons on ships and fishing vessels
Read the full outcome
Detail of outcome
Public consultation on draft MGN on Media, Other Organisations and Persons carried as passengers on Fishing vessels and other ships took place between 16 January 2019 to 15 February 2019. A broad cross section of organisations and companies were directly notified of the consultation exercise, including the UK Main fishing Federations which represents a broad cross section of UK fishing interests. Two written responses were received, from significant players in the industry. The responses on specific aspects of the proposals are set out in the table below.
| Consultee | Para | Original Text | Consultee | MCA Response |
|---|---|---|---|---|
| MAIB | General | MCA and PFD introduced in the summary without being explained in full. | As this is a guidance note it is possible that someone new to the industry may not appreciate what the acronyms stand for | Agreed. Acronyms explained |
| MAIB | 听 | References | While references to legislation and other guidance is helpful, it may lead to a non-mariner losing the will to chase down a rabbit hole when they have, to their eyes, a perfectly usable vessel being presented to them. Less jargon and more plain English would make this guidance note much more useful. | Accepted but whilst the document has been reviewed and simplified where possible, references are still necessary. |
| MAIB | Summary | It is strongly recommended that individuals, such as family and friends and in particular, children, are not carried as passengers whilst a vessel is fishing commercially | A vessel may be chartered under a commercial agreement where children may be present as passengers. It would be better to clarify the statement to ensure that it is clear that it refers to commercial fishing vessels rather than chartered fishing vessels where fishing for pleasure is being enjoyed. | Agreed. MGN amended to clarify what a commercial fishing vessel is. |
| MAIB | 听 | Where it is not usual to carry passengers on a particular type of vessel, additional safety measures should be considered. | This is unhelpful and very vague. 鈥楽afety measures鈥� needs to be qualified or the comment removed. The next point on the draft MGN is far more useful to the shipowner/ master. | This line has been removed. |
| MAIB | Introduction | 1.2 This MGN was produced following discussions with media organisations. It informs organisations 鈥� | Which organisations are being informed? Perhaps another word rather than to repeat the word 鈥榦rganisations鈥�? | Wording amended |
| MAIB | Who to contact | 2.1 In the first instance, the vessel鈥檚 status, its classification and the qualifications of the crew can be obtained from the owner, manager or master. If there is any doubt, ship owners, managers or masters should contact their local MCA Marine Office for guidance, details of which are on our website. | Not quite sure who should be checking this. An owner is unlikely to doubt his own vessels status etc. Double 鈥�.鈥� At end of paragraph |
Clarified that the organization wishing to use the vessel must check. |
| MAIB | Safety Considerations | 3.1 The captain/skipper | The document refers to captain here but master elsewhere. | Document now refers to skippers. |
| MAIB | 听 | 3.2 and 3.3 鈥榬isk assessment鈥� | With capitals and without capitals, which style is it? | Single style adopted |
| MAIB | 听 | 3.3 It is not appropriate for young children to be on board fishing vessels whilst operating commercially where they might cause distraction from safe operation. | See comment previously made under summary, although agreed that children should not be a distraction to safe operation. | Clarified what a commercial fishing vessel is. |
| MAIB | 听 | 3.4 All persons on board fishing vessels not operating commercially and small commercial vessels, including the skipper and crew of the vessel, whilst on the open decks of the vessel at sea, should wear Personal Floatation Devices and/or use Safety Lines | This appears to apply a more stringent requirement on pleasure crafts than commercially operated vessels. See 3.5 in draft MGN for more information. | Para 3.5 reminds readers of the mandatory requirement for commercial fishing vessels. However, the MGN now recommends that PFDs or lifelines are worn, even if the risk assessment has concluded that there is now |
| MAIB | 听 | 3.7 It is strongly recommended that, where possible, safety drills are conducted prior to departure with as many of those involved in the production taking part as possible. | If a vessel is operating with passengers, the MGN does not provide whether less than 12 at this stage, then this should be required and not merely recommended. | Amended to remove wording regarding recommendation |
| MAIB | 听 | 3.10 If the Owner or Skipper is unable to ensure the safety of crew and additional persons onboard or is uncomfortable with the implicated risks of having additional persons onboard then they have a responsibility to either prohibit access to the vessel for the additional persons or to not sail under unsafe conditions | This appears to mix the requirements already pointed out in 3.9 with general seaworthiness. The mixture of topics is confusing in this paragraph. | MCA is of the view that the section, as it contains general safety considerations is suitable and 3.9 and 3.10 of the Consultation MGN refer to different requirements, for access and for safety when on board. |
| MAIB | Using registered fishing vessels | 1. If an organisation wishes to use registered fishing vessels as part of its work they should in the first instance make contact with the owner/manager/skipper of the vessel, and thereafter the owner/manager/skipper of the vessel and the organisation should make contact with the local MCA Marine Office. | It is not clear why the owner/ manager or skipper (Note not master or captain) should contact the MCA Marine Office. | Clarified that the organisation should check |
| MAIB | 听 | 5.2.3. | It is unclear who has the responsibility to check for the decal and then contact the MCA if necessary | References to decals removed. Now refers to Small Fishing Vessel Certificates |
| MAIB | 听 | 听 | Throughout the section 鈥榮kipper鈥� is capitilised and then not. | Amended |
| MAIB | 听 | 5.4.1 听 Any passengers that are to be carried onboard fishing vessels are strongly recommended to undertake personal sea survival training. | This is completely at odds with the requirement that a safety briefing is 鈥榮trongly鈥� recommended. | Section 3.8 now requires the safety briefing |
| MAIB | Small Commercial Vessels | 6.2 These vessels have various limitations on their operation dependent upon the vessel鈥檚 certification or the certification of the skipper | Skipper/ master or captain? | Amended to skipper |
| MAIB | Vessels on the UK鈥檚 inland waters (excluding fishing vessels). | 听 | This MGN is designed for those who may be outside the marine industry, define 鈥榠nland waters鈥� so that they may know what area is actually being referred to. To refer to another document is not helpful. | Categories of Waters now included in MGN |
| MAIB | Large Ships (excluding Fishing Vessels and Passenger Ships) | 听 | Quite vague and unhelpful for a non-mariner. Who has the responsibility? | Title amended to Ships of 24m Loadline length and over |
| MAIB | Manning | 听 | Quite vague and unhelpful for a non-mariner. Who has the responsibility? | Amended to say organisations should check |
| NEPIA | General | 听 | No mentions (that I can see) of ensuring adequate LSA for extra personnel that may be on board | Reference to LSA added as section 3.6 and Annex 1 |
| NEPIA | 听 | Para 5.3.1 | A vessel is not engaged in fishing when working nets purely for the reasons of obtaining media footage. I鈥檓 not sure I fully agree with this as the vessel would still present similar navigational risks to other vessels as if it was fishing? | Agreed but this is based on legal definitions. |
| NEPIA | 听 | Para 5.4.1 | Regarding sea survival training for passengers on fishing vessels 鈥� I鈥檓 not sure this would be achievable/realistic although others more experienced in the industry would be better placed to comment | Sea Survival training is recommended. |
| NEPIA | 听 | Annex 1 | Passenger familiarisation should perhaps need to include muster locations? | agreed and Annex amended |
Original consultation
Consultation description
This consultation seeks comments on the revision of MGN 494 which provides guidance on the carriage of media, other organisations or persons as passengers on ships and fishing vessels
These MGNs are being updated to provide additional guidance on the conduct of risk assessment, particularly when children are to be on board and to ensure that they are consistent with the new guidance in MSN 1871 Amendment No.1, MSN 1872 Amendment No.1, MSN 1873 Amendment No.1, MGN 571, MGN 587 and MGN 588.
Documents
Updates to this page
Published 16 January 2019
Last updated 10 March 2025
show all updates
-
MGN 604 Consultation comments and MCA responses - Final Outcome.
-
Summary updated.
-
First published.