Validity of the RYA ICC
Validity of the RYA ICC
Wednesday, 6 September 2017
My attention was recently directed to a website suggesting that an ICC issued by the RYA is only valid on a UK registered vessel and for craft to 24m; these notes will hopefully reassure people who might be concerned by that claim.
The site maintains that the UK Maritime and Coastguard Agency (MCA) has advised the RYA that the ICC issued under their auspices is only valid for command of a UK registered vessel; however the RYA themselves would appear to regard this as a technicality, as they have RYA associate schools in e.g. Australia which issue ICC with inland endorsement, mostly to owners of non-UK registered vessels.
It also claims that the ICC is only valid for command of a vessel to 24m, justifying the claim by reference to the Merchant Shipping Act 2015 and subsequent MCA Notices. However the MCA is basically concerned with UK vessels proceeding to sea and foreign vessels in UK territorial waters; their jurisdiction does not extend to continental inland waterways.
As noted on my Certification page the ICC per se is issued to the person rather than the vessel and is in compliance with UN Resolution 40, and it is up to each country that is a signatory to Resolution 40 to put any limits it might require on its acceptance.
Dutch regulations specifically allow the holder of a UK ICC to command a Dutch registered vessel, though they do limit the length to 25m for an ICC issued after July 2011. Germany limits acceptance to vessels under 20m (15m on the Rhine), but Switzerland on the other hand explicitly notes that there is no limit on length of vessel.
In Belgium The Vade-mecum de la navigation de plaisance en Belgique published 2011 by Service public fédéral Mobilité et Transports lists the national certificates of other European nations including the UK at p.7 and gives their equivalence with the Belgian brevets. The footnote to the table reads “Un ICC (International Certificate for operators of pleasure Craft), délivré par un des pays ci-dessus, est également reconnu”. It makes no connection with the registry of the vessel itself.
Revised pleasureboat certification came into force in Belgium at 20/12/16 (see link), but there is no mention of change re the acceptance of foreign certificates, and the ICC in particular. https://mobilit.belgium.be/sites/default/files/navigation_expose_brevets_plaisance.pdf
In France the Decree 6 June 2008 relative to steering French motorised pleasure craft by foreign helmsmen and the issue of French certificates by equivalence with foreign certificates states (my translation):
“Art1.1 Foreign helmsmen with a certificate issued in their own country, either by the authorities of such country or an organisation recognised by these authorities, or an international certificate of competence for pleasure craft defined in Article 14 of the decree 2 August 2007 are authorised to steer a French pleasure craft within the limits of the prerogatives given by the certificate they hold”.
This specifies equivalence of an ICC issued under Article 14 (which preceded Resolution 40) and is anyway concerned with French vessels. However the list of certificats étranger which are accepted in France for visiting craft includes the ICC, with no mention of Res.14. It also puts no limit on the length of vessel on which the ICC is valid. The only instance of limitation is if an owner wishes to gain a French EGP; the ICC will only be accepted for issue of the Permis Fluvial for craft to 20m and he must then continue with the full EGP course.
Things may well change after Brexit, but owners currently only need an EGP (or other comparable certificate) if they wish to cruise Germany with a craft ≥20m or the Netherlands with one ≥25m, or to operate a hotel boat in France (in which case they should also have an attestation spéciale passagers).
Other relevant pages here are Certification for Helmsmen of Pleasure Craft, Certification for Helmsmen of Hotel Boats, and EGP Application.