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Division 222 for vessels under 500 UMS: what is changing?

Division 222 is a regulation issued by the French maritime authorities to organize the safety of cargo ships of less than 500 UMS (Universal Measurement System) or less than 12 passengers.

On July 17, 2018, a new version of this regulation was published. It no longer speaks about recommendations for safety and maintenance of vessels but about objectives achieve.

Let's study the impact of this new version of Division 222 on the operation of private or charter yachts, fishing & passengers boats, etc.

What is the gross tonnage?

Before reviewing the changes to Division 222, it is important to understand what gross tonnage is. Gross tonnage is a measure of the size of a vessel and is calculated based on the volume of all enclosed spaces on the vessel, including storage and living spaces. A vessel with a gross tonnage of less than 500 UMS is considered a small cargo vessel.

Who is affected?

The new regulation applies to all cargo vessels with a tonnage of less than 500 gross measurement units (UMS).

The following boats are therefore affected by these changes:

  1. Small fishing vessels such as coastal fishing vessels and trawlers

  2. Passenger vessels, such as local ferries and tourist shuttles (less than 12 passengers)

  3. Port work vessels, such as tugs and service boats

  4. Yachts and superyachts, sailboats or pleasure motorboats carrying fewer than 12 passengers

  5. Cargo vessels, such as barges, barges and coastal tankers

Why these changes?

Prior to the amendment of Division 222, the design standards for these vessels were relatively flexible and not very stringent. Operators of these vessels were not required to comply with many strict safety, stability or load capacity regulations.

This new version is intended to respond to the technological, environmental and regulatory developments that have taken place in the maritime sector in recent years. It has also been motivated by new international standards governing maritime safety, in particular those established by the International Maritime Organization (IMO).

What changes have been made to Division 222?

The changes to Division 222 were introduced to enhance the safety and reliability of small cargo vessels by improving their design and operating conditions. The changes include more stringent requirements for vessel design, construction and maintenance, as well as higher requirements for crew training and certification.

Specifically, the requirements can be divided into three categories:

  1. Ship design and construction: ships and yachts must be able to withstand the most difficult sailing conditions and be able to undergo shocks, stability and watertightness problems. They must be designed to be stable enough to sail in all weather conditions.

  2. Vessel maintenance: regular inspections must be carried out to ensure that vessels and yachts are in good working order.

  3. Crew training and certification: all crew members, from the captain to the chief engineer, deckhand, steward and stewardess, must demonstrate a minimum level of knowledge of ship safety and maintenance. In particular, they must be able to react quickly when a danger arises and be able to deal with any risk at sea or on the quay.

All these occupational risks on board the ships and yachts concerned must be recorded in a Single Occupational Risk Assessment Document (Document Unique d'Évaluation des Risques Professionnels or DUERP in French). This document will include the list of identified risks, a risk hierarchy system (generally with 3 levels of risk), the analysis of the level of risk and an action plan explaining the measures taken to eliminate or reduce this risk.

Template of "Document Unique d'Évaluation des Risques Professionnels"

You can download a template of the Document Unique d'Évaluation des Risques Professionnels en milieu maritime, based on the recommendations of the French Ministry of the Sea on our website for free.

This document will help you to understand all the risks related to the operation of your boat, namely your crew's road trips, the safety of the vessel and navigation, traffic on the docks, embarkation and disembarkation, mooring and unmooring, anchoring, towing and taking a tow, driving the vessel, maintenance and upkeep work, circulation on board, hauling, machine work, hygiene, health and comfort on board, etc.

How to respond to this new regulation?

It is therefore clear that French regulations are increasingly structuring and regulating the operation of cargo vessels of less than 500 UMS, which include yachts for example.

The experts are unanimous and recommend that any shipowner or owner of such vessels take action in two stages:

  • technical audit and implementation of the "Document Unique d'Évaluation des Risques Professionnels"

  • set up an adequate maintenance software

You wish to be accompanied? Discover our missions of expertise, technical audit, etc. on this link.

Want to know more?

Find the advice of Philippe Vignaux, teacher and consultant specialized in the technical management of yachts and ships under 500 UMS in this video:

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