14 February 2025

Support our response to the new MCA Sport or Pleasure Vessel Code

The Ellen MacArthur Cancer Trust has produced a response to proposals in the new Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 2025. We are asking people to support our response before the consultation period ends on Tuesday 25 February 2025.

The Maritime and Coastguard Agency (MCA) has been working on a new Code of Practice for Small Vessels in Commercial use for Sport or Pleasure ('Sport or Pleasure Vessel Code'). This new Code will set out the legal and safety requirements under which the Ellen MacArthur Cancer Trust operates in the future. You can read the full details here - Merchant Shipping (Vessels in Commercial Use for Sport or Pleasure) Regulations 2025.

The Ellen MacArthur Cancer Trust is committed to running safe sailing trips and has made clear it welcomes measures to enhance the safety of its operations. But it believes these measures should be evidence-based and proportionate, and not negatively impact the ability to deliver its charitable aims of supporting as many young people living through and beyond cancer as possible from across the UK.

All Ellen MacArthur Cancer Trust trips are free at the point of delivery. Any amendments to the Code that could have significant cumulative cost implications will inevitably mean the charity is not able to support as many young people.

The proposed code is now in a period of consultation, which closes at midnight on Tuesday 25 February.

What we're asking you

Every response to the MCA carries the same weight - an individual counts the same as an organisation.

We have submitted our organisation response. But for our voice to really be heard through this consultation, we are asking you - as people who know and love the Ellen MacArthur Cancer Trust - to also respond on our behalf before the deadline. The more responses we get, the louder our voice.

Here is a template letter you can download and complete - EMCT MCA Response Letter - February 2025

Please return completed response letters to:

Please note: All responses must be received no later than midnight on Tuesday 25 February 2025 and all submissions will be in the public domain.

What we're asking the MCA

There are six points the Ellen MacArthur Cancer Trust is specifically asking the MCA to carefully consider, to improve clarity.

Definition of ‘Crew’ – young people on Ellen MacArthur Cancer Trust trips are by sail training definition ‘Trainees’, in that they have no legal safety responsibilities. The charity is advocating for the removal of the word ‘Trainees’ from the revised definition of ‘Crew’, plus adding ‘Trainees’ to the Code text where appropriate/required, to ensure the status quo remains.

Additional training requirements (Radar & Stability) – if it is a requirement for those in charge of a navigational watch to complete a 2.5 day Radar course and for all skippers a one-day stability course, there will be cost implications for the Ellen MacArthur Cancer Trust, while the number of available freelance skippers will also decrease, impacting the ability to run trips. The charity doesn’t believe these proposals will make its operations safer, and that the RYA Yachtmaster syllabus covers stability in sufficient depth and the one-day RYA Radar course also meets requirements. On this basis, the charity strongly advocates for the inclusion of the RYA Radar Course in the list of MCA-approved or recognised courses.

New equipment

  1. Personal Locator Beacons – on trips, multiple people, including trainees, are on deck at any one time. By making it a requirement for a crewmember to wear a PLB equipped with GPS and a light whilst on open deck, it is difficult to understand who would wear this single PLB when more than one or two people are on deck at the same time. The cost of equipping all lifejackets with this equipment is prohibitive. The Ellen MacArthur Cancer Trust feels this should be a ‘recommendation’ not a ‘requirement’ and believes in a man overboard situation on sail training vessels, the priority should be everyone onboard is alerted – to keep eyes on the MOB - rather than prioritising a land station.
  2. Immersion suits –the charity runs trips from its Scottish base – for which this point is relevant – in June to early September. To provide immersion suits to all crew and trainees for every trip during that period would be exceptionally costly, have significant storage implications and be disproportionate for the time of year the trips are running and the distance travelled on them.

New certification

  1. Stability reassessment – the Ellen MacArthur Cancer Trust strongly believes a stability reassessment at 20 years should not be required unless there is a change in the area or category of operation or modifications to the vessel. The charity also seeks greater clarity over what would be included in any 20-year reassessment process. Depending on what was required, it is estimated work could cost £2,000 to £20,000, expenditure that would impact the ability to support as many young people as now and/or the fleet available to run trips on.
  2. Change to examination regime for vessels over 20 years old – the Ellen MacArthur Cancer Trust recognises vessels over a certain age may need a more stringent examination regime. But it is felt the proposed regime of an in-water inspection every year is more than is necessary and will have a significant cost implication. The charity believes a more suitable change to the current system would be to have the midterm inspection out of the water, which would reduce the burden of cost whilst giving an opportunity for a thorough examination.

Of the four vessels the Ellen MacArthur Cancer Trust owns, one (Moonspray) is over 20 years old. The proposed changes in examination regime and stability reassessment would make her financially unviable.

You can view our full submission here - EMCT MCA Full Consultation Response - February 2025

Thank you for your support.

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