Capt. Ted Morley was raised aboard a schooner and has made a career working on board vessels ranging from superyachts to super tankers. During his tenure at sea, he worked his way up from seaman to master. He currently holds a USCG Master’s License, Unlimited Tonnage as well as several foreign certificates. Capt. Morley actively participates in maritime advisory committees in the U.S. as well as overseas and is involved in regulatory policy review in the U.S..
For years, captains, crew, and managers of large yachts have had to deal with a bevy of codes and standards. While the IMO STCW Code remains the international standard for training and certification, last year we saw a change in the requirements that the Red Ensign yachts must comply with. The MCA had initially established the Large Yacht Code 3 (LY3) and the Passenger Yacht Code (PYC), dependent upon the tonnage and the number of passengers the yacht carried.
In 2019, the Red Ensign Group Yacht Code (REG Code) was implemented as a replacement to these two codes. The goal was to standardize and simplify existing yacht codes across the Red Ensign registries. This code was introduced in 2017 to provide time for vessel operators to learn more about it prior to implementation, but there are still many questions.
While the REG Code does not change the STCW Code, it does discuss emergency training and drills along with equipment and kit that must be carried aboard applicable yachts in both the over and under 500 GT categories.
The code is split: Part A for large yachts carrying up to 12 passengers and Part B for passenger yachts carrying up to 36 passengers (this count doesn’t include seafarers or occasional workers on board). There are also Common Annexes that pertain to the classifications. If a yacht is engaged in trade that includes cargo, it must then comply with a different set of rules that govern commercial cargo vessels.
While the REG Code does not change the STCW Code, it does discuss emergency training and drills along with equipment and kit that must be carried aboard applicable yachts in both the over and under 500 GT categories. This means that the code is designed specifically for yachts and is not intended for commercial cruise or ferry vessels as outlined in the STCW Code and SOLAS Convention. This simplifies many of the large yacht construction and operational requirements but still refers to the applicable STCW Code and flag state requirements for crew manning, training, and certification. SOLAS is also referenced in the various code sections and remains the international compliance standard.
Whereas the new REG Code simplifies and clarifies the previous codes, the crew still must comply with the STCW and flag state requirements. Captains and managers are advised to research the REG Codes and perhaps engage an industry expert to guide them through the implementation of the new code aboard. All applicable Red Ensign yachts must comply with the new code as of their first compliance survey after January 1, 2019. Many yachts have adopted a program in which they work to phase in their compliance. Yachts with their keels laid after January 1, 2019, must comply with the requirements that include structural changes to ensure full compliance.
A year into implementation and there are still yachts that don’t fully understand the new regulations. You can download Part A and Part B and the Common Annexes to familiarize yourself with the relevant sections.
The column originally ran in the April 2020 issue of Dockwalk.