number of tourist operators have indicated to us that they have recently received notices from Transport Canada requesting they fill out a Small Vessel Inventory Request for Information.
As we have written about in the past, changes to the Canada Shipping Act that were made several years ago have reclassified some boats used in our industry from pleasure craft to small commercial vessels. This request from Transport Canada is intended to help them to understand how many of our boats will now fall under the new small commercial vessel definition.
The simplest test of how a boat is classified is to ask who drives the boat. If the business operator or an employee drives the boat, it is a small commercial vessel. Rental boats that are driven only by guests are still classified as pleasure craft.
Generally, for the outdoor tourism industry, the boats that are re-classified as small commercial vessels will be any boats that are operated by guides and other “working boats” such as boats used to transport guests or supplies to camp. Boats that have multiple uses, such as those that are sometimes operated by guests and operated by guides at other times would also be treated as small commercial vessels.
Once they have completed this inventory, Transport Canada will be starting a process of inspection of small commercial vessels. For most of the boats used in our industry, there are no changes to construction or equipment standards, so they will simply be inspected for conformity to their original pleasure craft standards.
There were earlier concerns that Transport Canada would require special training for anyone operating these small commercial vessels. This has now been addressed, and the Pleasure Craft Operator Card will be the accepted qualification. There is also a requirement in the regulation for the carriage of Small Vessel Life Jackets rather than the PFDs that are approved for pleasure craft. However, implementation of this requirement is currently on hold as Transport Canada works on the development of a new, more compact Small Vessel Life Jacket standard. For now, PFDs remain acceptable.
NOTO is continuing discussions with Transport Canada regarding simplifying the application of these new regulations. Our arguments led to the acceptance of the Pleasure Craft Operator Card, and we will continue to urge the acceptance of PFDs. We will keep working with Transport Canada to make the inventory, inspection and registration process as simple as possible.
Please give the NOTO office a call if you have questions or concerns. Your comments will help us to continue to work with Transport Canada to make the transition to these new regulations as simple and painless as possible.
This article was taken from page 16 of NOTO's "The Outfitter" publication, Fall 2007 Issue