Workboat Code Edition 3

Workboat Code Edition 3: understanding the requirements and preparing your operation

With 13 December 2026 approaching, workboat owners and operators should check both their vessel’s certification arrangements and the readiness of their Safety Management System.

Workboat Code Edition 3 brings together requirements covering vessel construction, equipment, crewing and operational safety. For operators, preparation means understanding what applies to each vessel and being able to demonstrate that safety arrangements work in practice.

Understanding the transition dates

Edition 3 entered into force on 13 December 2023. The MCA’s general transition rule for existing vessels certificated under the Brown Code, the relevant provisions of MGN 280 or Workboat Code Edition 2, Amendment 1 is the next renewal examination or three years after entry into force, whichever is later. Individual provisions can specify different treatment.

This means 13 December 2026 is a significant transition date, but should not be presented as every existing vessel’s renewal deadline. Check your vessel’s certificate and examination history with its Certifying Authority.

The MCA and Workboat Association have urged affected operators to prepare and book surveys early, warning that limited availability could leave vessels waiting for certification.

What needs checking?

A vessel review should address construction and watertight integrity, stability, machinery and electrical installations, lifesaving and firefighting equipment, navigation, radio communications, crewing and qualifications. Specialist activities, including towing and lifting, introduce further considerations.

Safety management is another central requirement. Section 31 requires a proportionate SMS covering relevant activities onboard and ashore. Appendix 8 addresses policies, risk assessments, responsibilities, training, operating procedures, emergencies, accident reporting, maintenance and review.

Operators must also designate a person ashore with appropriate knowledge, experience, authority and resources. Cybersecurity requires its own proportionate measures and risk assessment; protecting an online document platform alone does not address every vessel cyber risk.

When must the SMS be implemented?

MCA guidance states that vessels certificated under Edition 3 must implement a proportionate SMS by 13 December 2026. Remotely operated unmanned vessels certificated under the Code were required to implement one from its entry into force.

The guidance distinguishes an operational system from a manual alone. Owners and operators should demonstrate implementation through a self-assessment or an alternative method providing comparable evidence. Where self-assessment is used, the guidance recommends at least one assessment per vessel within each relevant 12-month period.

The Certifying Authority samples implementation evidence at vessel examinations. Its role does not extend to developing the SMS or auditing it in detail. Responsibility remains with the owner or operator.

Making safety management useful onboard

A useful starting point is to follow an ordinary working day through the system. Can the skipper find the relevant procedure? Does a new crew member understand the emergency arrangements? When someone reports a defect, is it clear who decides what happens next?

An operator preparing for examination could bring together familiarisation and drill records, maintenance and defect reports, risk assessments, incident reports and evidence that actions have been completed. These records help explain how the operation manages its risks.

For example, a defect report becomes more useful when it records the immediate precautions, the person responsible for repair and the confirmation that the equipment can return to service. The same approach helps turn lessons from drills and near misses into practical improvements.

How Liberation Maritime can help

Liberation Maritime helps workboat owners and operators develop and maintain Safety Management Systems suited to their vessels, people and activities.

We start by reviewing the operation and its existing arrangements, identifying gaps and agreeing priorities. We then develop tailored procedures, risk assessments and records, supported by practical guidance for the people using them onboard and ashore.

Implementation support helps management, skippers and crew understand their responsibilities, follow reporting routes and use the system confidently. This can include management walkthroughs, crew familiarisation and guidance on drills, reporting and corrective action.

As operations change, we provide separately scoped annual SMS reviews and additional support for training, internal audits, new vessels or activities, and incident investigations.

For operators seeking external shore-side support, a Designated Person Ashore service can be arranged under a separate appointment with defined responsibilities, authority and contact arrangements. Engaging an external provider supports the operator’s management arrangements while the operator retains responsibility for safe operation.

Digital access onboard and ashore

Liberation Maritime is developing a managed digital SMS service combining tailored content, a secure platform and a configured ruggedised onboard tablet.

The service is being designed to support controlled documents, reporting forms, training and drill records, and oversight of outstanding actions. Offline access to essential documents and agreed forms is central to its development, allowing crews to use the system where connectivity is limited.

The aim is to make safety management easier to use during everyday work, while giving management a clearer view of what needs attention. Contact us to discuss digital SMS availability and the needs of your operation.

Preparing your next steps

Start by confirming your vessel’s transition position with its Certifying Authority. Review the applicable technical requirements alongside your SMS, assign responsibility for outstanding work and organise evidence of implementation.

Liberation Maritime can help you scope that work and develop a practical route forward. Contact us to discuss your vessels, existing arrangements and support needs.

The operator remains responsible for safe operation and implementation of its SMS. Consultancy support does not replace vessel certification.

Sources

The Workboat Code Edition 3: https://www.gov.uk/government/publications/the-workboat-code-edition-3

MCA transition advice: https://www.gov.uk/government/news/united-message-for-workboat-code-edition-3-deadline-check-prepare-book

MGN 710: safety management systems for small workboats and pilot boats: https://www.gov.uk/government/publications/mgn-710-m-safety-management-systems-for-small-workboats-and-pilot-boats/mgn-710-m-safety-management-systems-for-small-workboats-and-pilot-boats