PMSC Appendix 4 - Audit_Islay_Redacted

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Argyll and Bute Council
Port Marine Safety Code
Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023
January 2024
Appendix 4

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Port Marine Safety Code
Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023
January 2024

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | i
Document Information
Document History and Authorisation
Title Port Marine Safety Code
Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023
Commissioned by Argyll and Bute Council
Issue date January 2024
Document ref R.4231
Project no R/4952/01
Date Version Revision Details
17 January 2024 1 Issued for client review
Authorised
(Designated Person)
Approved
(Quality Manager)
Authorised
(Project Director)
Monty Smedley Capt. Trevor Auld Gordon Osborn
Suggested Citation
ABPmer, (2024). Port Marine Safety Code, Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023, ABPmer Report No.
R.4231. A report produced by ABPmer for Argyll and Bute Council, January 2024.
Author
M.J. Smedley
Notice
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Accepted as Issued for client use

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | ii
Contents
1 The Port Marine Safety Code ................................................................................................ 1
1.1 About the Harbour Authority ................................................................................................................. 2
2 Purpose and Method ............................................................................................................... 3
2.1 Audit scope .................................................................................................................................................... 3
2.2 Audit definitions and outcomes ............................................................................................................ 3
2.3 Audit date and criteria .............................................................................................................................. 4
2.4 Auditor............................................................................................................................................................. 4
2.5 Auditees .......................................................................................................................................................... 4
3 Audit Summary ........................................................................................................................... 5
3.1 Summary of Observations ....................................................................................................................... 5
3.2 Summary of Quayside Checks ............................................................................................................... 6
4 References .................................................................................................................................... 8
4.1 Websites ......................................................................................................................................................... 8
5 Abbreviations/Acronyms ........................................................................................................ 9
Appendices
A Detailed Audit Findings ........................................................................................................ 12
A.1 PMSC Section 1 – Accountability for Marine Safety .................................................................. 12
A.2 PMSC Section 2 – Key Measures Needed to Secure Marine Safety .................................... 16
A.3 PMSC Section 3 – General Duties and Powers ............................................................................. 25
A.4 PMSC Section 4 – Specific Duties and Powers ............................................................................. 28
B Quayside Check ....................................................................................................................... 35
B.1 Quayside Check: Port Askaig ............................................................................................................... 35
B.2 Quayside Check: Bruichladdich Pier ................................................................................................. 42
B.3 Quayside Check: Port Charlotte ......................................................................................................... 47
Images
Image B1. Port Askaig, mooring lines South Pier ............................................................................................. 38
Image B2. Port Askaig, vessel waste and rubbish on the quayside ........................................................... 38
Image B3. Port Askaig, mixed passenger and vehicle use ............................................................................ 39
Image B4. Port Askaig, obstructed water egress ladder ................................................................................ 39
Image B5. Port Askaig, unattached life ring ........................................................................................................ 40
Image B6. Port Askaig, bollard ................................................................................................................................. 40
Image B7. Port Askaig, broken capping rail ........................................................................................................ 41
Image B8. Port Askaig, equipment inappropriately fixed .............................................................................. 41
Image B9. Bruichladdich, stone pier plant growth and moorings ............................................................. 44
Image B10. Bruichladdich, severely corroded water egress ladder ............................................................. 44
Image B11. Bruichladdich, life ring incorrectly secured .................................................................................... 45
Image B12. Bruichladdich, oil pollution equipment storage .......................................................................... 45
Image B13. Bruichladdich, bollard ............................................................................................................................. 46
Image B14. Bruichladdich, illegible signage .......................................................................................................... 46
Image B15. Port Charlotte, life ring incorrectly secured ................................................................................... 49
Image B16. Port Charlotte, degraded mooring ring .......................................................................................... 49

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 1
1 The Port Marine Safety Code
The Port Marine Safety Code (‘the Code’) sets out a national standard for every aspect of port marine
safety. Its aim is to enhance safety for everyone who uses, or works in, the UK port marine environment.
It is authored by the UK Government, supported by the devolved administrations and representatives
from across the maritime sector and, whilst the Code is not mandatory, these bodies have a strong
expectation that all harbour authorities will comply. The Code is applicable both to Statutory Harbour
Authorities and to other marine facilities, which may not have statutory powers; these are collectively
referred to throughout the Code as ‘organisations’ (DfT, 2016).
In reading this audit report, the Council and Duty Holder should note the following extract from the
Code:
“The Code does not contain any new legal obligations but includes (amongst other things) references
to the main legal duties which already exist. Failure to comply is not an offence in itself. However,
the Code represents good practice as recognised by a wide range of industry stakeholders and a failure
to adhere to good practice may be indicative of a harbour authority being in breach of certain legal
duties. Moreover, the organisation may suffer reputational damage if it has publicly committed to
the Code’s standards and then fails to meet them.”
(DfT, 2016)
In order to measure compliance with the Code, the table below sets out the 10 Duty Holder
responsibilities, and corresponding cross-references with sections of the Code, which this audit has
considered.
No PMSC Duty Holder Responsibilities PMSC Section
Reference
1 Duty Holder Formally identify and designate the Duty Holder, whose members are
individually and collectively accountable for compliance with the Code
and their performance in ensuring safe marine operations in the harbour
and its approaches.
1.6-1.8, 1.10, 1.16-1.17
2 Designated
Person
A ‘Designated Person’ must be appointed to provide independent
assurance about the operation of the marine safety management system.
The designated person must have direct access to the Duty Holder.
1.11-1.12
3 Legislation The Duty Holder must review and be aware of their existing powers
based on local and national legislation; seeking additional powers if
required in order to promote safe navigation.
2.3-2.6,
4.3-4.5
4 Duties and
Powers
Comply with the duties and powers under existing legislation as
appropriate.
1.3-1.5, 1.9, 1.13-1.15,
3.1-3.14,
4.2, 4.6-4.20, 4.25-4.32
5 Risk
Assessment
Ensure all marine risks are formally assessed and are eliminated or as low
as reasonably practicable in accordance with good practice.
2.7-2.11
6 Marine Safety
Management
System
Operate an effective marine safety management system which has been
developed after consultation, is based on formal risk assessment, and
refers to an appropriate approach to incident investigation.
2.12-2.17, 2.19-2.23,
2.25, 2.29
7 Review and
Audit
Monitor, review and audit the risk assessment and marine safety
management system on a regular basis – the independent designated
person has a key role in providing assurance for the Duty Holder.
2.2, 2.24, 2.30-2.32
8 Competence Use competent people (i.e. trained, qualified and experienced) in
positions of responsibility for managing marine and navigation safety.
2.18
9 Plan Publish a safety plan showing how the standard in the Code will be met
and a report assessing the performance against the plan at least every 3
years.
2.26-2.28
10 Aids to
Navigation
Comply with directions from the General Lighthouse Authorities and
supply information and returns as required.
4.21-4.24

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
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1.1 About the Harbour Authority
The Isle of Islay is the is the southernmost island of the Inner Hebrides of Scotland. It lies in Argyll just
south west of the Isle of Jura and around 40 kilometres (22 nautical miles) north of the Northern Irish
coast. The Isle’s main port is Port Ellen, which is owned by Caledonian Maritime Assets Limited (CMAL)
and operated by CalMac Ferries Limited (CFL). Islay’s other ports includes Port Askaig, Bruichladdich
and Port Charlotte. These locations are owned by Argyll and Bute Council (A&BC) as both a Harbour
Authority and Marine Facility operator. Other privately owned ports and marine facilities are also
located around Islay’s coast.
1.1.1 Port Askaig
Port Askaig is a Statutory Harbour Authority (SHA) by virtue of ‘The Pier and Harbour Order
Confirmation (No 3) Act, Schedule: Islay Piers Order, 1904 and the subsequent ‘Port Askaig Pier Order
Confirmation Act 1975. These are collectively known as the ‘Port Askaig Acts and Order 1904 to 1975’.
A&BC is therefore the Local Lighthouse Authority (LLA) with respect to aids to navigation through
Section 193 of the Merchant Shipping Act 1995. A&BC is not a Competent Harbour Authority for Port
Askaig.
Port Askaig is a busy port hosting a CFL ferry terminal with connections to Kennacraig and the Isle of
Colonsay. The port also maintains an inter-island ferry to the Isle of Jura, for both foot passengers and
vehicle traffic, this ferry service and route is provided by A&BC. The port is an important location for
commercial fishing vessels, with quayside facilities for safe berthing, landing catch and vessel mooring.
The port also hosts the Royal National Lifeboat Institute (RNLI) who operate a Severn Class Boat named
the ‘Helmut Schroder of Dunlossit II’ from a dedicated berth, with facilities offered by a fully fitted out
office, crew room and operational rooms.
1.1.2 Bruichladdich Pier
Bruichladdich Pier is an SHA by virtue of ‘The Pier and Harbour Order Confirmation (No 3) Act, Schedule:
Islay Piers Order, 1904’. A&BC is therefore the Local Lighthouse Authority (LLA) with respect to aids to
navigation through Section 193 of the Merchant Shipping Act 1995. A&BC is not a Competent Harbour
Authority for Bruichladdich Pier.
Bruichladdich Pier located on the western shore of Loch Indaal, this Pier is operated commercially by
Gleaner Oils on behalf of A&BC and is used exclusively for tankers. The Pier consists of an original solid
stone structure augmented by eight berthing and mooring dolphins and associated walkways to
accommodate larger double hulled coastal tankers. The stone Pier serves the local community with
small inshore fishing vessels, creel boats and day boats making use of the facility. Tanker activity
between the years 2015 and 2023 ranges between six vessels and two vessel visits per year.
1.1.3 Port Charlotte
Port Charlotte is a village located on the western shore of Loch Indaal. The Pier at Port Charlotte is a
solid stone and concrete structure, with a sea wall on its northern side and an open Pier to the south.
Securing points in the form of mooring rings are installed on the Pier, as is a water egress ladder and
stone access steps. It is used exclusively by recreational and small inshore fishing vessels. The Pier at
Port Charlotte is a marine facility, owned and operated by A&BC. It is not an SHA, nor does it have any
lighting or ancillary services.

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
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2 Purpose and Method
2.1 Audit scope
Argyll and Bute Council (A&BC) has contracted ABPmer to provide Designated Person services for its
ports, harbours and piers. Part of this service includes the provision of annual auditing to establish if
the Harbour Authority is compliant with the requirements of the Port Marine Safety Code (PMSC). The
scope of the audit includes a review of Harbour Authority performance against the standard laid out
within the latest edition of the Code. Any aspects that do not comply with, or fully address, the
requirements of the Code will be identified, and recommendations for improvement will be made.
2.2 Audit definitions and outcomes
The following definitions are used in the audit report:
Non-compliance: is a failure to adhere to a legal requirement such as an Act, Order or its Regulations.
The Port Marine Safety Code requires organisations to confirm compliance with the requirements of the
Code. Therefore, Port Marine Safety Code audits are designed to test the requirements of the Code
with any failure to comply identified as a ‘non-compliance’.
Non-conformity: is an opportunity for the management system to improve through the identification
of a requirement that is not met. Non-conformities are not regulatory but relate to the port or harbour’s
own operational instructions which are not met or fully met. Any non-conformities identified through
the audit process are identified in bold text in the report.
Evidence: Non-compliances and Non-conformities are identified through factual evidence sampled
during the audit.
2.2.1 Outcomes
The audit report uses the following outcomes:
Non-Compliance: a non-compliance with the requirements of the Code which are a
breach of legal obligations or may compromise marine safety, environmental safety or
present a significant reputational risk. Recommendations for addressing non-
compliances are identified in red.
Observation: refers to an improvement opportunity such as an update to information,
procedural change, or a non-conformity with local operating instructions. Whilst
observations are defined as improvement opportunities, addressing them may improve
the overall system standard. Recommendations for addressing observations are
identified in yellow.
Satisfactory: a system component that meets or exceeds the requirements of the Code.
Items of best practice are identified in bold.
Not applicable: part of the Code that is not relevant to the Organisation being audited.

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2.3 Audit date and criteria
The onsite check of port, harbour and pier facilities was carried out on the Isle of Islay on Thursday
11 May 2023 with the check of marine safety management system requirements carried out on
12 October 2023.  The latest version of the PMSC, and the accompanying Guide to Good Practice (GtGP),
have been used as the benchmarking standard within Appendix A.  The audit tables also identify the
paragraph numbers from the Code (DfT, 2016) and relevant sections of the Guide to Good Practice
(DfT, 2018), for cross reference purposes.   
In addition, within Appendix B the Health and Safety Executive (HSE) publication L148 ‘Safety in Docks:
Approved Code of Practice and Guidance’ (ACOP) (HSE, 2014) and the Port Skills and Safety (PSS)
publications SIP 005 ‘Guidance on Mooring’ (PSS, 2019a) and SIP 014 ‘Guidance on Safe Access and
Egress’ (PSS, 2019b) have been used.  The Appendix tables to this report contain the test questions and
evidence, noting down compliance, non-compliance and observational remarks.  
2.4 Auditor
The following auditor conducted this audit.   
Team Member Initials Company, Designation
Monty Smedley MJS
ABPmer, Principal Maritime Consultant
Lead Auditor for Quality Management Systems (QMS ISO 9001)
Designed Person (PMSC) Argyll and Bute Council
2.5 Auditees
The following individuals participated in the audit.   
Team Member Initials Role/Designation
Allan Finlay AF Piers and Harbours – Technical Officer
John Willis JW Assistant Harbour Master – Campbeltown
Scott Reid SR Marine Operations Manager

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
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3 Audit Summary
Number Key Measures
Ten-Point ‘Health Check’
1 Duty Holder 0 2 5
2 Designated Person 0 0 2
3 Legislation 0 3 5
4 Duties and Powers 0 14 36
5 Risk Assessment 0 2 5
6 MSMS 0 6 10
7 Review and Audit 0 0 4
8 Competence 0 3 2
9 Plan 0 0 3
10 Aids to Navigation 0 0 2
Total 0 30 74
The summary presented in the above table identifies that, for the ten-point health-check, Argyll and
Bute Council as the Statutory Harbour Authority for Port Askaig and Bruichladdich Pier, plus the Marine
Facility owner for Port Charlotte Pier, is found to be compliant with the requirements of the Port Marine
Safety Code. The following item of best practice was identified during the audit:
 Provision and maintenance of Aids to Navigation is recognised as an area of best practice with a
100% availability for Category 3 and 99.56% for Category 2 Aids.
3.1 Summary of Observations
The PMSC audit (at three locations) identified 30 observations relating to improvement opportunities
for management consideration, the detailed findings being presented in Appendix A. The following
points identify the more significant items, split by port location.
 Not all Councillors on the Harbour Board have attended Duty Holder training, the Marine Safety
Plan has an objective of 100% attendance.
 The MSMS, Section 1.2.2 does not list Bruichladdich Pier as an SHA.
 Marine risk assessments for Port Askaig, Bruichladdich, Port Charlotte were all reviewed in the same
month. It is recommended that risk assessment review is staggered over the year.
 Whilst the MSMS provides for Council processes, the Standard Operating Procedures (SOPs) specific
to Port Askaig, Bruichladdich and Port Charlotte require further development.
 The MSMS, Section 1.2 and 1.6 provide a high-level structure regarding responsibilities for marine
safety. The way these responsibilities are met at Port Askaig, Bruichladdich and Port Charlotte is
not clearly laid out. In practice, the Harbour Master team from Campbeltown has operational
oversight for these locations, with local Council staff at Port Askaig (whose primary role is the
operation of the Jura Ferry) providing both marshalling and onsite support. Lastly, an Islay based
Council services operator provides maintenance services. This structure is not documented fully in
SOPs.

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
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 There are no routine stakeholder meetings at Port Askaig, Bruichladdich or Port Charlotte. Meetings
are held, but around specific needs and requirements. It is recommended that port user groups or
forums are set up for Islay.
 The lack of Port or Pier onsite staff at Port Askaig, Bruichladdich and Port Charlotte means there is
no-one immediately on-hand to respond to an incident or monitor vessel traffic. Whilst
Bruichladdich and Port Charlotte do not have regular vessel traffic, Port Askaig is a busy port. The
A&BC operated Jura Ferry is staffed by Council employees; however, their principal focus is the safe
and efficient operation of the ferry. It is recommended that the Council conduct a review of staff
resource for its Ports and Pier on Islay.
 There is no specific emergency plan for Port Askaig or Bruichladdich Pier.
 There is no LPS provision at Port Askaig outside of port user information available on A&BC’s
website. There is also no routine arrival or departure contact procedure for the CFL ferry with the
Harbour Authority. If the Jura Ferry is using the linkspan berth (due to the tide being too low for
the Jura Ferry to use the slipway) vessel traffic management is arranged between vessel Masters.
The Council should consider if this is an effective form of berth allocation.
3.2 Summary of Quayside Checks
Marine operations and quayside checks were also carried out, 16 observations were identified
cumulatively for all three locations. The following provides a summary of more significant items:
3.2.1 Port Askaig (Appendix B.1)
 At the time of the quayside checks, there were numerous mooring lines causing obstruction along
the southern Pier. It is recommended that housekeeping is improved with vessel Masters and
owners required to remove unnecessary lines from quayside areas.
 In several locations, due to the amount of available space and port road layout, both pedestrians
and vehicles use the same area. This was especially noted when the CFL Ferry passenger embarked
and disembarked, with vehicles dropping off or collecting foot passengers. It is recommended that
a review of the layout around the ferry berth is conducted with reference to the Health and Safety
Executive (HSE) publication L148 ‘Safety in Docks: Approved Code of Practice and Guidance’ (HSE,
2014) Section 58 to 72 ‘Safe site – design and activity’.
 Some of the water egress ladders were obstructed by mooring lines and not all life ring housings
were fixed in location.
3.2.2 Bruichladdich Pier (Appendix B.2)
 The common user stone Pier had a number of mooring lines obstructing the stone steps used to
access and egress the launch point and water.
 One of the water egress ladders at the original stone Pier was severely corroded with the rungs
unusable.
 Not all life rings were in a serviceable condition and housed correctly.
 A number of Pier signs had weathered and deteriorated to the point of being illegible.

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3.2.3 Port Charlotte (Appendix B.3)
 The life ring housing was broken and not secured to its support.  
 Some of the mooring rings were visibly deteriorated and may not provide sufficient restraint
capacity. 
 There is no signage at the Pier.  It is recommended that signage with A&BC’s details as the marine
asset owner is installed.

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4 References
ABPmer, 2016. Port Askaig: Navigational Risk Assessments. R2536. February 2016.
DfT, 2016. Port Marine Safety Code, Department for Transport (DfT) a, November 2016.
DfT, 2018. A Guide to Good Practice on Port Marine Operations Prepared in conjunction with the Port
Marine Safety Code 2016, Department for Transport (DfT), February 2018.
Health and Safety Executive (HSE), 2014. ‘Safety in Docks: Approved Code of Practice and Guidance’
(ACOP)’, Publication L148.
ISO 9001: Quality Management Systems. International Organization for Standardization.
Port Skills and Safety (PSS), 2019a. Guidance on Mooring, SIP 005. March 2019.
Port Skills and Safety (PSS), 2019b. Guidance on Safe Access and Egress, SIP 014. September 2019.
4.1 Websites
https://www.argyll-bute.gov.uk/sites/default/files/2023-05/dp_contact_information3_abc.pdf
https://www.argyll-
bute.gov.uk/moderngov/ieIssueDetails.aspx?IId=123876&PlanId=0&Opt=3#AI150723
https://www.argyll-bute.gov.uk/sites/default/files/2023-11/Marine%20Training%20Policy.pdf
https://www.argyll-bute.gov.uk/form/reporting-an-accident-or-inciden
https://www.argyll-bute.gov.uk/roads-and-travel/marine-services/marine-safety-management-system
https://www.gov.uk/government/publications/port-marine-safety-code-compliant-ports/port-marine-
safety-code-compliant-ports-list
https://www.argyll-bute.gov.uk/roads-and-travel/marine-services/port-askaig-pier
https://www.argyll-bute.gov.uk/roads-and-travel/marine-services/bruichladdich-pier
https://www.calmac.co.uk/article/2150/Port-Askaig
https://www.argyll-bute.gov.uk/fees/22/piers

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5 Abbreviations/Acronyms
A&BC Argyll and Bute Council 
ACOP Approved Code of Practice and Guidance
ALRS Admiralty List of Radio Signals
AtoN Aid(s) to Navigation
BPA British Ports Association
CARP Critical Activity Recover Plan
CAT Category
CERS Consolidated European Reporting System
CFL CalMac Ferries Limited
CHA Competent Harbour Authority
CMAL Caledonian Maritime Assets Limited
DfT Department for Transport
DRA Dynamic Risk Assessment
FRA Formal Risk Assessment 
GLA General Lighthouse Authority
GtGP Guide to Good Practice on Port Marine Operations
HDPCA Harbour, Docks and Piers Clauses Act 1847
HRO Harbour Revision Order
HSE Health and Safety Executive
IMO International Maritime Organization
ISO International Organization for Standardization
KPI Key Performance Indicator
LATON Local Aids to Navigation
LLA Local Lighthouse Authority
LPS Local Port Service
LSE Lifesaving Equipment
MAIB Marine Accident Investigation Branch
MARNIS Marine Risk Software Produced by ABPmer
MCA Maritime and Coastguard Agency
MGN Marine Guidance Notes
MSMS Marine Safety Management System
n/a Not Applicable

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OPRC International Convention on Oil Pollution Preparedness, Response and Co-operation
PEC Pilotage Exemption Certificates
PFSP Port Facility Security Plan
PMSC Port Marine Safety Code
PSS Port Skills and Safety
QMS Quality Management System
RATSA Railways and Transportation Safety Act
RNLI Royal National Lifeboat Institute 
SAC Special Areas of Conservation
SEPA Scottish Environment Protection Agency 
SHA Statutory Harbour Authority
SIP Safety in Port
SOPs Standard Operating Procedures
SOSREP Secretary of State's Representative
SPA Special Protection Areas
SWL Safe Working Load
UK United Kingdom
UKHO United Kingdom Hydrographic Office
VHF Very High Frequency
VTS Vessel Traffic Service 
Cardinal points/directions are used unless otherwise stated. 
SI units are used unless otherwise stated.

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Appendices

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
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A Detailed Audit Findings
A.1 PMSC Section 1 – Accountability for Marine Safety
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
1.3-1.5 Duties and
Powers
Is the Organisation’s Duty
of Care for users of the
harbour, port of facility
stated?
Satisfactory – A&BC’s Marine Safety
Management System (MSMS), ‘Policies and
Statements’, Volume 1, revision 01, issued
November 2023. The MSMS, Section 3.1
under National Legislation states: “Harbour
Authorities have a range of statutory and non-
statutory duties and powers relating to marine
operations. The Council has a Duty of
reasonable Care to its harbour users and will
ensure the safety at work of employees and
other persons who may be affected by the
Authority's activities as far as is reasonably
practicable to do so”. Additionally, Section 10
‘Conservancy’ also states that: “There is a duty
to conserve a harbour so that it is reasonably
fit for use as a port, and a duty of reasonable
care to see that the harbour is in a fit condition
for vessels to use.”
MJS_001 MJS
Are local Acts and Orders
identified?
Satisfactory – the harbour authority has a
copy of its local legislation. Local Acts and
Orders 1904 to 1975 include:
 The Pier and Harbour Order Confirmation
(No 3) Act, 1904. Schedule ‘Islay Piers
Order 1904’.
 The Port Askaig Pier Order Confirmation
Act 1975.
MJS_008
MJS_009
MJS
Is the Harbour, Docks and
Piers Clauses Act (HDPCA)
1847 incorporated into local
Acts and Orders?
Satisfactory – the HDPCA has been
incorporated into the ‘Pier and Harbour Order
Confirmation (No 3) Act, 1904. Schedule ‘Islay
Piers Order 1904’, with certain exceptions.
MJS_008
MJS_009
MJS

Page 18

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 13
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
1.6 – 1.7 The Duty Holder Has the organisation
appointed and confirmed
who the Duty Holder is?
Satisfactory – A&BC has assigned the post
and accountability of the Duty Holder to the
Council’s Executive Director of Development
and Infrastructure Services. The Harbour
Board retains responsibility for providing
policy direction to the officers of the
Authority. An organisational structure is
provided the MSMS, Section 1.6.
MJS_001 MJS
1.8 The Duty Holder Are the Duty Holder’s
responsibilities for
compliance with Code
defined?
Satisfactory – the MSMS, Section 1.4 lists the
principal requirements of the Duty Holder.
MJS_001 MJS
1.10 The Duty Holder Does the Duty Holder (and
Harbour Board members)
have a clear understanding
of the port’s marine
activities and MSMS?
Satisfactory – the Harbour Board and Duty
Holder receive information from officers of
the Authority, presented as technical reports
to Board Meetings. Periodically the Harbour
Board and Duty Holder visit one of the
Council’s ports, harbours or piers. The last
Oban visit was on 24 September 2021. The
Harbour Board were also invited to the
Campbeltown Emergency Response Exercise
in November 2021. The MSMS is provided on
the Council’s website.
Observation – the Council is encouraged to
arrange an opportunity in 2024 for the Duty
Holder and Board to visit one of the
Authority’s ports, harbours or piers.
Recommendation – to provide awareness
of the Council’s ports, harbours and piers,
arrange an annual visit for the Duty Holder
and Board.
MJS_001 MJS
Has the Duty Holder
(Harbour Board members)
been provided with a clear
brief or training on their
role under the requirements
of the Code?
Satisfactory – six (of the eight) Councillors of
the Harbour Board, plus the Council’s
Executive Director of Development and
Infrastructure Services (as Duty Holder) have
attended training run on 05 September 2022.
Observation – not all Councillors on the
Harbour Board have attended Duty Holder
training, the Marine Safety Plan has an
objective of 100% attendance.
Recommendation – that members of the
Harbour Board who have not attend Duty
Holder training, complete this training as
soon as practical.
MJS_011 MJS

Page 19

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 14
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
1.11-1.12 The Designated
Person
Has the Harbour Authority
appointed an individual as
the Designated Person?  
Satisfactory – the Duty Holder has appointed
ABPmer to provide Designated Person
services, with Monty Smedley as the named
Designated Person.  This contract
commenced on 01 November 2021.  The
Designated Person’s contact details are
hosted on the Council’s website.     
https://www.argyll
-
bute.gov.uk/sites/
default/files/2023-
05/dp_contact_inf
ormation3_abc.pdf 
MJS  
Is the Designated Person’s
role explained in the
MSMS?
Satisfactory – the MSMS, Section 2.0 lists the
duties of the Designated Person.    
MJS_001 MJS
1.13 Chief Executive
[or equivalent]]
Have executive and
operational responsibilities
for marine safety been
clearly assigned?
Satisfactory – the MSMS, Section 1.6.1 lists
the responsibilities of the ‘Head of Roads and
Infrastructure Services’, and Section 1.6.2 lists
the responsibilities of the ‘Marine Operations
Manager’.     
MJS_001 MJS  
How is marine safety
funded within the
organisation?
Satisfactory – funding is identified and agreed
through the Council’s approvals process. 
Officers of the Authority have delegated
spending powers within their spending limits. 
All significant funding decision outside of
spending limits come to the Harbour Board,
officers of the Authority provide technical
input to Harbour Board decisions.   
n/a MJS
1.9, 
1.14 – 1.15
Harbour Master Have executive and
operational responsibilities
for marine safety been
clearly assigned?
Satisfactory – the MSMS, Section 2.5 states
that: “Harbour Masters and their Assistants are
appointed by the Harbour Authority to support
the Marine Operations Manager to develop the
team’s service plans by working in partnership
with colleagues (within and out with the
service) and by taking personal responsibility
for planning how these are delivered effectively
and efficiently”.  Section 1.6.4 lists specific
duties.  Additionally, the Council also appoints
Pier Masters in selected locations, the duties
of which are identified in Section 1.6.5.   
MJS_001 MJS

Page 20

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 15
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.   
1.9, 
1.14 – 1.15
Cont.   
Harbour Master
Does an officer with
responsibilities for marine
safety attend Board
meetings?
Satisfactory – three times a year, a report is
provided by the Executive Director with
responsibility for Roads and Infrastructure
Services; major issues are raised to the
Harbour Board.  Evidence from the Harbour
Board meeting of 31 August 2023 identifies
reports including the Oban Harbour Update,
Port Marine Safety Code Update, Piers and
Harbours marine asset management plan and
the Argyll and Bute Harbour Board Workplan.     
MJS_012
MJS_013 
https://www.argyll
-
bute.gov.uk/sites/
default/files/2023-
05/dp_contact_inf
ormation3_abc.pdf
MJS
1.16 – 1.17 The
Organisation’s
Officers
Does the MSMS provide
details of the organisation’s
Officers and their
responsibilities for marine
safety?
Satisfactory – the MSMS, Section 1.6.3 lists
the responsibilities of the Marine Technical
Officer, and Section 1.6.6 provides detail on
the Council’s Assistant Harbour Masters.     
MJS_001 MJS

Page 21

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 16
A.2 PMSC Section 2 – Key Measures Needed to Secure Marine Safety
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
2.2 Further
guidance
Does the organisation
review any of the following:
 MAIB digest / reports
 MCA health check trends
Satisfactory – the MCA Health Checks trends
was included in the Designated Person’s
briefing note which was tabled at the
02 September 2021 Harbour Board meeting.
Information from the MAIB and the BPA in the
former of safety circulars are distributed by
the Marine Operations Admin Officer.
Evidence sighted.
MJS_014
https://www.arg
yll-
bute.gov.uk/mo
derngov/ieIssue
Details.aspx?IId
=123876&PlanI
d=0&Opt=3#AI
150723
MJS
2.3 – 2.6 Review existing
powers
Does the Harbour Authority
have an understanding of
local legislation?
Satisfactory – the Harbour Authority has a list
of local Acts and Orders in the MSMS, Section
3.2 ‘Local Legislation’ with the ‘Islay Piers
Order 1904’ listed.
Observation – the MSMS, Section 1.2.2 does
not list Bruichladdich Pier as an SHA, nor does
Section 3.2.
Recommendation – the MSMS, Section
1.2.2 and 3.2 should be adjusted to show
Bruichladdich Pier as an SHA.
MJS_001
MJS_008
MJS_009
MJS
Are local Acts and Harbour
Orders referenced in
MSMS?
Satisfactory – the MSMS, Section 3.2, has a list
of local Acts or Orders.
Observation – the bullet point entry for Port
Askaig reads: “Port Askaig, by virtue of the
‘Islay Piers Order 1904”. This should read: Port
Askaig, by virtue of the Acts and Order 1904
to 1975’.
Observation – there is no bullet point for
Bruichladdich Pier, which was established as
an SHA by the Islay Piers Order 1904.
Recommendation – the MSMS, Section 3.2
bullet point for Port Askaig should be
updated to include the 1975 Act.
Recommendation – the MSMS, Section 3.2
has an additional bullet point added for
Bruichladdich Pier SHA.
MJS_001 MJS
Have the Harbour
Authority’s existing powers
been reviewed?
Satisfactory – the harbour acts have been
reviewed by A&BC lawyers.
Recommendations for update have been
presented to the Council and a Harbour
Revision Order (HRO) consolidation process
initiated. Evidence provided.
MJS_015
MJS_016
MJS_017
MJS

Page 22

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 17
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.   
2.3 – 2.6
Cont.   
Review existing
powers
Is the organisation’s
jurisdiction known and
mapped?
Satisfactory – the ‘Port Askaig Pier
Confirmation Order 1975’, Section 28(1) and
(2) states:   
1. The limits within which the Council shall
exercise in relation to the pier undertaking the
powers conferred on them by the Order of
1904 and this Order shall comprise the existing
pier and the works and so much of the sea as is
included within the area marked “Port Askaig
Pier Limits”' on the pier limits map (hereinafter
referred to as “the pier limits”).   
2. In relation to the pier undertaking subsection
(1) of Section 5 (Limits) of the Order of 1904
shall have effect.   
The ‘Pier and Harbour Order Confirmation (No
3) Act, 1904.  Schedule: Islay Piers Order
1904’, in Section 4(3) states that: “The term
‘Port Askaig Pier’ as used in this Order shall not
include the existing passenger slip adjoining
Port Askaig Pier on the south and that slip and
the existing old Cattle Ferry pier at Port Askaig
situated two hundred feet or thereabouts to the
south of Port Askaig Pier are expressly excluded
from the limits of this Order” 
The Islay Piers Order 1904 further states that:
“The limits within which the Undertakers shall
in respect of each of the Piers have authority
and within which the powers of the Pier Master
may be exercised shall comprise each of the
Piers and an area below high-water mark
within a distance of one hundred feet at Port
Askaig and fifty feet at Bruichladdich Pier
measured in any direction seawards from any
part of each of the Piers which limits are in this
Order termed ‘the harbour limits’” 
MJS_008
MJS_009
MJS_025
MJS_026
MJS_027
MJS

Page 23

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 18
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.3 – 2.6
Cont.
Review existing
powers
Cont.
Is the organisation’s
jurisdiction known and
mapped?
A&BC holds a copy of the ‘the pier limits’ plan
and is able to demonstrate the limits and
jurisdiction. In addition, as part of the
planned Consolidated Harbour Act, these
limits will be reviewed, evidence provided.
MJS_008
MJS_009
MJS_025
MJS_026
MJS_027
MJS
2.7 – 2.11 Use of Formal
Risk Assessment
(FRA)
Have risks associated with
marine operations been
assessed and a means of
controlling them deployed?
Satisfactory – the MSMS, Section 5 describes
the assessment methodology. A set of 21 risk
assessments are in place, split into: Port
Askaig (12), Bruichladdich (7) and Port
Charlotte (2). Risk Assessments are managed
via the MARNIS Port Risk Assessment
Software. All assessments were in-date at the
time of audit with all reviews completed in
May 2023. The hazard scenarios cover a
range of foreseeable eventualities based on
current harbour activities. A selection of two
risk assessments per location were sampled.
Observation – staggering review dates for
Marine Risk Assessments is considered best
practice. All the assessments for Islay had the
same revision date.
Recommendation – that a staggered
approach to risk assessment review is
adopted, on a cyclic basis, over the year.
MJS_018
MJS_019
MJS_020
MJS_021
MJS
How does the organisation
ensure those undertaking
marine risk assessment are
competent in the role?
Satisfactory – the Harbour Master has
undertaken a training course for marine risk
completed on 05 April 2016. Certificate
sighted.
MJS_022 MJS
2.7 – 2.11 Use of Formal
Risk Assessment
(FRA)
Are stakeholders included
in marine risk
review/assessments?
Satisfactory – the original risk assessments
conducted in October 2015 included
stakeholders at Port Askaig, ABPmer report
R2536 (ABPmer, 2016) contains a list of these
involved in creating the risk assessments.
Observation – there is no evidence that
Bruichladdich or Port Charlotte risk
assessments have been reviewed with
stakeholders.
Recommendation – the experience and
knowledge of harbour users should be
sought, and their engagement documented
in the risk assessments.
MJS_023 MJS
Does the MSMS prescribe
the review frequency for
risk assessments?
Satisfactory – the MSMS, Section 5.1.3 states
that: “Navigational risk assessments are
maintained for the main ports and harbours as
a minimum. The regular (annual) review of
these risk assessments and any new risk
assessments caused by operational changes
will identify new risks”.
MJS_001 MJS

Page 24

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 19
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.7 – 2.11
Cont.
Use of Formal
Risk Assessment
(FRA)
Is a system of Dynamic Risk
Assessment (DRA) used?
Satisfactory – the MSMS, Section 5.2 provides
information on the DRA requirement. The
Council has a DRA flowchart to aid decision
making.
MJS_001
MJS_024
MJS
2.12-2.14 Implement a
MSMS
Is there an MSMS? Does
this incorporate policies
and procedures? The
MSMS must incorporate a
regular and systematic
review of its performance.
Satisfactory – A&BC’s Marine Safety
Management System (MSMS), ‘Policies and
Statements’, Volume 1, revision 01, issued
November 2023. A revision history table is
included, with a draft noted as being issued in
January 2023. The MSMS was approved by
the Harbour Board in August 2023. The
MSMS, Section 7.1 under the sub-heading
‘periodic review’ identifies that: “Additional to
the above the Marine Safety Management
System will be reviewed and reissued by the
Marine Operations Manager every three years.”
Observation – whilst the MSMS provides for
Council processes, the Standard Operating
Procedures (SOPs) specific to Port Askaig,
Bruichladdich, Port Charlotte require further
development.
Recommendation – a review of port specific
SOPs to consider operations at each
location and ensure that any site-specific
requirements have been captured and
recorded in a systematic way.
MJS_001 MJS
2.15 Key
Performance
Indicators (KPIs)
Does the harbour authority
detail KPIs and/or make a
statement about
performance in the
organisation’s annual
report?
Satisfactory – A&BC’s key performance
indicators are detailed in the ‘Marine Safety
Plan’ as measured objectives. The MSMS,
Section 9.1 provides information on active
and reactive system measurements.
MJS_001
MJS_007
MJS
2.16 MSMS assigning
responsibility
Does the MSMS explicitly
assign responsibility for
appropriate
safety/conservancy
matters?
Satisfactory – the MSMS, Section 1.6 ‘Marine
Operational Management Structure’ details
the assignment of responsibility to key
officers of the Authority. The MSMS,
Section 1.2 identifies the grouping of ports by
region.
MJS_001 MJS

Page 25

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 20
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.16
Cont.
MSMS assigning
responsibility
Cont.
Does the MSMS explicitly
assign responsibility for
appropriate
safety/conservancy
matters?
Observation – whilst the MSMS, Section 1.2
and 1.6 provide a high-level structure, the way
in which responsibilities for marine safety are
met at Port Askaig, Bruichladdich and Port
Charlotte is not clearly laid out. In practice,
the Harbour Master team from Campbeltown
has operational oversight for these locations,
with local Council staff at Port Askaig (whose
primary role is the operation of the Jura Ferry)
provide both marshalling and onsite support.
Lastly, an Islay based Council services
operator provides maintenance services. This
structure is not documented fully in the
MSMS or supporting SOPs.
Recommendation – a review of port specific
SOPs to detail the local level onsite
operational and support services.
MJS_001 MJS
2.17 MSMS
Consultation
Are forum/consultation
meetings held?
Satisfactory – the ‘Navigational Safety,
Pilotage and Towage Policy’ states that Argyll
and Bute Council will: “Consult widely with
port and other relevant stakeholders in respect
of navigational safety issues.” At Port Askaig,
the RNLI, CFL and local fishing users form the
stakeholder community. At Bruichladdich,
Gleaner Limited, operate the Pier during
tanker visits. Stakeholder consultation centres
on any new developments and initiatives.
Observation – there are no routine
stakeholder meetings at Port Askaig, meetings
are held, but around specific needs and
requirements.
Observation – there is no evidence of
stakeholder engagement at Bruichladdich or
Port Charlotte. Whilst Port Charlotte may not
warrant a user meeting (as it was not evident
if there is a regular set of users) there was
evidence of local use at Bruichladdich Pier.
Recommendation – scheduling routine user
meetings and documenting this in minutes.
Recommendation – scheduling routing user
meetings for Bruichladdich Pier (which
could also include Port Charlotte).
MJS_002 MJS

Page 26

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 21
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
2.18 Competence
standards
Are personnel qualified and
trained for their marine
safety role?
Satisfactory – training records are held
centrally, in a MS Excel sheet titled ‘Training
Matrix July 2022’. The training matrix
identifies dates training was completed for
each member of staff. The MSMS, Section 8.1
states: “The Marine Operations Department
shall maintain a training matrix for all staff
and the respective line managers are
responsible for keeping it up-to-date. The
training matrix and training records is held and
maintained centrally”. Induction records
sampled for Rothesay staff.
Observation – it is not clear what the terms
‘Essential’ and ‘Required’ mean on the matrix.
Observation – whilst line managers are
responsible for keeping records up to date,
there is no assurance that a full set of training
records are held centrally.
Recommendation – provide definitions for
the terms used on the matrix for the
avoidance of doubt.
Recommendation – a full internal
audit/check of certification against role is
conducted. This should confirm that all
mandatory training is held, or courses are
booked, with certification held centrally.
MJS_001
MJS_026
MJS_027
MJS
Is there a policy on
revalidation or maintenance
of qualifications in place?
Satisfactory – a Marine Training Policy is in
place, dated v1 August 2023, and available for
download from the A&BC website. The
Marine Operations Admin Officer maintains a
central record of training. Individual staff are
identified with dates of training and
certification held in day/month/year format.
Observation – the training records do not
clearly record, date taken and expiry date for
qualifications
Recommendation – adding date taken and
expiry date (named columns) to training
records.
MJS_003
https://www.arg
yll-
bute.gov.uk/site
s/default/files/2
023-
11/Marine%20T
raining%20Polic
y.pdf
MJS

Page 27

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 22
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
2.19 – 2.22 Incident
reporting and
investigation
Does the MSMS identify
the organisation’s
instruction regarding:
 reporting
 recording of incidents
 investigation
 enforcement (if relevant).
Satisfactory – the MSMS Section 4.5 details
the process to follow should an incident
occur, this addresses investigation and
reporting. There were no recorded marine
incidents for Port Askaig, Bruichladdich or
Port Charlotte. An online reporting method is
available.
Observation – the lack of incident records
may represent a lack of stakeholder
awareness on reporting processes, or the
relatively low level of use at Bruichladdich and
Port Charlotte. Given the volume of traffic
and users at Port Askaig, it may be expected
that marine incidents have occurred.
Anecdotal information from CFL Masters
identify potential near miss incidents with
passing traffic in the approaches to the Port
Askaig berthing area.
Observation – the lack of Port or Pier onsite
staff at Port Askaig, Bruichladdich and Port
Charlotte means there is no-one immediately
on-hand to respond to an incident or monitor
traffic. Whilst Bruichladdich and Port
Charlotte do not have regular vessel traffic,
Port Askaig is a busy port. The A&BC
operated Jura Ferry is staffed by Council
employees; however, their principal focus is
the safe and efficient operation of the ferry.
Recommendation – port community
stakeholders are reminded of the reporting
processes for marine incidents.
Recommendation – the Council should
conduct a review of staff resource for its
Ports and Pier on Islay.
MJS_001
Anecdotal
https://www.arg
yll-
bute.gov.uk/for
m/reporting-an-
accident-or-
inciden
MJS
GtGP 13.2 Incidents
involving Death
or Crime
Are procedures in place for
incidents involving death or
crime?
Satisfactory – the MSMS, Section 4.6 details
actions to be taken in the event of death or
crime.
MJS_001 MJS
GtGP 13.9 Incident
publication
Does the Harbour Authority
disseminate information
from accident
investigations?
Satisfactory – the MSMS, Section 4.8 details
statutory reporting requirements, incident
reports are distributed to the Scottish
Environment Protection Agency (SEPA) and
the MCA.
MJS_001 MJS

Page 28

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 23
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
2.23 Incident
statutory
reporting
Are procedures for
reporting incidents to the
MAIB in place?
Satisfactory – the MSMS, Section 4.8 details
statutory reporting requirements, including
the Marine Guidance Note (MGN) 564
‘Incident reporting and investigation’. There
have been no MAIB reportable incidents
within A&BC’s SHA since MARNIS records
commenced in 2017.
MJS_001 MJS
2.24 Monitoring
performance
and auditing
Has the MSMS been
subject to audit (internal
and/or external)?
Satisfactory – the last external audit of the
MSMS was conducted in September 2022 at
Oban (North Pier). The MSMS, Section 7.2
and 7.3 detail the audit process for A&BC.
MJS_001
MJS_031
MJS
2.25 Enforcement Are local officers aware of
enforcement powers and
responsibilities?
Satisfactory – the MSMS, Section 4.9 provides
the enforcement procedure.
MJS_001 MJS
Is there a policy on
enforcement and
prosecution in place?
Satisfactory – A&BC publish an Enforcement
and Prosecution policy, as version 1, dated
August 2023.
MJS_004 MJS
2.26 Publication of
plans and
reports
Does the organisation
commit itself to developing
policies and procedures to
satisfy the requirements of
the Code?
Satisfactory – this requirement is evidenced
through the publication of Navigational
Safety, Pilotage and Towage Policy’ and its
Marine Safety Plan, published on A&BC’s
website.
https://www.arg
yll-
bute.gov.uk/roa
ds-and-
travel/marine-
services/marine-
safety-
management-
system
MJS
2.27 Plan assessment Is an assessment of the
organisation’s performance
against the plan published?
Satisfactory – the Marine Safety Plan contains
an assessment of the previous plan.
MJS_007 MJS
2.28 Safety plan for
marine
operations
Is a ‘Safety Plan for Marine
Operations’ published
(every three years).
Satisfactory – a signed and issued ‘Marine
Safety Plan’ approved by the Harbour Board
on 04 March 2021 is hosted on the A&BC’s
website. The plan covers the years 2021 to
2023.
MJS_007 MJS
2.29 Consensus Has the Harbour Board
maintained consensus with
harbour users?
See response in this Audit report, Section 2.17
on Consultation.
n/a MJS

Page 29

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 24
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
2.30 – 2.32 Monitoring
compliance
Has the Harbour Authority
confirmed compliance with
the PMSC for the port to
the MCA within the last
three years?
Satisfactory – the Council wrote to the MCA
on 10/03/21 to confirm its current state of
compliance with the Code.  Letter evidenced. 
The DfT list of ports reporting compliance
does not include A&BC ports, harbours or
marine facilities.  This position has been taken
by the DfT, guided by the MCA, as the Council
has confirmed it was not (at that time) fully
compliant with the requirements of the Code. 
At the time of writing the letter the Council
was working towards full compliance in a
number of key areas, including: legislation
review, policy review, MSMS documentation
and creation of SOPs. 
MJS_032 
https://www.go
v.uk/governmen
t/publications/p
ort-marine-
safety-code-
compliant-
ports/port-
marine-safety-
code-
compliant-
ports-list 
MJS
GtGP 2.2.3
(also, Code
Executive
Summary)
Monitoring
compliance
Has the Harbour Authority
confirmed all organisations
with its jurisdiction comply
with the requirements of
the Code?
Satisfactory – there are no other
Organisations within the Port Askaig or
Bruichladdich SHA area owning marine
facilities.  Port Charlotte is a marine facility
and therefore does not have a statutory
jurisdictional area.     
n/a MJS

Page 30

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 25
A.3 PMSC Section 3 – General Duties and Powers
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
3.1 – 3.4 Safe and
Efficient Port
Operations
Does the Duty Holder have
regard to efficiency,
economy and safety of
operation in respect to the
services and facilities
provided?
Satisfactory – the MSMS, Section 9.0 ‘Marine
Safety Plan’ outlines the requirements from
the Code and points to the ‘Marine Safety
Plan’ to deliver this requirement.   
Observation – the Marine Safety Plan does not
specifically mention ‘safe and efficient
port/marine operations’, however, the items in
the plan identify key performance indicators
required to achieve this.   
Recommendation – that the Marine Safety
Plan has wording added at its next revision,
to confirm how the Council delivers the
requirement for delivering ‘safe and
efficient port/marine operations’.  
MJS_001
MJS_007
MJS
3.5 Open port duty Is the port or harbour
subject to Open Port Duty’?
Satisfactory – it is considered highly likely that
both Port Askaig and Bruichladdich Pier
incorporate an Open Port Duty under Section
33 of the ‘Harbours, Docks and Piers Clauses
Act 1847’.  The HDPCA 1847 provisions are
referenced in the ‘Islay Piers Order 1904’.  Port
Charlotte as a marine facility, does not have
an Open Port Duty.   
MJS_008 MJS
3.6 Conservancy
duty
How does the harbour
authority conserve the
harbour?:
 Survey as necessary
 Place navigation marks
 Keep ‘vigilant watch’ for
any seabed changes
 Keep hydrographic
records
 Ensure hydrographic
information is published
 Update UKHO.  
Satisfactory – the MSMS, Section 10.0
providing information on the Council’s
approach to conservancy.  This includes
conservancy duty, hydrographic survey policy,
dredging, Aids to Navigation (AtoN), wreck
removal, dangerous vessels and licensing
marine works.  The MSMS, Section 10.1 details
hydrography, with the last bathymetric survey
was conducted for Port Askaig was conducted
on 12 April 2021, with Bruichladdich Pier
surveyed on the 13 April 2021.  Port Charlotte
has no harbour survey based on its low-level
usage and lack of port user community that
would benefit from a survey.  Information was
passed by the survey contractor to UKHO,
evidence seen.   
MJS_001
MJS_028
MJS_029
MJS
3.7 Updates
provided to
UKHO
Does the organisation have
an Agreement with UKHO,
and/or do they provide
survey information to
UKHO?
Satisfactory – a bilateral agreement between
A&BC and the UKHO is in place, dated
17 March 2017.   
MJS_034 MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 26
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
GtGP 1.9.11,
and 7.8
Licensing,
Regulating
Harbour Works
and Dredging?
Does the harbour authority
have the power to licence
works?
Satisfactory – there is no evidence that A&BC
as Harbour Authority at Port Askaig or
Bruichladdich Pier having any powers to
licence third party marine works under its
local Acts and Orders. The 1904 provides
powers to make improvements, maintain and
regulate the Piers. Any works at Port
Charlotte would require a Marine Licence.
Mooring licences are required for individual
and commercial moorings, via the Crown
Estate, with navigation consent required from
A&BC as the SHA.
MJS_008
MJS_009
MJS_052
MJS_053
MJS_054
MJS
3.8 Environmental
duty
Does the Organisation
understand its obligations:
 Nature conservation
Section 48A of Harbours
Act 1964
 Obligations for SPA, SACs
under Habitat Regs.
 the Nature Conservation
(Scotland) Act 2004
Satisfactory – the MSMS, Section 3.1 lists
National legislation, including several Acts
relating to Environmental Duties. These
requirements are delivered through the
Harbour’s services. A&BC also issue a ‘Marine
Conservancy and Hydrographic Policy’,
Version1, issued August 2023 which has
intrinsic links to environmental duties.
Information regarding local habitat is
contained in the Oil Pollution Response plan.
MJS_001
MJS_005
MJS_035
MJS
3.9 Civil
Contingency
Duty
Does the MSMS include
reference to the Harbour
Authority’s obligations as a
Category 2 responder?
Satisfactory – the MSMS, Section 4.4.6
includes reference to Civil Contingency duties
within supporting port, harbour and pier
Annexes.
MJS_001 MJS
GtGP 6.2.4,
6.5
Emergency
Planning /
Pollution
control
Does the MSMS include
emergency planning and oil
pollution response?
Satisfactory – an Oil Pollution Response Plan
is in place, which was approved by the MCA
on 04 December 2018 and is valid until the
27 November 2023. The annual OPRC return
form was evidenced. A&BC maintain a Critical
Activity Recover Plan (CARP) which
incorporates the Council’s Civil Contingency
duties.
Observation – there is no specific emergency
plan for Port Askaig or Bruichladdich Pier.
Recommendation – the development of an
SOP or specific plan for Port Askaig and
Bruichladdich Pier.
MJS_035
MJS_036
MJS

Page 32

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 27
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
Cont.   
GtGP 6.2.4,
6.5
Cont.   
Emergency
Planning /
Pollution
control
Does the port/harbour carry
out emergency plan
exercises?
Satisfactory – a training exercise for oil
pollution was carried out for A&BC in
Campbeltown on 23 November 2021, as
operation ‘Smerby’.  The Campbeltown team
are operationally responsible for the delivery
of marine services at Port Askaig,
Bruichladdich Pier and Port Charlotte.    
MJS_038 MJS
3.10 – 3.11 Harbour
Authority
Powers review
Has the Harbour Authority
reviewed its powers?
See the audit report response in Section 2.3 –
2.6.   
n/a MJS
3.12 – 3.14 Revising Duties
and Powers
Evidence of Harbour
Revision Orders, or Harbour
Closure.  
Satisfactory – the last HRO was made in 1975.   MJS_009 MJS

Page 33

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 28
A.4 PMSC Section 4 – Specific Duties and Powers
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
4.2 Appointment of
Harbour Master
Is there a Harbour Master
appointment for the port?
Satisfactory – a Harbour Master is appointed
for Port Askaig and Bruichladdich Pier,
evidence of appointment letter provided. The
Harbour Master based at Campbeltown (with
an appointment date of 09 September 2007)
references an appointment for Port Askaig
and Bruichladdich Pier under the ‘Islay Piers
Order 1904’.
MJS_008
MJS_042
MJS
4.3 – 4.5 Byelaws Does the organisation have
powers to make Byelaws,
are these published?
Satisfactory – under the ‘Islay Piers Order
1904’, Section 28(1), the undertakers may
make Byelaws under Section 83 of the HDPCA
1847. This relates to Port Askaig and
Bruichladdich Pier only. Port Charlotte is a
marine facility with no power under harbour
legislation to make Byelaws.
MJS_008 MJS
Date of last byelaw review? Not Applicable – no known Byelaws are
issued.
n/a MJS
4.6 – 4.7 Special
Directions
Are the Harbour Master’s
powers of Direction shown
in the MSMS, how is
delegation identified?
Satisfactory – the MSMS, Section 5.1.1, details
the use of Special Direction stating: “Special
directions – may be given by the harbour
master, deputies or their assistants: these
directions are time and vessel specific and are
apt for operational purposes of short duration
and for emergencies”.
Observation – there is no SOP detailing how
Special Directions are given or recorded by
the Harbour Master, Deputy or Assistants. It
should also be noted that under the Islay Piers
Order 1904, powers cannot be delegated and
must be used by appointed Harbour Masters,
Pier Masters or Dock Masters, or their
Deputies.
Recommendation – an SOP for the use of
Special Directions is drafted and agreed.
This should detail the giving of the
direction and its recording. This relates to
Port Askaig and Bruichladdich Pier only.
Port Charlotte is a marine facility with no
power under harbour legislation to issue
directions.
MJS_001 MJS
4.8 General
Directions
Are the powers of General
Directions available to the
Harbour?
Not applicable – powers of General Direction
are not available.
n/a MJS
4.9 Harbour
Directions
Are Harbour Directions
used and published?
Not applicable – Harbour Directions have not
been applied for.
n/a MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 29
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
4.10
GtGP 6.4
Dangerous
Vessels
Does the MSMS (or other
plan) make provision for
giving directions to
dangerous vessels?
Satisfactory – the Harbour Masters have
powers under the Dangerous Vessels Act
1985. This is listed in the MSMS, Section 3.1
under ‘National Legislation’.
Observation – as there is no appointed
Harbour Master or Pier Master for Port Askaig
and Bruichladdich Pier, therefore there is no
appointee to make use of this power.
Recommendation – the creation of a SOP
based around actions a Pier or Harbour
Master should take in respect of a
dangerous vessel. This relates to Port
Askaig and Bruichladdich Pier only. Port
Charlotte is a marine facility with no power
under harbour legislation to issue
directions.
MJS_001 MJS
Is the role of the Secretary
of States' Representative
for Maritime Salvage and
Intervention (SOSREP)
acknowledged?
Satisfactory – the MSMS, Section 4.4.3 details
the role of the SOSREP.
MJS_001 MJS
GtGP 6.2 Dangerous
Substances
Are there clear
requirements for
declaration of dangerous
goods/substances?
Satisfactory – the MSMS, Section 4.4.4 details
the entry and control of dangerous goods and
substances in the harbour. The Council’s
website contains reporting forms for
‘Dangerous Good Notification Procedures’. At
Port Askaig, CFL (as ferry operator) manages
the dangerous goods notification process at
the ferry terminal with A&BC as the harbour
operator provided with summary information.
MJS_001
MJS_043
MJS_044
https://www.arg
yll-
bute.gov.uk/roa
ds-and-
travel/marine-
services/marine-
safety-
management-
system
MJS
GtGP 8.4 Vessel Traffic
Management
Is vessel traffic managed
within the port area, how is
this achieved?
Satisfactory – vessel traffic is monitored and
managed through:
 Visual observation and communications by
Very High Frequency (VHF) between port
traffic.
 Scheduled visits by the Campbeltown team
when tanker traffic visits Bruichladdich Pier.
MJS_043
MJS_044
Observational
MJS
Is vessel traffic monitoring
information passed to the
MCA by the quickest
means?
Satisfactory – the Council has a CERS login. Observational MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 30
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
Cont.
GtGP 8.4
Cont.
Vessel Traffic
Management
Has the need for VTS/LPS
been reviewed recently?
Satisfactory – the current method of vessel
traffic management has been arranged to
meet the demands of harbour use at
Bruichladdich Pier and Port Charlotte with
scheduled visits made to view tanker traffic
arrivals at Bruichladdich.
Observation – whilst Port Askaig has Council
staff operating the Jura Ferry, there is no
dedicated onsite staff to manage the harbour.
The there is no LPS provision outside of port
user information available on A&BC’s website.
Observation – there is no arrival or departure
contact procedure for the CFL ferry with the
Harbour Authority. If the Jura Ferry is using
the linkspan berth (due to the tide being too
low for the Jura Ferry to use the slipway)
vessel traffic management is arranged
between vessel Masters.
Recommendation – the provision of LPS at
Port Askaig should be reviewed by A&BC
to consider if improved vessel traffic
management is needed.
Recommendation – the requirement for
LPS at Port Askaig is reviewed to ensure
that berth allocation processes are in place.
Observational MJS
GtGP 13.2.2 Drink and drugs Do staff know what to do if
they suspect that a mariner
(master, pilot, seaman) has
committed an offence
whilst on duty?
Satisfactory – the MSMS, Section 3.1
references the Railways and Transportation
Safety Act (RATSA) 2003. The Council has a
Drink and Drugs Policy for its own staff.
Observation – there is no specific instruction
on the actions to take if a professional
mariner is suspected of a drink or drugs
offence when on duty.
Recommendation – the creation of an SOP
or procedure to inform the Authority’s
officers of their expected action for a drink
or drugs offence under the RATSA 2003.
MJS_001 MJS
4.11
GtGP 9.0
Pilotage Is the port a CHA? Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
Has the requirement for
pilotage been reviewed?
Satisfactory – the Organisation is not a
Competent Harbour Authority; marine risk
assessments do not identify the need for
pilotage as a risk control.
MJS_019
MJS_020
MJS_021
MJS
4.12
GtGP 9.4
Pilotage
Directions
Are Pilotage Directions
issued?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
4.12
GtGP 9.4
Pilotage
Directions
Were stakeholders
consulted during the
drafting phase of the most
recent Pilotage Direction?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 31
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
4.13
GtGP 9.4
Authorisation of
pilots
Is the process for
appointing Pilots
referenced in the MSMS?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
4.14
GtGP 9.4.31
Pilot Training Does the CHA implement
the International Maritime
Organisation (IMO)
resolution A960?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
GtGP 9.5.43 Pilotage Does the authority operate
an effective Pilot Fatigue
Management System?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
4.15 – 4.16
GtGP 9.5
Pilot Exemption
Certificates
Is a clear process for the
issuing of PECs published?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
Are the requirements
equivalent to those for an
authorised pilot?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
GtGP 8.7.15 –
8.8.10
Port Passage
Plan
Is there a published
passage plan?
Satisfactory – information is included in the
Admiralty List of Radio Signals (ALRS),
Volume 6, the Reeds Nautical Almanac and
Marina Guide and the Port of Scotland
publication. Port entry information is also
available on the Bute Berthing Company
website.
Observation – information in ALRS Volume 6
for Port Askaig provides a contact phone
number and VHF channel only.
Recommendation – reviewing ALRS
Volume 6 for Port Askaig and advise UKHO
of any updates.
MJS_048 MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 32
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
GtGP 8.10 Recreational
navigation
Are recreational users of
the harbour considered?
Satisfactory – information is published on
A&BC’s website for Port Askaig and
Bruichladdich Pier. Ferry terminal information
is provided by CFL for its service operating
from Port Askaig.
Observation – the ‘Our Piers and Harbours’
website information, whilst a valuable
resource, does not contain recreational
information (or an indication/heading as to
whether there are berths for recreational
vessels).
Recommendation – a review of the ‘Our
Piers and Harbours’ website information to
specifically include recreational information.
https://www.arg
yll-
bute.gov.uk/roa
ds-and-
travel/marine-
services/port-
askaig-pier
https://www.arg
yll-
bute.gov.uk/roa
ds-and-
travel/marine-
services/bruichl
addich-pier
https://www.cal
mac.co.uk/articl
e/2150/Port-
Askaig
MJS
4.17 – 4.20 Collecting Dues Are dues clearly defined? Satisfactory – charges (including dues) are laid
out on the Council’s website. The process for
setting charges uses a benchmarking exercise
with other local ports. Charges are increased
at the rate of inflation.
https://www.arg
yll-
bute.gov.uk/fee
s/22/piers
MJS
4.21-4.23 Aids to
Navigation
Are defects and
rectification of defects
recorded?
Satisfactory – as the Local Lighthouse
Authority (LLA) the following Aids to
Navigation are maintained.
Port Askaig:
 2 fixed red lights (vertical) on the West Arm.
 1x Sectored Light.
Bruichladdich:
 2 fixed red lights (vertical) on the West Arm.
Port Charlotte is a marine facility and has no
LLA function, nor does it have any navigation
lights.
https://www.arg
yll-
bute.gov.uk/roa
ds-and-
travel/marine-
services/port-
askaig-pier
https://www.arg
yll-
bute.gov.uk/roa
ds-and-
travel/marine-
services/bruichl
addich-pier
MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 33
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
4.24 GLA returns Are returns made to the
GLA?
Satisfactory – the LATON three-year return for
A&BC identifies the availability return values
for the period April 2020 to April 2023 as:
 Cat 2 = 99.56% (target is 99.0%)
 Cat 3 = 100% (target is 97.0%)
Provision and maintenance of Aids to
Navigation is recognised as an area of best
practice.
MJS_040 MJS
4.25-4.32 Wrecks,
Abandoned or
unserviceable
vessels
Does the MSMS refer to
powers for dealing with
wrecks?
Satisfactory – the MSMS, Section 10.4
addresses wrecks within the Conservancy
section and with respect to marking of wrecks.
There are no known wrecks in Port Askaig,
Bruichladdich or Port Charlotte.
MJS_001
Anecdotal
MJS
GtGP
9.4.17 -9.4.21
Pilot Launches Do pilot boats meet
statutory requirements and
appropriate Codes?
Not applicable – the Organisation is not a
Competent Harbour Authority and therefore
has no requirement to operate a pilot boat.
n/a MJS
GtGP - 10 Towage
Operations
Does the organisation
produce towage
guidelines?
Satisfactory – towage is commented on in the
‘Navigational Safety, Pilotage & Towage
Policy’.
Observation – there is no procedure for
dealing with towage (either routine or non-
routine) at other A&BC ports, harbours or
piers. This is important for any marine works
that may require towage operations.
Recommendation – drafting of appropriate
towage guidelines for all A&BC ports,
harbours and piers.
MJS_002
Observational
MJS
Is there a process for
approving towage
providers?
Not applicable – there are no towage
providers at Port Askaig, Bruichladdich or Port
Charlotte.
n/a MJS
Are non-routine tows pre-
approved / managed by
the organisation?
Satisfactory – towage is commented on in the
‘Navigational Safety, Pilotage & Towage
Policy’.
MJS_001 MJS
GtGP 1.9.11 Licensing
Harbour Tugs?
Does the harbour authority
have the power to licence
tugs?
Not applicable – there are no known powers
to licence tugs.
n/a MJS
GtGP - 10.4 Diving
Operations
(commercial)
Is there a process for
managing commercial
diving?
Satisfactory – a ‘Permission to Dive Permit’ is
used in A&BC’s ports and harbours.
Observation – there is no diving SOP for Port
Askaig, Bruichladdich or Port Charlotte.
Recommendation – the creation of a diving
SOP or procedure that applies to all AB&C
ports or harbours, or is specific to Port
Askaig, Bruichladdich and Port Charlotte.
MJS_047 MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 34
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
GtGP - 10.4 Diving
Operations
(recreational)
Is there a process for
managing recreational
diving?
Not applicable – there is no history of
recreational diving.
n/a MJS
GtGP - 6.7.3 Hot Work
Permits
Is there a process for
managing Hot Works?
Satisfactory – a ‘Marine Department Hot Work
Permit’ is used in A&BC’s ports and harbours.
Observation – there is no hot work SOP for
Port Askaig, Bruichladdich or Port Charlotte.
Recommendation – the creation of a hot
work SOP or procedure that applies to all
AB&C ports or harbours, or is specific to
Port Askaig, Bruichladdich and Port
Charlotte.
MJS_045
MJS_046
MJS
GtGP – 6.7.3 Bunkering Is there a process for
managing Bunkering?
Satisfactory – CalMac ferries do not bunker at
Port Askaig. The Jura Ferry and fishing vessels
may bunker by road tanker or from fuel cans.
Bunkering does not occur at Bruichladdich or
Port Charlotte.
Observation – there is no evidence of third
parties bunker check lists in use at Port
Askaig.
Recommendation – the Harbour Authority
should retain bunkering check lists.
n/a MJS
GtGP – 11.3,
11.4
Regulation of
Port Craft, Pilot
Launches and
Workboats
Does the Authority have a
procedure for regulating
port craft?
Satisfactory – for vessels booked into Port
Askaig by the Campbeltown team, a check of
workboats is made.
Observation – the Council does not have a
formalised process for checking commercially
operated Coded vessels.
Recommendation – the Harbour Authority
considers the requirements of the GtGP
(Section 11.3, 11.4) with respect to
regulating third party commercial
workboats and launches within its area of
jurisdiction and creates a registration
scheme for workboats using the Authority’s
area.
MJS_001 MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 35
B Quayside Check
Visual observation of Port Askaig, Bruichladdich Pier and Port Charlotte quayside during the site visit on the 11 May 2023.
B.1 Quayside Check: Port Askaig
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
PMSC 3.0
GtGP 8.11.19
ACOP 207-208
SIP 014
Access Is the quayside and its access
locations clear of debris and
obstructions?
Satisfactory – Port Askaig is comprised of a north
basin used mainly by fishing vessels, the main
(ferry) berth and the Jura Ferry Slipway, with a
southern Pier forming the southern basin. The
lifeboat berths at a dedicated facility to the south
of the port. Generally, the port infrastructure is of
good quality with quayside areas appropriate to
their use.
Observation – at the time of the quayside checks,
there were numerous mooring lines causing
obstruction along the southern Pier. In a number
of locations, vessel waste and other general rubbish
was left on the quayside. See Image B1 and B2.
Recommendation – housekeeping should be
improved with vessel Masters required to remove
unnecessary lines from quayside areas and waste
from vessels removed or disposed of properly.
MJS
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – walkways were generally clear of
obstructions with footpaths and vehicle marshalling
areas for both the CFL ferry and Jura ferry.
Observation – in several locations, due to the
amount of available space and port road layout,
both pedestrians and vehicles use the same area.
This was especially noted when the CFL Ferry
passenger embarked and disembarked, with
vehicles dropping off or collecting foot passengers
passing close to, and around queuing passengers.
See Image B3.
Recommendation – the Health and Safety
Executive (HSE) publication L148 ‘Safety in Docks:
Approved Code of Practice and Guidance’
(ACOP) (HSE, 2014) Section 58 to 72 ‘Safe site –
design and activity’ provides the requirements
for designing and operating pedestrian and
vehicle assess. The layout of Port Askaig should
be considered in light of the ACOP with the aim
of removing risks to pedestrians from moving
vehicles associated with ferry traffic.
MJS
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the quayside surfaces of the Piers and
berthing areas were appropriate to their intended
use and operation.
MJS

Page 41

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 36
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
ACOP 211-223
SIP 014
Rescue and
Lifesaving
equipment (LSE) at
the water’s edge
Is there appropriate means of
egress from the water?
Satisfactory – the Piers and quayside areas had
good quality and appropriately spaced water
egress ladders, with grab rails fitted at deck level.
Observation – some of the water egress ladders
were obstructed by mooring lines, this was noted
on the south Pier. See Image B4.
Recommendation – housekeeping should be
improved with vessel Masters required to remove
mooring lines from water egress ladders.
MJS
Is there appropriate LSE at
quay edge?
Satisfactory – Life saving equipment (life rings)
were installed along all Piers and quayside.
Observation – not all life rings were fixed. See
Image B5.
Recommendation – life rings should be checked
on a routine basis with any damaged items
repaired or replaced.
MJS
SIP 005 Bollards and
securing
equipment
Does the general condition of
bollards appear to be in good
order?
Satisfactory – the bollards along the Piers are
(visually) in good condition.
Observation – the quay bollards were not
numbered, or Safe Working Loads (SWL) identified.
See Image B6.
Recommendation – bollards and bits are
inspected, numbered and SWL added.
MJS
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – fendering on the Pier is vertical
rubber sections on timber, the condition of which is
considered to be good from visual observation. In
other areas, the fendering is wood vertical sections
with some tyres used for fishing vessels and
workboat berths.
MJS
Is the condition of the
fendering in good order?
Satisfactory – fitted fendering was observed to be
in serviceable condition.
MJS
Are chaffing plates used? Satisfactory – wooden beams/toe rails are used
along the Pier edge as protection from lines
chaffing on the quay and also double as barriers to
prevent items being knocked off the Piers onto
vessels moored below.
Observation – the wooden beams/toe rails along
the southern Pier has some sections that had
sustained damage. See Image B7. It was also
noted that equipment may have been installed at
the Pier that was causing damage to wooden
sections. See Image B8. The attachment of this
item had caused the wooden beam to loosen.
Recommendation – that inspection and
maintenance of quayside beams/rails is
conducted. Any equipment fitted to the Pier
should be fitted in such a way as to prevent
damage to infrastructure.
MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 37
Reference Subject Evidence Required 
For Compliance Observation Recommendations Auditor
ACOP 232-235
SIP 005
SIP 014
Lighting Is lighting appropriate and
appear to be in compliance
with ACOP ‘safety in docs’ and
the PFSP?  
Satisfactory – there is ample lighting on the Piers,
ferry berth and the slipway.  The marshalling area
and footpaths has street lighting.   
MJS
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – there is adequate delineated between
quayside operations along the Piers.   
Observation – there is mixed pedestrian, public and
fishing use away from the quayside.  This is
unavoidable given the space and roadway layout. 
See previous response to ‘Access’. 
See previous recommendation on Access.  
MJS
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – the harbour has adequate signage.     MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 38 
Image B1. Port Askaig, mooring lines South Pier Image B2. Port Askaig, vessel waste and rubbish on the quayside

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 39  
Image B3. Port Askaig, mixed passenger and vehicle use Image B4. Port Askaig, obstructed water egress ladder

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 40  
Image B5. Port Askaig, unattached life ring Image B6. Port Askaig, bollard

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 41  
Image B7. Port Askaig, broken capping rail Image B8. Port Askaig, equipment inappropriately fixed

Page 47

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 42
B.2 Quayside Check: Bruichladdich Pier
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
PMSC 3.0
GtGP 8.11.19
ACOP 207-208
SIP 014
Access Is the quayside and its access
locations clear of debris and
obstructions?
Satisfactory – the quayside is comprised of an
original stone pier used by the local community
and inshore fishing vessels, leading to a new jetty
with eight mooring dolphins connected by
walkways. The new pier and dolphins are clear of
debris and obstructions with access controlled
through security gates.
Observation – the common user stone Pier had a
number of mooring lines obstructing the stone
steps used to access and egress the launch point
and water, the quayside also had an amount of
plant growth which could present a slip or trip
hazard. See Image B9.
Recommendation – housekeeping on the stone
pier is improved with redundant mooring lines
removed and plant growth removed from the
pier surface.
MJS
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – walkways were clearly marked for
pedestrians to access the pier.
MJS
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the stone pier and new pier with
mooring dolphins is appropriate to its use and
operation.
MJS
ACOP 211-223
SIP 014
Rescue and
Lifesaving
equipment (LSE) at
the water’s edge
Is there appropriate means of
egress from the water?
Satisfactory – the pier has appropriately spaced
LSE. At the stone pier, some of the water egress
points were built into the dockside infrastructure.
Observation – one of the water egress ladders at
the original stone Pier was severely corroded and
not in a usable condition. See Image B10.
Recommendation – the water egress ladder is
replaced and/or removed.
MJS
Is there appropriate LSE at
quay edge?
Satisfactory – life saving equipment (life rings) were
installed along the Pier.
Observation – not all life rings were in a serviceable
condition and housed correctly. See Image B11.
Observation – some of the oil pollution response
equipment storage bins had been used for waste.
See Image B12.
Recommendation – life rings should be checked
on a routine basis with any damaged items
repaired or replaced.
Recommendation – oil pollution response
equipment storage should be checked, and any
unnecessary items removed.
MJS

Page 48

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 43
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
SIP 005 Bollards and
securing
equipment
Does the general condition of
bollards appear to be in good
order?
Satisfactory – the bollards and mooring hooks
along the new Pier were (visually) in a serviceable
condition.
Observation – the bollards were not numbered, or
Safe Working Loads (SWL) identified. See Image
B13.
Recommendation – bollards and bits are
inspected, numbered and the SWL added.
MJS
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – fendering on the new Pier is sprung
fender units, secured with chains. This appeared
(visually) to be in a serviceable condition.
Fendering on the original Pier was in the form of
tyres or timber sections.
MJS
Is the condition of the
fendering in good order?
Satisfactory – fitted fendering was observed to be
in serviceable condition.
MJS
Are chaffing plates used? Satisfactory – metal tubular rails are used along the
outer edge of the new Pier to allow mooring lines
to run over them without fouling or chaffing.
Chaffing plates or wooden sections are not used on
the original Pier.
MJS
ACOP 232-235
SIP 005
SIP 014
Lighting Is lighting appropriate and
appear to be in compliance
with ACOP ‘safety in docs’ and
the PFSP?
Satisfactory – there is ample lighting around all
berths at the new Pier and original Pier. (Note,
quayside checks carried out in daylight only).
MJS
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – there is adequate delineated between
the commercially operated new Pier and the public
use original Pier. Security gates are used to restrict
access.
MJS
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – the harbour has signage.
Observation – a number of Pier signs had
weathered and deteriorated to the point of being
illegible. See Image B14.
Recommendation – a full check of signage
should be conducted with degraded or illegible
signed replaced.
MJS

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 44  
Image B9. Bruichladdich, stone pier plant growth and moorings Image B10. Bruichladdich, severely corroded water egress ladder

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 45 
Image B11. Bruichladdich, life ring incorrectly secured Image B12. Bruichladdich, oil pollution equipment storage

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 46  
Image B13. Bruichladdich, bollard Image B14. Bruichladdich, illegible signage

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Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023 Argyll and Bute Council
ABPmer, January 2024, R.4231 | 47
B.3 Quayside Check: Port Charlotte
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
PMSC 3.0
GtGP 8.11.19
ACOP 207-208
SIP 014
Access Is the quayside and its access
locations clear of debris and
obstructions?
Satisfactory – the Pier was clear of debris and
obstructions.
MJS
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – there was one area comprised of a
stone and concrete Pier, with open access to the
public and for vessel berthing.
MJS
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the Pier was appropriate to its use. MJS
ACOP 211-223
SIP 014
Rescue and
Lifesaving
equipment (LSE) at
the water’s edge
Is there appropriate means of
egress from the water?
Satisfactory – the Pier had a water egress ladder at
the end which was in good condition, and a set of
stone access steps half way along the Pier which
had railings to reduce the risk of an accidental fall.
MJS
Is there appropriate LSE at
quay edge?
Satisfactory – the Pier had one life ring.
Observation – the life ring housing was broken and
not secured to a support. See Image B15
Recommendation – life rings should be checked
on a routine basis with any damaged items
repaired or replaced.
MJS
SIP 005 Bollards and
securing
equipment
Does the general condition of
bollards appear to be in good
order?
Satisfactory – mooring rings are installed on the
Pier.
Observation – some of the mooring rings are
visually deteriorated and may not provide sufficient
restraint capacity. See Image B16.
Recommendation – mooring rings should be
inspected and replaced if significantly
deteriorated.
MJS
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – fendering on the Pier is vertical
rubber sections on timber, the condition of which is
considered to be good from visual observation. In
other areas, the fendering is wood vertical sections
with some tyres used for fishing vessels and
workboat berths.
MJS
Is the condition of the
fendering in good order?
Satisfactory – fitted fendering was observed to be
in serviceable condition.
MJS
Are chaffing plates used? Not applicable – chaffing plates and/or wood
sections are not used on the Pier.
MJS
ACOP 232-235
SIP 005
SIP 014
Lighting Is lighting appropriate and
appear to be in compliance
with ACOP ‘safety in docs’ and
the PFSP?
Not applicable – there is no lighting at the Pier, the
facility is not used for loading or unloading vessels
at night.
MJS

Page 53

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 48
Reference Subject Evidence Required 
For Compliance Observation Recommendations Auditor
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – the facility is one Pier, extending from
the shore.  The layout is comprised of one Pier
section.   
MJS
ACOP 82 Signage Is appropriate signs and
markings provided
Observation – there is no signage at the Pier.   Recommendation – a sign with contact details for
A&BC as the marine asset owner would be
advisable, this will allow users to make contact if
the facility is damaged or assistance is required.  
MJS

Page 54

Port Marine Safety Code - Audit: Isle of Islay (Port Askaig, Bruichladdich, Port Charlotte) 2023    Argyll and Bute Council
ABPmer, January 2024, R.4231  | 49  
Image B15. Port Charlotte, life ring incorrectly secured Image B16. Port Charlotte, degraded mooring ring

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