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Appendix D Port Marine Safety Code – Isles of Mull and Iona

Argyll and Bute Council · 2 March 2023
Back to Argyll and Bute Harbour Board — 2 March 2023 and its agenda

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Argyll and Bute Council 
Port Marine Safety Code
Audit: Isles of Mull and Iona 
(Craignure, Bunessan, Fionnphort, Iona) 2022 
November 2022

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Port Marine Safety Code
Audit: Isles of Mull and Iona 
(Craignure, Bunessan, Fionnphort, Iona) 2022 
November 2022 
Fionnphort
Iona
Bunessan 
Craignure

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022  Argyll and Bute Council
ABPmer, November 2022, R.4024  | i
Document Information
Document History and Authorisation
Title Port Marine Safety Code 
Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022
Commissioned by Argyll and Bute Council
Issue date November 2022
Document ref R.4024
Project no R/4952/01
Date Version Revision Details
03 November 2022 1 Issued for client review
28 November 2022 2 Issued for client use   
Authorised 
(Auditor)
Approved 
(Quality Manager)
Authorised 
(Designated Person)
Harry Aitchison Richard Vaughan Monty Smedley   
Suggested Citation
ABPmer, (2022).  Port Marine Safety Code, Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022, ABPmer
Report No. R.4024.  A report produced by ABPmer for Argyll and Bute Council, November 2022. 
Author
M.J. Smedley 
Notice
ABP Marine Environmental Research Ltd ("ABPmer") has prepared this document in accordance with the client’s instructions, for
the client’s sole purpose and use.  No third party may rely upon this document without the prior and express written agreement
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Sections of this document may rely on information supplied by or drawn from third party sources.  Unless otherwise expressly
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for any loss or damage suffered by any person, including the client, as a result of any error or inaccuracy in any third party
information or for any conclusions drawn by ABPmer which are based on such information. 
All content in this document should be considered provisional and should not be relied upon until a final version marked
‘issued for client use’ is issued. 
All images on front cover copyright ABPmer. 
ABPmer
Quayside Suite, Medina Chambers, Town Quay, Southampton, Hampshire   SO14 2AQ
T: +44 (0) 2380 711844   W: http://www.abpmer.co.uk/

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Contents
1 The Port Marine Safety Code ................................................................................................ 1
1.1 About the Harbour Authority ................................................................................................................. 2
2 Purpose and Method ............................................................................................................... 4
2.1 Audit scope .................................................................................................................................................... 4
2.2 Audit definitions and outcomes ............................................................................................................ 4
2.3 Audit date and criteria .............................................................................................................................. 5
2.4 Auditor............................................................................................................................................................. 5
2.5 Auditees .......................................................................................................................................................... 5
3 Audit Summary ........................................................................................................................... 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 ............................................................................. 24
A.4 PMSC Section 4 – Specific Duties and Powers ............................................................................. 27
B Quayside Checks ..................................................................................................................... 33
B.1 Craignure ..................................................................................................................................................... 33
B.2 Bunessan ...................................................................................................................................................... 36
B.3 Fionnphort .................................................................................................................................................. 41
B.4 Iona ................................................................................................................................................................ 44

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Figure
Figure 1. Craignure Harbour Limits......................................................................................................................... 2 
Images  
Image B1. Craignure, ladder does not extend below waterline .................................................................. 35
Image B2. Craignure, ladder with missing handrails or grab loops .......................................................... 35
Image B3. Bunessan, trip hazards and obstruction to steps. ....................................................................... 38
Image B4. Bunessan, obsolete lifting equipment (trip hazard) ................................................................... 38
Image B5. Bunessan, tires and ropes affixed to ladders ................................................................................ 39
Image B6. Bunessan, life ring .................................................................................................................................... 39
Image B7. Bunessan, wooden fendering in disrepair ...................................................................................... 40
Image B8. Fionnphort, access to pier blocked by fishing pots .................................................................... 43
Image B9. Fionnphort, life ring missing cover ................................................................................................... 43
Image B10. Iona, small vessel slipway step and poor quality surface ......................................................... 46
Image B11. Iona, access ladder is blocked by rope ............................................................................................ 46

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022  Argyll and Bute Council
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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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1.1 About the Harbour Authority
The Isle of Mull is the second-largest island of the Inner Hebrides (after Skye) and lies off the west coast
of Scotland in the council area of Argyll and Bute.  Mull has a number of harbours, ports, piers and
slipways.  The Council is responsible for three, namely: Craignure, Bunessan and Fionnphort which are
all operated by the Harbour Master team from Oban.   
Craignure lies close to the Isle of Mull's easternmost point and is the main terminus for the ferries from
Oban Bay.  A&BC is the Statutory Harbour Authority (SHA) by virtue of the Argyll County Council
(Arinagour and Craignure Piers, etc) Order 1961, the limits of which are set out in Part 4, Section 24(2)
of the Order as shown in Figure 1.  The Council is the facility owner for its marine assets and the SHA
for the harbour.  The original pier was built in 1894 and is located in the south east end of the bay
adjacent to the village hall.  The present pier is located on the west side of the bay and was built in 1964,
it has two berths with the northern berth used by the ferry and the southern berth for other craft.  The
harbour has scheduled ferry services, with occasional calls from aquaculture and small cruise vessels. 
There are a number of local resident community moorings around the original pier at the south east
end of Craignure Bay.   
Figure 1. Craignure Harbour Limits

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Bunessan pier is located on the Ross of Mull in the south west of the Isle of Mull, A&BC is the marine
facility owner for the pier structure, but the area does not form part of an SHA.  The pier was constructed
from the local granite in circa 1846, prior to the building of the pier boats anchored in the bay and
shuttled their cargo ashore in small boats.  Current use of the pier is local fishing vessels all the year
round and visiting yachts during the summer months.   
Fionnphort is the Mull terminal for the Iona Ferry.  The marine berthing facilities at Fionnphort are owned
by A&BC but the area does not form part of an SHA.  The port has a slipway providing passenger and
vehicle access to the ferry, plus a pier which is used by local fishing vessels, recreational and privately-
owned craft.  Baile Mòr is the Isle of Iona terminal for the Iona Ferry.  The port has a slipway providing
passenger and vehicle access to the ferry, as well as being used by local fishing vessels, recreational and
privately-owned craft.  The Iona ferry route is operated by CalMac Ferries Ltd (CFL) and provides a lifeline
service linking the Isle of Iona to the Isle of Mull.   
Vessel traffic within the Sound of Iona can be characterised into two groups.  The first is the ferry traffic
which navigates between Fionnphort and Baile Mòr on the Isle of Iona (approximate east to west route,
linking the Isles of Mull and the Isle of Iona).  The second, is traffic transiting through the Sound
(approximate north-east, south-west direction) which is comprised of fishing vessels, recreational
vessels and the Staffa Tour boats which operate from Fionnphort and Baile Mòr on Iona.

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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 audit was carried out onsite at Oban on 06 September 2022, with a site visit to the Isle of Mull and
the Isle of Iona on the 29 September 2022.  The latest version of the PMSC, and the accompanying
Guide to Good Practice (GtGP), has 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, 2020) and SIP 014 ‘Guidance on Safe Access and
Egress’ (PSS, 2019) have been used.  The appendix tables to this report contain the test questions and
evidence, noting down conformity, non-conformity and observational remarks.  
2.4 Auditor
The following auditor conducted this audit.   
Team Member Initials Company, Designation
Harry Aitchison  HJA ABPmer, Maritime Consultant
Internal Auditor: Quality Management Systems (QMS ISO 9001)
Monty Smedley MJS
ABPmer, Principal Maritime Consultant
Lead Auditor for Quality Management Systems (QMS ISO 9001)
Designed Person (PMSC) Argyll and Bute Council
Sophie Butler  SRB ABPmer, Maritime Analyst
Internal Auditor: Quality Management Systems (QMS ISO 9001)
2.5 Auditees
The following individuals participated in the audit.   
Team Member Initials Role/Designation
Allan Finlay AF Piers and Harbours – Technical Officer
Julie Hendry JH Marine Operations – Admin Officer
Scott Reid SR Marine Operations Manager
Vicki McKenzie VM Oban North Pier – Harbour Master

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3 Audit Summary
Number Key Measures
Ten-Point ‘Health Check’   
1 Duty Holder 0 2 5
2 Designated Person 0 1 2
3 Legislation 1 2 3
4 Duties and Powers 0 15 37
5 Risk Assessment 2 1 4
6 MSMS 3 5 9
7 Review and Audit 0 1 4
8 Competence 0 7 3
9 Plan 1 0 2
10 Aids to Navigation 0 0 2
Total 7 34 71 
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 Craignure and the marine facility owner for
Bunessan, Fionnphort and Iona Slipway, the Council is found not to be fully compliant with the
requirements of the Port Marine Safety Code.  The following three non-compliances were recorded: 
 The MSMS does not cite the Craignure 1961 Order, nor are the harbour limits shown.  The MSMS
must contain information on the local legislation for Craignure and expand upon the powers, duties
and responsibilities provided by the local Acts and Orders.  
 The MSMS does not state the expected review frequency for marine risk assessments.  The MSMS
does state in its Annexes for each port that: “The Harbour staff will record all
incidents/accidents/near misses on the Safety Management System (MarNIS). The reports will be
used to review accidents and incidents, for assessing whether any action is necessary to reduce the
risk of recurrence”.  It can be concluded that marine risk assessments are reviewed after incidents
occur, however the MSMS does not state that the risk assessments are updated or re-issued.  The
MarNIS system provides notification of assessments which are about to expire, based on a one-year
review frequency.  Users may set their own review frequency.  
 The ‘Marine Safety Plan’ for the years 2018 to 2020 (the previous plan) has not been assessed and
the Organisation’s performance against the plan published.  
 Bunessan, Fionnphort and Iona do not have any operational marine/navigational risk assessments. 
A review of marine hazards and the creation of marine/navigational risk assessments for Bunessan,
Fionnphort and Iona should be conducted without delay.  
 Bunessan, Fionnphort and Iona are not included in the MSMS.  The Code requires that all marine
facilities, as a minimum, are operated with reference to a proportional MSMS.   
 The MSMS Section 4 addresses ‘Consultation’, with sections on consultation policy, statutory
consultation and consultation with interested parties.  The MSMS does not provide information on
the consultation process in place for Craignure, Bunessan, Fionnphort or Iona.  
 There is no method for recording incident records for Bunessan, Fionnphort and Iona.  Information
from the audit identifies that no incidents have been reported.

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The PMSC audit identified 34 observations relating to improvement opportunities for management
consideration, the detailed findings being presented in Appendix A.  The following points identify the
more significant items: 
 The Admiralty Chart, 2389 ‘Loch Linnhe Southern Part’ and 2390 ‘Sound of Mull’ does not map the
statutory harbour limits for Craignure
 Whilst there are system audits of the MSMS, it is not clear if Craignure, Bunessan, Fionnphort and
Iona have been included in a cyclic audit of unstaffed marine facilities.  
 There have been no bathymetric surveys Bunessan, which this is not a statutory harbour authority
(and therefore a survey is not required under Conservancy Duty) the A&BC Hydrographic Policy
commits to undertaking such hydrographic surveys as are necessary for safe and efficient navigation
and to provide port users with up-to-date and accurate hydrographic information.  As such, the
absence of survey information for Bunessan is considered to be a non-conformity with A&BC’s
hydrographic policy.  
 At the time of audit there was no evidence of an appointment letter for the statutory role of Harbour
Master or Deputy Harbour Master for Craignure.  
 Fionnphort does not have any information on the A&BC ‘Piers and Harbours’ website.  
 The MSMS Annex on Craignure does not provide information on how powers of Special Direction
are used for controlling vessel movements.  
 There is currently no method of obtaining assurance that craft working commercial (i.e., not Council
activities) are operating their vessels in accordance with relevant MCA codes.   
Quayside checks were also carried out all four facilities, a number of observations were recorded as
shown in Appendix B.  The following identify key findings: 
 At Craignure, some of the water egress (safety) ladders do not continue below the waterline.  It is a
requirement that ladders extend to at least 1 m below the water surface at low water.  
 At Bunessan, housekeeping was noted to be poor with disused ropes hanging off the pier and a
substantial amount of stored and/or abandoned fishing equipment.  This equipment obstructed
access to safety equipment and water egress ladders.  
 At Bunessan, one life ring was noted to be in a deteriorated state of repair.  
 At Fionnphort, gated access to the pier was tied shut, with ferry employees witnessed jumping
around the gate rather than going through it.  Operational areas should be gates to prevent public
access; however, gates should be accessible to pier operatives/ferry staff.  
 At the Isle of Iona slipway, a significant amount of concrete obstructed access for small vessels using
the slipway at certain states of tide.  This presents a navigational hazard and creates a risk of vessel
grounding or contact which may result in hull damage.   
The following points of best practice were noted: 
 Provision and maintenance of Aids to Navigation is recognised as an area of best practice with a
100% availability for Category 3 and 99.8% for Category 2 Aids.  
 At the time of audit, all seven Councillors of the Harbour Board, plus the Council’s Executive Director
of Development and Infrastructure Services (as Duty Holder) have attended Duty Holder Training. 
The Marine Safety Plan has an objective of 100% attendance for Duty Holder training.

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4 References
DfT, 2016.  Port Marine Safety Code, Department for Transport (DfT), 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. 
MCA, 2022. Navigation: Vessel Traffic Services (VTS) and Local Port Services (LPS) in the United Kingdom.
Marine Guidance Note: MGN 401 (M+F) Amendment 3.  Maritime & Coastguard Agency, March 2022. 
Port Skills and Safety (PSS), 2019.  Guidance on Safe Access and Egress, SIP 014.  September 2019.
https://www.portskillsandsafety.co.uk/resources/sip014-guidance-safe-access-and-egress 
Port Skills and Safety (PSS), 2020.  Guidance on Mooring, SIP 005.  November 2020.
https://www.portskillsandsafety.co.uk/resources/sip-005-guidance-mooring-operations 
4.1 Websites
https://www.argyll-bute.gov.uk/fees/22/piers 
https://www.argyll-bute.gov.uk/marine-safety-management-system 
https://www.argyll-bute.gov.uk/mid-argyll-kintyre-and-islay/craignure-pier 
https://www.argyll-bute.gov.uk/moderngov/ieListMeetings.aspx?CId=567&Year=0 
https://www.argyll-bute.gov.uk/sites/default/files/dp_contact_information_abc.pdf 
https://www.gov.uk/government/publications/port-marine-safety-code-compliant-ports/port-marine-
safety-code-compliant-ports-list

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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
DfT Department for Transport
DGHAR Dangerous Goods in Harbour Areas Regulations 2016
DRA Dynamic Risk Assessment
DSHAR Dangerous Substances in Harbour Areas Regulations 2016
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
HQ Head Quarters
HR Human Resources
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
M+F Merchant Shipping and Fishing Vessels
MAIB Marine Accident Investigation Branch
MarNIS Maritime Navigation and Information Services
MCA Maritime and Coastguard Agency
MGN Marine Guidance Notes
MS Microsoft
MSMS Marine Safety Management System
n/a Not Applicable
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
RYA Royal Yachting Association
SAC Special Areas of Conservation
SEPA Scottish Environment Protection Agency

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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
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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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), version 11,
issued in May 2020, states in Section 10 under
the heading Conservancy 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 – one of the locations audited has
a harbour Act: 
 Craignure is a Statutory Harbour Authority
(SHA), the harbour authority has a copy of
its local legislation in the form of the ‘Argyll
County Council (Arinagour and Craignure
Piers, etc) Order 1961’.  
 Bunessan, Fionnphort and Iona Slip are
marine facilities and outwith an SHA
boundary, there is no (known) extant local
harbour legislation.   
MJS_005 MJS  
Is the Harbour, Docks and
Piers Clauses Act (HDPCA)
1847 incorporated into local
Acts and Orders?  
Satisfactory – the HDPCA has been
incorporated, as referenced in the Section 2(1)
and Section 3(3)of the 1961 Act.   
MJS_005 MJS
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 2.1.   
MJS_001 MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 13
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
1.8 The Duty Holder Are the Duty Holder’s
responsibilities for
compliance with Code
defined?  
Satisfactory – the MSMS, Section 2.2 lists the
duties of the Duty Holder.   
Observation – the role laid out in the MSMS
for the Duty Holder does not include all the
bullet point requirements listed in the Code
(DfT, 2016).   
Recommend – to ensure a match between
the role, as laid out in the Code, and the
role defined in the MSMS, it is
recommended that Section 2.2. is reviewed.  
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.  Annually the Harbour
Board and Duty Holder visit one of the
Councils 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 making it a simple
process to view the most recent version.   
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 – all the current (seven)
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.  The Marine Safety Plan has an
objective of 100% attendance on the Duty
Holder training course by the completion
date of the plan.  This is an area of best
practice.  It should be noted that at the time
of audit, a bye-election was planned and
following its completion the Harbour Board
will increase to eight.   
MJS_002
MJS_006
MJS
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 were
posted on the Oban staff notice board.   
https://www.arg
yll-
bute.gov.uk/site
s/default/files/d
p_contact_infor
mation_abc.pdf 
MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 14
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.   
1.11-1.12
Cont.   
The Designated
Person
Is the Designated Person’s
role explained in the
MSMS?
Satisfactory – the MSMS, Section 2.5 lists the
duties of the Designated Person.   
Observation – the appointment information in
Section 2.5 of the MSMS is not accurate.   
Recommendation – the Designated
Person’s details in the MSMS are updated.  
MJS_001 MJS
1.13 Chief Executive
[or equivalent]]
Have executive and
operational responsibilities
for marine safety been
clearly assigned?
Satisfactory – the MSMS, Section 2.2 lists the
responsibilities of the Duty Holder, who is
also the Chief Executive.   
Observation – the MSMS, Section 2.2 does
not address the financial and resource role
that typically, a Chief Executive would be
responsible for providing in respect of a
Harbour Authority function.     
Recommendation – the role profile in the
MSMS is reviewed and wording around
‘adequate resources’ is included.  
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 will
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
2.5 lists specific duties.   
MJS_001 MJS  
Does an officer with
responsibilities for marine
safety attend Board
meetings?
Satisfactory – three times a year, a report is
provided by the Executive Director for Roads
and Infrastructure; major issues are raised to
the Harbour Board.  Evidence from the
Harbour Board meeting of 01 September
2022 identifies reports including the Marine
Asset Management Plan Update, Port Marine
Safety Code Update, Oban Bay Update and
Draft Harbour Board Workplan.     
MJS_006
MJS_007 
https://www.arg
yll-
bute.gov.uk/mo
derngov/ieListM
eetings.aspx?CI
d=567&Year=0 
MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 15
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
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 2.3 lists the
responsibilities of the Organisation’s Officers
(including the Head of Roads and Amenity
Services and the Marine Operations
Manager).  Section 2.4 has a sub-heading for
Assistant Harbour Masters.   
Observation – the role of the Technical
Officer(s) for Piers and Harbours could be
usefully included within the MSMS.   
Recommendation – include the role of the
Technical Officer(s) for Piers and Harbours.  
MJS_001 MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 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_009
MJS_010
MJS
2.3 – 2.6 Review existing
powers
Does the Harbour
Authority have an
understanding of local
legislation?
Satisfactory – the Harbour Authority has a
copy of the Craignure 1961 Order, plus a map
with the extent of the harbour limits shown.   
MJS_003
MJS_005
MJS  
Are local Acts and
Harbour Orders
referenced in MSMS?
Non-compliance – the MSMS does not cite
the Craignure 1961 Order, nor are the harbour
limits shown.  
Recommendation – the MSMS must
contain information on the local legislation
for Craignure and expand upon the powers,
duties and responsibilities provided by the
local Acts and Orders.  
MJS_001 MJS  
Have the Harbour
Authority’s existing
powers been reviewed?
Satisfactory – the harbour acts have been
reviewed by A&BC lawyers with an external
review conducted by marine lawyers. 
Recommendations a consolidated Harbour
Act (covering all Argyll and Bute ports,
harbours and marine facilities (excluding
Oban)) has been commenced.   
MJS_047 MJS  
Is the organisation’s
jurisdiction mapped and
clear?
Satisfactory – the ‘Argyll County Council
(Arinagour and Craignure Piers, etc) Order
1961’, Part 4, Section 24(2) sets out the
harbour limits.  This area is mapped by the
Council.   
Observation – the Admiralty Chart, 2389 ‘Loch
Linnhe Southern Part’ and 2390 ‘Sound of
Mull’ does not map the port limits.   
Observation – the MSMS, does not include
information on the Craignure SHA boundary.   
Recommendation – providing the
boundaries to the UK Hydrographic Office
including descriptions from the 1961 Act,
Part 4, Section 24(2) requesting update of
the harbour limits.   
Recommendation – the description for
A&BC’s SHA area at Craignure is included
in the MSMS to match the areas described
in the 1961 Act, Part 4, Section 24(2).  
MJS_003
MJS_005
MJS

Page 23

Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 17
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
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 8 describes
the assessment methodology.  A set of 11 risk
assessments are in place for Craignure
harbour, all assessments were in-date at the
time of audit.  Review dates were completed
on 13 September 2022.  The hazard scenarios
cover a range of foreseeable eventualities
based on current harbour activities.   
Non-compliance – Bunessan, Fionnphort and
Iona do not have any operational
marine/navigational risk assessments.   
Non-compliance – a review of marine
hazards and the creation of
marine/navigational risk assessments for
Bunessan, Fionnphort and Iona.  
MJS_001
MJS_004
MJS_011
MJS_012
MJS  
How does the
organisation ensure
those undertaking
marine risk assessment
are competent?
Satisfactory – the Harbour Master has
undertaken a training course for marine risk
completed on 02 March 2021.  Certificate
sighted.   
MJS_013 MJS  
Are stakeholders
included in marine risk
review/assessments?
Satisfactory – risk assessment reviews are
conducted with the Assistant Harbour Master. 
The risk assessment sample identifies that the
Royal Yachting Association (RYA), the Royal
National Lifeboat Institute (RNLI) and the
Clyde Cursing Club were consulted on
selected risk assessments for Craignure.    
MJS_004
MJS_012
MJS   
Non-compliance – the MSMS does not state
the expected review frequency for marine risk
assessments.  The MSMS does state in its
Annexes for each port that: “The Harbour staff
will record all incidents/accidents/near misses
on the Safety Management System (MarNIS).
The reports will be used to review accidents
and incidents, for assessing whether any action
is necessary to reduce the risk of recurrence”.  It
can be concluded that marine risk
assessments are therefore reviewed after
incidents occur, however it does not state that
the risk assessment is updated or re-issued,
Recommendation – the Harbour Authority
requirement for frequency of risk
assessment review is positively stated in the
MSMS for the avoidance of doubt, for
example: Marine Risk Assessment must be
reviewed annually and following an
accident or incident that changes the
specifics of an existing risk assessment.  
MJS_001 MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 18
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)
Cont.   
Does the MSMS
prescribe the review
frequency for risk
assessments?
Cont.   
nor is any review frequency given.  The
MarNIS system provides notification of
assessments which are about to expire, based
on a standard one-year review frequency. 
Users may set their own review frequency.   
MJS_001 MJS  
Is a system of Dynamic
Risk Assessment (DRA)
used?
Satisfactory – a DRA flow diagram has been
prepared and distributed to harbour staff at
Oban, a copy was posted on the notice board.   
Observation – the MSMS does not addresses
the expectations of the Harbour Authority in
respect to DRA.   
Recommendation – the approach to
Dynamic Risk Assessment is defined for
harbour staff.   
MJS_048 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) is issued as
version 11, dated May 2020.  A revision
history is included with notes defining
changes made over time.  The MSMS is
presented as a manual and supporting
Annexes for individual ports, harbours and
piers which includes Craignure.   
Observation – the MSMS distribution list
contains names of post holders which is out
of date.   
Observation – the MSMS contains various
sections of national guidance, some of which
is generic in nature and not tailored to
A&BC’s specific circumstances.   
Non-compliance – Bunessan, Fionnphort and
Iona are not included in the MSMS.  The Code
requires that all marine facilities, as a
minimum, are operated with reference to a
proportional MSMS.   
Recommendation – the distribution list
should be reviewed with posts and roles
updated as required.   
Recommendation – the MSMS should be
fully reviewed to remove extraneous
information and provide tailored
procedures to each port, harbour and pier. 
Recommendation – marine activities
relevant to Bunessan, Fionnphort and Iona
are documented in the MSMS.  
MJS_001 MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 19
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
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 for ports and harbours are
identified in the ‘Marine Safety Plan’ as
specific outcomes.   
Observation – the MSMS does not address
port and harbour KPIs.   
Recommendation – a section on KPIs
should be included within the MSMS, with
reference to the expectations of internal
business processes and the ‘Marine Safety
Plan’.  
MJS_001
MJS_002
MJS
2.16 MSMS assigning
responsibility
Does the MSMS explicitly
assign responsibility for
appropriate
safety/conservancy
matters?
Satisfactory – the MSMS, Section 2 ‘Key
Personnel and Responsibilities’ assigns
responsibility for safety and conservancy to
key post holders in the Harbour Authority.   
MJS_001 MJS
2.17 MSMS
Consultation
Are forum/consultation
meetings held? 
Non-compliance – the MSMS Section 4
addresses ‘Consultation’, with sections on
consultation policy, statutory consultation and
consultation with interested parties.  The
MSMS does not provide information on the
consultation process in place for Craignure,
Bunessan, Fionnphort or Iona.  
Recommendation – organise and run
regular user consultation meetings, record
meeting minutes and outcomes.    
n/a MJS

Page 26

Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 20
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 – Craignure, Bunessan, Fionnphort
and Iona have no onsite A&BC staff.  The
harbour master team from Oban provides this
function.  With respect to evidence of
competency standards for these staff, two MS
Excel files are maintained, the first is titled
‘Harbour Training Matrix 2021’ the second is
titled ‘training records’.  The training matrix
identifies the Essential, Required,
Advantageous and Not Required training. 
The training records identifies staff by location
with dates against qualifications held.   
Observation – the matrix does not include the
roles of the Duty Holder, the Marine
Operations Manager, Technical Officers,
Senior Pier Operatives and the Marine
Operations Admin Officer.  The training record
files does hold a ‘HQ and Others’ worksheet. 
Observation – it is not clear what the terms
‘Essential’ and ‘Required’ mean on the matrix. 
Observation – the training matrix identifies
roles and named individuals.   
Observation – the MSMS, Section 6.3 states
that: “The ARGYLL & BUTE HARBOUR BOARD
will maintain a training matrix for all staff and
the respective line managers are responsible
for keeping it up-to-date”.  The training matrix
is maintained by the Marine Operations
Admin Officer, with notification of training
completed provided by Harbour Masters.   
Recommendation – that all roles are
identified in the matrix to ensure it
documents all job roles with a remit for
delivering marine safety functions for the
Harbour Authority.   
Recommendation – provide definitions for
the terms used on the matrix for the
avoidance of doubt.   
Recommendation – considering if names
are required against roles in the matrix.   
Recommendation – review the wording and
process in the MSMS Section 6.3 to ensure
it operates as required.  
MJS_001
MJS_014
MJS_015
MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 21
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont. 
2.18
Cont. 
Competence
standards
Is there a policy on
revalidation or
maintenance of
qualifications in place?
Satisfactory – the MSMS, Section 6.1 is titled
‘Argyll and Bute Council Training Policy’.  The
bullet pointed items in the training policy are
considered to be comprehensive.   
Observation – it is not clear if the ‘policy’
within the MSMS has been approved by the
Harbour Board and Duty Holder, nor is it clear
at what frequency this policy is reviewed.   
Recommendation – the policy is separated
from the body of the MSMS manual and
presented as part of a policy pack.  
MJS_001 MJS  
Is there a list of the
organisation’s staff,
training received,
qualifications held
and/or experience
required for their role?
Satisfactory – 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.  Harbour Master
keeps a local record of all staff training.   
Observation – where training has been
undertaken by the Council, the Marine
Operations Admin Officer maintains course
certification.  Where qualifications were
already held by the individual or completed
locally, the Harbour Master holds the
certification.     
Observation – the training records do not
clearly lay out the date taken and expiry date
for qualifications   
Recommendation – that the Council
considers carrying out an audit of
certification required to be held by staff
and updates its central records accordingly. 
Recommendation – adding date taken and
expiry date (named columns) to training
records.  
MJS_001
MJS_014
MJS_015
MJS
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 3.6 details
the process to follow should an incident
occur, this addresses reporting.  The MSMS
Section 9.2, 9.3, 9.6 and 9.7 details incident
procedures and investigation.  There are no
incidents recorded for Craignure (noting that
the database commences in 2017).  Records
evidenced.   
Non-compliance – there is no structured
method for recording incident records for
Bunessan, Fionnphort and Iona.  Information
from audit identifies that no incidents have
been reported.   
Recommendation – a method of recording
incidents, investigations and outcomes
should be put in place for Bunessan,
Fionnphort and Iona.   
MJS_016
MJS_017
MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 22
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
GtGP 13.2 Incidents
involving Death
or Crime
Are procedures in place
for incidents involving
death or crime?
Satisfactory – the MSMS Section 9.8 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 – incident reports are distributed
to the Scottish Environment Protection
Agency (SEPA) and the Maritime and
Coastguard Agency (MCA), the MSMS, Section
3.7.1 identifies MCA reporting requirements.   
MJS_001 MJS
2.23 Incident
statutory
reporting
Are procedures for
reporting incidents to
the MAIB in place?
Satisfactory – the MSMS Section 9.10 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_017
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 October 2018 at:
Campbeltown, Oban, Port Beag, Cuan Ferry
Slip and Easdale Ferry.  The last internal audit
was carried out at Oban in August 2022.   
Observation – whilst there are system audits
of the MSMS, it is not clear if Craignure,
Bunessan, Fionnphort and Iona have been
included in a cyclic audit of unstaffed marine
facilities.   
Recommendation – the development of an
internal audit schedule that includes
unstaffed marine facilities.  
MJS_019
MJS_020
MJS_021
MJS_022
MJS
2.25 Enforcement Are local officers aware
of enforcement powers
and responsibilities?
Satisfactory – the MSMS Section 9.12 provides
the enforcement procedure.   
Observation – text within the MSMS provides
outline requirements.  There are no specific
processes in place for Craignure with respect
to enforcement or prosecution.  This links to
topics of duties and powers, local legislation
and byelaws.   
Recommendation – the development of
Craignure specific information and/or
processes for enforcement and
prosecution.  
MJS_001 MJS  
Is there a policy on
enforcement and
prosecution in place?
Satisfactory – the MSMS, Section 9.11 is titled
‘Enforcement Policy’.   
Observation – it is not clear if the ‘policy’
within the MSMS has been approved by the
Harbour Board and Duty Holder, nor is it clear
at what frequency this policy is reviewed.   
Recommendation – the policy is separated
from the body of the MSMS manual and
presented as part of a policy pack.  
MJS_001 MJS

Page 29

Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 23
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
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 evidence
through the publication of PMSC policy and
plans on the Council’s website. 
https://www.arg
yll-
bute.gov.uk/mar
ine-safety-
management-
system 
MJS
2.27 Plan assessment Is an assessment of the
organisation’s
performance against the
plan published?
Non-compliance – the ‘Marine Safety Plan’ for
the years 2018 to 2020 (the previous plan) has
not been assessed and the Organisation’s
performance published.  
Recommendation – a review of the
previous plan for the years 2018 to 2020 is
assessed and published.  
n/a 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 Council’s
website.  The plan covers the years 2021 to
2023.   
MJS_002 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
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, guidance by the MCA, as the
Council has confirmed it is not compliant at
the time of writing the letter but was working
towards full compliance in a number of key
areas, including: legislation review and
update, policy review, MSMS documentation
and creation of Standard Operating
Procedures (SOPs). 
MJS_023 
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 Craignure SHA area
operating marine facilities.   
n/a MJS

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ABPmer, November 2022, R.4024  | 24
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 – a commitment to ‘safe and
efficient’ port operations is made in the MSMS
within the hydrographic policy and within
individual port, harbour and Pier Annexes. 
Checking of the pier and breakwater is part of
the pier asset inspection regime.   
MJS_001 MJS
3.5 Open port duty Is the port or harbour
subject to Open Port Duty’?
Satisfactory – Craignure operates on the
premise that an Open Port Duty under Section
33 of the ‘Harbours, Docks and Piers Clauses
Act 1847’ is in place.  Bunessan, Fionnphort
and Iona are not subject to Open Port Duty. 
MJS_001
MJS_005
MJS
3.6 – 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, details
the Harbour Authority’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 last
bathymetric survey at Craignure was
conducted on 02 November 2021, the
30 May 2017 at Fionnphort, and
09 November 2020 at Iona.  Information was
passed by the survey contractor to UKHO. 
Observation – there have been no
bathymetric surveys of Bunessan.  The MSMS,
in Section 10 ‘conservancy’ and Section 10.3
‘Hydrographic Policy’ commit to undertaking
such hydrographic surveys as are necessary
for safe and efficient navigation and to
provide port users with up-to-date and
accurate hydrographic information.  As such,
the absence of survey information for
Bunessan is considered to be a non-
conformity with A&BC’s hydrographic policy.   
Recommendation – the policy on
hydrographic survey is applied and
bathymetric surveys conducted at Bunessan
with the information shared with marine
facility users.  
MJS_001
MJS_016
MJS_017
MJS_024
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_025
MJS_026
MJS

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ABPmer, November 2022, R.4024  | 25
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 Craignure has any
powers to licence marine works under its local
Acts and Orders.  There is no licence held for
the disposal of dredged material at sea.   
MJS_005 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 11 is titled
‘Environmental Policy’ and Section 11.1.1
which provides four bullet points on plans,
procedures and policies.  Information
regarding Craignure and its local habitat is
contained in the Oil Pollution Response plan.   
Observation – the environmental policy lacks
detail on how the obligations of the Harbour
Authority under national legislation is
delivered.   
Observation – practical measures for applying
the policy (in terms of procedures) are not
evident from the MSMS.   
Observation – training for staff on
environmental duties and associated policy
and procedures is not in place.   
Recommendation – the policy is separated
from the body of the MSMS manual and
presented as part of a policy pack with
improved information linking to obligations
under national legislation. 
Recommendation – develop procedures
and link to staff training to implement
environmental policy.   
Recommendation – development of a
standardised environmental training
delivery for port, harbour and pier
employees.  
MJS_001
MJS_030
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 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.   
MJS_027
MJS_046
MJS

Page 32

Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 26
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’.  Evidence provided.  In
addition, locally, the Harbour Master has kit
musters and drills prior to each season with
seasonal staff.  Staff also practised replacing a
contaminated boom with a clean boom whilst
keeping any oil entrapped.   
Observation – annual exercises of both the Oil
Pollution Response Plan and the Emergency
Plan at Craignure would be beneficial to
schedule.   
Recommendation – the production of a
yearly planner to detail emergency
exercises.  
MJS_031
MJS_032
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 1961. 
The need for a revision to bring all ports,
harbour, piers and marine facilities into a
common and modern format has been
commenced.   
MJS_047 MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 27
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 – the MSMS identifies the
Harbour Master’s role by name.   
Observation – at the time of audit there was
no evidence of an appointment letter for the
statutory role of Harbour Master or Deputy
Harbour Master for Craignure.   
Recommendation – consider issuing a letter
of appointment for statutory roles, separate
to normal Human Resource (HR) letters.  
MJS_001 MJS
4.3 – 4.5 Byelaws Does the organisation have
powers to make Byelaws,
are these published?
Not applicable – evidence does not support
the powers to make Byelaws at Craignure. 
These powers are not identified in the 1961
Order.  Bunessan, Fionnphort and Iona are
marine facilities and not subject to powers
available to a harbour authority.   
MJS_005 MJS  
Date of last byelaw review? Not applicable – no Byelaws are known to be
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 5.1.3.2, deals
with the topic of Special Direction as a high
level description stating: “Ports will monitor
vessel movements to ensure compliance with
all relevant bye-laws and General or Special
Directions as well as Pilotage Directions and,
where applicable, Local Notices to Mariners”.   
Observation – the MSMS Annex on Craignure
does not provide information on how powers
of Special Direction are used for controlling
vessel movements.   
Recommendation – the MSMS Annex on
Craignure should be expanded to include a
procedure for issuing Special Directions.  
MJS_001 MJS
4.8  General
Directions
Are the powers of General
Directions available to the
Harbour?
Not applicable – evidence does not support
powers of General Direction at Craignure. 
These powers are not identified in the 1961
Order.  Bunessan, Fionnphort and Iona are
marine facilities and not subject to powers
available to a harbour authority.   
MJS_005 MJS  
When were General
Directions last reviewed?
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: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 28
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 Master has powers
at Craignure (but not Bunessan, Fionnphort or
Iona) under the Dangerous Vessels Act 1985. 
This is laid out in the MSMS, Section 10.4.4.   
Observation – information relating to the
expected action for the Harbour Master in
respect of a dangerous vessel should be laid
out as a procedure.   
Recommendation – the creation of a
Standard Operating Procedure based
around actions a Pier or Harbour Master
should take in respect of a dangerous
vessel.  
MJS_001 MJS  
Is the role of the SOSREP
acknowledged?
Satisfactory – the ‘Secretary of State’
overruling the Harbour Master’s direction is
acknowledged in the MSMS, Section 5.1.3.4   
Observation – the term SOSREP is not
included in the MSMS.   
Recommendation – the term SOSREP
should be included with an explanation of
the role and how this operates in the UK.  
MJS_001 MJS
GtGP 6.2 Dangerous
Substances
Are there clear
requirements for
declaration of dangerous
goods/substances? 
Satisfactory – the declaration of dangerous
goods and substances is detailed in the
MSMS, Section 5.1.3.6.  The Council’s website
contains reporting forms for the declaration of
dangerous goods.   
Observation – the MSMS states that:
“Dangerous Substances in Harbour Areas
Regulations (DSHAR) 2016”.  The current
regulations are the ‘The Dangerous Goods in
Harbour Areas Regulations 2016 (DGHAR)’.   
Recommendation – updating the MSMS to
the latest regulation and acronym.  
MJS_001
MJS_042
MJS_043
MJS
GtGP 8.4 Vessel Traffic
Management
Is vessel traffic managed
within the port area, how is
this achieved? 
Satisfactory – vessel traffic self-manages
within Craignure with the regular ferry service
following its passage plan o, and from the
pier.  As marine facilities, Bunessan,
Fionnphort and Iona do not have harbour
jurisdictions requiring vessel traffic
management.   
Observational MJS  
Is vessel traffic monitoring
information passed to the
MCA by the quickest
means?  
Satisfactory – the Council has a CERS login,
however there is no evidence of CERS
reporting given the traffic type using
Craignure, Bunessan, Fionnphort and Iona.   
n/a MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 29
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.  The
formal risk assessment for vessel traffic
management is a strategic action in the
Marine Safety Plan and is dated for
completion by 2023.  This strategic action
references MGN 401, (MCA, 2022).   
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 references the
Railways and Transportation Safety Act
(RATSA) 2003.  The MSMS, Section 9.8 also
references actions to take if a crime has been
committed.  The Council also has a Drink and
Drugs Policy for its own staff.    
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 – A&BC’s harbour operation at
Craignure does not handle vessels of
sufficient size to require a Pilotage Service. 
None of the risk assessments for the harbour
identify the need for a Pilotage Service.   
MJS_011
MJS_012
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
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

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 30
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
GtGP 8.7.15 –
8.8.10
Port Passage
Plan
Is there a published
passage plan?
Satisfactory – information for Craignure is
included in the Admiralty List of Radio Signals
(ALRS), Volume 6.    
ALRS, Volume 6 MJS
GtGP 8.10 Recreational
navigation
Are recreational users of
the harbour considered?
Satisfactory – information is published on
A&BC website providing contact information
and harbour specifics.  Iona slipway
information links to the CalMac webpage. 
Bunessan is listed, with limited information
shown.   
Observation – Fionnphort does not have any
information on the A&BC ‘Piers and Harbours’
website.   
Recommendation – consider making an
entry for Fionnphort on the A&BC ‘Piers
and Harbours’ website.  
https://www.arg
yll-
bute.gov.uk/mid
-argyll-kintyre-
and-
islay/craignure-
pier
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 at Craignure. 
 2x CAT 2: Fixed Red Lights (vertical) leading
lights (240° True).   
MJS_001 MJS
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 2019 to April 2022 as: 
 Cat 2 = 99.84% (target is 99%)
 Cat 3 = 100% (target is 97%) 
Provision and maintenance of Aids to
Navigation is recognised as an area of best
practice.   
MJS_044 MJS
4.25-4.32 Wrecks,
Abandoned or
unserviceable
vessels
Does the MSMS refer to
powers for dealing with
wrecks?
Satisfactory – the MSMS addresses wrecks
within the Conservancy section.  Removal of
wreck from Craignure Bay (Oct/Nov 2022)
evidenced.   
Observation – the MSMS does not contain
specific information on dealing with wrecks,
derelict or abandoned vessels.   
Recommendation – the topic of wrecks,
derelict and abandoned vessels is covered
by a Harbour Authority procedure.  
MJS_001
MJS_029
MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 31
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
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 – the MSMS, Section 13.1.1.6
addresses towage.   
Observation – the section on towage
addresses Campbeltown only.  There is no
comment on towage (either routine or non-
routine) at other A&BC ports, harbours or
piers.   
Recommendation – drafting of appropriate
towage guidelines for all A&BC ports,
harbours or piers.  
MJS_001 MJS  
Is there a process for
approving towage
providers?
Not applicable – there are no towage
providers in Craignure Harbour.   
n/a MJS  
Are non-routine tows pre-
approved / managed by
the organisation?
Satisfactory – the MSMS, Section 13.1.1.6
addresses towage.   
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 – the MSMS, Section 13.1.1.7
addresses commercial diving in the harbour. 
A ‘Permission to Dive Permit’ for 17 June 2021
for Iona and 24 May 2022 for Craignure were
evidenced.   
MJS_001
MJS_034
MJS_035
MJS
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 – the MSMS, Section 13.1.1.2
under ‘Mooring Operations’ states that:
“Where appropriate permission to undertake
Hot Work is required for any burning, welding,
flame cutting, heating by blow torch and
brazing, when it is being done outside the
engine room of a vessel.  All hot work activities
carried out by third parties and other
contractors in the port is controlled by a “Hot
Work Permit”.  There is no history of using the
‘Hot Work Permit’ at Craignure, Bunessan,
Fionnphort or Iona.   
MJS_001 MJS

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 32
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
GtGP – 6.7.3 Bunkering Is there a process for
managing Bunkering?  
Satisfactory – the MSMS, Section 13.1.1.4
states that: “Bunkering may take place within
Harbour areas with approval of the Harbour
Master or his/her Assistant and Bunkering
Operations will follow an Approved Bunkering
Procedure provided by the Bunker Fuel
Supplier”.  The only bunkering activity
undertaken is at Craignure where CalMac
vessels are bunkered by tanker on the vessel
(using the vessel’s own check list and
procedures).     
MJS_001 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 – the MSMS, Section 13.1.1.5 has
a detailed section on the expectations for
Boat Licensing.   
Observation – there is currently no method of
obtaining assurance that craft working
commercial (i.e., not Council contracted
activities) are operating their vessels in
accordance with relevant MCA codes.   
Recommendation – the Harbour Authority
considers the requirements of the Code
and 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: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 33
B Quayside Checks
Visual observation of the harbour and marine facilities are Craignure, Bunessan, Fionnphort and Iona were undertaken on Thursday 29 September 2022.   
B.1 Craignure
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 Craignure Pier was free from
debris and trip hazards.  There was good signage
for the jetty. 
HJA/SRB
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – pedestrian walkways were clearly
marked. 
HJA/SRB
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the pier was in generally good
condition and surface is appropriate to its intended
use. 
HJA/SRB
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 – access and egress ladders were
installed at appropriate distances along the pier. 
HJA/SRB
Is there appropriate LSE at
quay edge?
Satisfactory – adequate lifesaving equipment (life
rings) were installed along the pier. 
Observation – some of the ladders do not continue
below the waterline.  See Image B1. 
Observation – some ladders located at the pier end
were missing handrails and/or grab loops at
deck/cope level. See Image B2.   
Recommendation – ladders should be replaced
with ones that extend to at least 1 m below the
low water mark. 
Recommendation – ladders with missing
handrails or grab looks should have these fitted
to assist ladder users reach the pier deck.   
HJA/SRB
SIP 005 Bollards and
securing
equipment
Does the general condition of
bollards appear to be in good
order?
Satisfactory – in the opinion of the auditor, the
mooring bollards appeared to be well maintained
and painted yellow.  All mooring equipment
observed to be in good condition. 
HJA/SRB  
Are the bollards numbered
and Safe Working Load (SWL)
shown?
Satisfactory – the bollards were all marked with
SWL. 
Observation – there was no (obvious) numbering of
the mooring bollards. 
Recommendation – bollards should be
numbered for ease of identification.
HJA/SRB  
Are additional bollards/rings
required?
Satisfactory – in the opinion of the auditor, ample
mooring bollards on the pier are provided.     
HJA/SRB

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 34
Reference Subject Evidence Required 
For Compliance Observation Recommendations Auditor
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – fendering on the pier is fixed and
observed to be in good condition.  Fendering was
suitable for the vessels being used. 
HJA/SRB
Is the condition of the
fendering in good order?
Satisfactory – pier fendering observed to be in
good condition. 
HJA/SRB
Are chaffing plates used? Satisfactory – chaffing plates and/or wood sections
were in use along the pier edge.   
HJA/SRB
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 – lighting units were installed around
the pier and were considered sufficient for
operations (note, the onsite checks were carried out
in daylight, lighting at night was not seen). 
HJA/SRB
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – the ferry passengers follow a marked
footpath, separate from pier operations.   
HJA/SRB
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – signage was evident throughout the
pier and entrance to the pier. 
HJA/SRB

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Image B1. Craignure, ladder does not extend below waterline  Image B2. Craignure, ladder with missing handrails or grab loops

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B.2 Bunessan
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?
Observation – housekeeping was considered to be
poor.  There were disused ropes hanging off the
pier and there was a substantial amount of stored
and/or abandoned fishing equipment, ropes, pots
and other fishing items along the pier.  See
Image B3. 
Observation – obsolete (rusting) metal lifting
equipment fixed to the pier presented a trip hazard. 
See Image B4.
Recommendation – users of the pier and harbour
staff should remove unused items, dispose of old
fishing gear in a responsible manner and provide
housekeeping to ensure the pier can be used
free of trip hazards.  Any ropes or unwanted
fishing gear can become an entrapment hazard
for wildlife, pier users and contribute to ghost
fishing1.   
Recommendation – lifting equipment should be
removed if no longer in use. 
HJA/SRB
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – the pier had no clearly marked
walkways, but it was considered not required as the
pier is not used routinely by members of the public.   
HJA/SRB
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the pier had clear access approaching
it, the road surface was in reasonable condition but
did have isolated potholes. 
HJA/SRB
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 adequate numbers of
ladders and stairs from the pier. 
Observation – steps were not accessible due to
ropes and other debris impeding access on the
pier.  See Image B3. 
Observation – the handrail located along the pier
edge was very loose. 
Observation – ropes and tires were tied to ladders
impeding use.  See Image B5 . 
Recommendation – clear pier of debris to allow
access to and from ladders and stairs. 
Recommendation – the handrail should be re-
secured firmly to the pier edge. 
Recommendation – clear all ropes and
obstructions from ladders. 
HJA/SRB
Is there appropriate LSE at
quay edge?
Satisfactory – the pier had adequate numbers of life
rings fitted to the handrails. 
Observation – one life ring was found to be in a
deteriorated state.  See Image B6. 
Recommendation – inspection and renewal of
the life ring and the commencement of a regular
inspection regime.  
HJA/SRB 
1  Discarded, lost, or abandoned, fishing gear in the marine environment which contributes to boat damage and death of wildlife through entrapment.

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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 – in the opinion of the auditor the
bollards and rings appeared to be appropriate to
the size of vessels using the pier and in an
adequate state of repair.   
Observation – the bollards and rings may present a
trip hazard. 
Recommendation – that bollards and mooring
rings, or area around the mooring rings at the
pier are painted in a bright colour to aid their
identification.  
HJA/SRB  
Are the bollards numbered
and Safe Working Load (SWL)
shown?
Observation – there was no (obvious) SWL for
bollards. 
Observation – there was no (obvious) numbering of
the mooring bollards.
Recommendation – bollards should be marked
with their SWL. 
Recommendation – bollards should be
numbered for ease of identification.
HJA/SRB  
Are additional bollards/rings
required?
Satisfactory – in the opinion of the auditor, ample
bollards and rings are installed along the pier which
are considered to be appropriate for the size of
vessel being handled. 
HJA/SRB
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Observation – fendering on the pier edge was
observed to be deteriorated and potentially in need
of replacement.  See Image B7. 
Recommendation – review pier edge wooden
protection to consider if replacement is required.  
HJA/SRB
Is the condition of the
fendering in good order?
Observation – fendering on the pier was considered
to be inadequate, vessel owners had provided
temporary and makeshift protection.  
Recommendation – review the fendering
arrangements and consider fitting protective
measures, for example, fixed rubber sections.  
HJA/SRB
Are chaffing plates used? Not Applicable – no chaffing plates seen.  HJA/SRB
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 – light units were installed around the
pier and were considered sufficient for operations
(note, the onsite checks were carried out in
daylight, lighting at night was not seen). 
HJA/SRB
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – the quayside is thought to be used
infrequently and by pedestrians only.   
HJA/SRB
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – signage was evident along the pier
and at the root of the pier. 
HJA/SRB

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Image B3. Bunessan, trip hazards and obstruction to steps. Image B4. Bunessan, obsolete lifting equipment (trip hazard)

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
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Image B5. Bunessan, tires and ropes affixed to ladders Image B6. Bunessan, life ring

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
ABPmer, November 2022, R.4024  | 40 
Image B7. Bunessan, wooden fendering in disrepair

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ABPmer, November 2022, R.4024  | 41
B.3 Fionnphort
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 and slipway were generally
clear of debris and all fishing pots were neatly
stacked to the side. 
Observation – fishing pots were neatly stacked
blocking access to the pier presenting a trip hazard. 
See Image B8. 
Observation – the gate to the pier was tied shut,
and CalMac ferry employees were witnessed
jumping around the gate rather than going
through it. 
Observation – there were a couple of raised metal
eyelets that presented trip hazards and were not
marked with a bright and notable colour. 
Recommendation – pier should be easily
accessible and fishing pots should be moved. 
Recommendation – gate should be locked to
prevent public access; however gates should be
accessible to pier operatives/ferry staff to allow
them access to the restricted area.   
Recommendation – eyelets are either painted or
removed if no longer useful.  
HJA/SRB
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – walkways were clearly marked for
pedestrians and cars accessing the ferry via the
slipway.   
HJA/SRB
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the pier and slipway were generally in
good condition and free of marine growth. There
were a few small potholes. 
HJA/SRB
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 were an adequate number of
access and egress ladders installed.   
HJA/SRB
Is there appropriate LSE at
quay edge?
Satisfactory – Life saving equipment (life rings)
were installed at the appropriate distances along
the pier. 
Observation – one life ring was missing its cover.
See Image B9 
Recommendation – life ring cover should be
replaced.
HJA/SRB
SIP 005 Bollards and
securing
equipment
Does the general condition of
bollards appear to be in good
order?
Satisfactory – in the opinion of the auditor the
bollards and rings appeared in good condition. 
Observation – the bollards and rings may present a
trip hazard and were not marked with a bright and
notable colour. 
Recommendation – bollards on the pier and
mooring rings, or area around the mooring rings
on the slipway are painted in a bright colour to
aid their identification.  
HJA/SRB

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ABPmer, November 2022, R.4024  | 42
Reference Subject Evidence Required 
For Compliance Observation Recommendations Auditor
Cont.   
SIP 005
Cont.   
Bollards and
securing
equipment
Are the bollards numbered
and Safe Working Load (SWL)
shown?
Observation – there was no (obvious) SWL for
bollards. 
Observation – there was no (obvious) numbering of
the mooring bollards.
Recommendation – bollards should be marked
with their SWL. 
Recommendation – bollards should be
numbered for ease of identification.
HJA/SRB  
Are additional bollards/rings
required?
Satisfactory – in the opinion of the auditor, ample
bollards and rings are installed along the pier and
slipway which are considered to be appropriate for
the size of vessel being handled. 
HJA/SRB
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – pier fendering is fixed and observed
to be in good condition.   
HJA/SRB
Is the condition of the
fendering in good order?
Satisfactory – all fitted fendering was observed to
be in good condition. 
HJA/SRB
Are chaffing plates used? Not Applicable – no chaffing plates seen.  HJA/SRB
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 – light units were installed around the
pier and were considered sufficient for operations
(note, the onsite checks were carried out in
daylight, lighting at night was not seen). 
HJA/SRB
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – walkways were clearly marked for
pedestrians and cars accessing the ferry via the
slipway.   
HJA/SRB
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – signage was evident at the
throughout pier and slipway. 
HJA/SRB

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Image B8. Fionnphort, access to pier blocked by fishing pots Image B9. Fionnphort, life ring missing cover

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Port Marine Safety Code - Audit: Isles of Mull and Iona (Craignure, Bunessan, Fionnphort, Iona) 2022   Argyll and Bute Council
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B.4 Iona
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 –both slipways had good access and
were clear of debris.   
Observation – a significant amount of concrete
obstructed access for small vessels using the
slipway at certain states of tide.  This presents a
navigational hazard and creates a risk of grounding
or contact which may result in vessel hull damage.     
Recommendation – concrete obstructions are
removed from the seabed to allow increased
access by vessels. 
HJA/SRB
Pedestrian/Disabled access for
passengers or leisure users?
Satisfactory – walkways were clearly marked for
pedestrians and cars accessing the ferry via the
ferry slipway.  The small vessel slipway was just
used by members of the public, so no walkways
were marked. 
HJA/SRB
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the slipway was generally in good
condition and free of marine growth. 
Observation – the ferry slipway had some obvious
potholes and was considered to be in need of
surface maintenance. 
Observation – the surface of the bottom of the
small vessel slip was poor and uneven.  There was
also a reasonable sized step, that was not marked.
See Image B10. 
Recommendation – ferry slipway surface should
be reviewed, and repair arranged if trip hazards
are identified.   
Recommendation – the small vessel slipway
surface is repaired, and the step is incorporated
into a slope or marked.  
HJA/SRB
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 – there was an access ladder fitted on
to the ferry slipway. 
Observation –a rope is used to help prevent an
accidental fall from the top of the ladder.  See
Image B11 
Recommendation – a suitable karabiner and wire
(stainless steel) is used to replace the rope,
allowing safe access to and from the ladder when
required.
HJA/SRB
Is there appropriate LSE at
quay edge?
Satisfactory – Life saving equipment (life rings)
were installed at the required intervals. 
Observation – there was no lifesaving equipment
accessible off the small vessel slip way 
Recommendation – move one life ring to the
south side of the handrail facing the small vessel
slip
HJA/SRB

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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 mooring rings on the small vessel
slip way are in good condition.  Mooring rings on
the ferry slip were in good condition but rusted. 
Observation – there was one bollard on the north
edge of the ferry slipway that lacked maintenance.   
Recommendation – bollard is either maintained
or removed if no longer in use
HJA/SRB  
Are the bollards numbered
and Safe Working Load (SWL)
shown?
Observation – there was no (obvious) SWL for the
bollard. 
Observation – there was no (obvious) numbering of
the mooring bollard.
Recommendation – bollards should be marked
with their SWL. 
Recommendation – bollards should be
numbered for ease of identification.
HJA/SRB  
Are additional bollards/rings
required?
Satisfactory – in the auditor’s opinion, mooring
rings on the ferry slip were adequate and suitable
for the vessels using them. 
Observation – through anecdotal information and
observation the mooring rings were judged to be
unfit for use due to construction. 
Recommendation – repair or replace mooring
rings to ensure they are suitable for vessels.
HJA/SRB
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Not applicable    HJA/SRB
Is the condition of the
fendering in good order?
Not applicable    HJA/SRB
Are chaffing plates used? Not applicable    HJA/SRB
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 – light units were installed around the
pier and were considered sufficient for operations
(note, the onsite checks were carried out in
daylight, lighting at night was not seen). 
HJA/SRB
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – walkways were clearly marked for
pedestrians and cars accessing the ferry via the
slipway.   
HJA/SRB
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – signage was evident at all slipways.      HJA/SRB

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Image B10. Iona, small vessel slipway step and poor quality surface Image B11. Iona, access ladder is blocked by rope

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