Appendix B Helensburgh and Kilcreggan Report

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Argyll and Bute Council 
Port Marine Safety Code
Audit: Helensburgh & Kilcreggan Piers 2021 
November 2021

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Port Marine Safety Code
Audit: Helensburgh & Kilcreggan Piers 2021 
November 2021

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | i
Document Information
Document History and Authorisation
Title Port Marine Safety Code
Audit: Helensburgh & Kilcreggan Piers 2021
Commissioned by Argyll and Bute Council
Issue date November 2021
Document ref R.3730
Project no R/4952/01
Date Version Revision Details
19 October 2021 1 Issued for client review
11 November 2021 2 Issued for client use
Authorised
(Designated Person)
Approved
(Quality Manager)
Authorised
(Project Director)
Monty Smedley Will Fellows Gordon Osborn
Suggested Citation
ABPmer, (2021). Port Marine Safety Code, Audit: Helensburgh & Kilcreggan Piers 2021, ABPmer Report No. R.3730.
A report produced by ABPmer for Argyll and Bute Council, November 2021.
Authors
M.J. Smedley
Notice
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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 ............................................................................................................... 3
2.1 Audit purpose and scope ......................................................................................................................... 3
2.2 Audit definitions and outcomes ............................................................................................................ 3
2.3 Audit date and criteria .............................................................................................................................. 4
2.4 Auditors........................................................................................................................................................... 4
2.5 Auditees .......................................................................................................................................................... 4
3 Audit Summary ........................................................................................................................... 5
4 References .................................................................................................................................... 7
4.1 Websites ......................................................................................................................................................... 7
5 Abbreviations/Acronyms ........................................................................................................ 8
Appendices
A Detailed Audit Findings ........................................................................................................ 11
A.1 PMSC Section 1 – Accountability for Marine Safety .................................................................. 11
A.2 PMSC Section 2 – Key Measures Needed to Secure Marine Safety .................................... 14
A.3 PMSC Section 3 – General Duties and Powers ............................................................................. 21
A.4 PMSC Section 4 – Specific Duties and Powers ............................................................................. 24
B Quayside and Mooring ......................................................................................................... 30
B.1 Quayside Observations: Helensburgh Pier and Slipways ......................................................... 30
B.2 Quayside Observations: Kilcreggan Pier ......................................................................................... 33
B.3 Mooring Operations ............................................................................................................................... 35
Images
Image B1. Helensburgh Pier, mooring bollard .................................................................................................. 32
Image B2. Helensburgh Pier, derelict decking section ................................................................................... 32

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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
Managemen
t 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
Argyll and Bute Council is the marine facility owner and operator for the Helensburgh Pier and adjacent
slipways, and the Kilcreggan Pier on the Rosneath Peninsula. These marine facilities are not Statutory
Harbour Authorities (SHA) in their own right, Helensburgh sits within the ‘Clyde Dockyard Port of
Gareloch and Loch Long’ (which is a Queen’s Harbour Master Dockyard Port) and Kilcreggan sits within
the SHA for Clydeport which is a privately owned Harbour Authority operated by Peel Ports.
Helensburgh Pier was built in 1860 and is a 245 m pier, with a L-Shaped jetty head, with a wide pier
leading to a car park. The pier has two slipways, one on either side at the root of the pier. The pier has
not accepted vessel since 2020 when the berthing area and access steps were restricted in use with
pedestrian railings added and access steps removed or blocked off. A fire in the 1970s on the pier
destroyed the previous pier building, leaving the pier decking in one area in a derelict condition. The
derelict section has security fencing to prevent public access. Helensburgh Pier is not staffed but is
inspected by the Kilcreggan Pier Master on a scheduled basis.
Kilcreggan Pier provides berthing and passenger access for the ferry service connecting Gourock with
Kilcreggan. The original pier was built in 1850 and was replaced by the current pier in 1897. The ferry
assigned to this route is the 19.5 m Motor Vessel (MV) Chieftain which is operated by CalMac Ferries
Ltd (CFL). The vessel provides a service for foot passengers, with a summer schedule, Monday to Friday,
from circa 06:50 to 18:45 hr; with reduced hours service on Saturday. Kilcreggan Pier is permanently
staffed with a Pier Master and Pier Operatives.

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2 Purpose and Method
2.1 Audit purpose and 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 port auditing to establish if the
requirements of the Code are being met at each of A&BC’s ports, harbours and piers. Each facility will
be audited as a rolling programme. The scope of each audit requires an on-site visit. The purpose of
the site visit is to review the port, harbour or pier’s marine safety management system, vessel traffic
management and mooring operations. The detailed audit topic list is drawn from the latest edition of
the Code and laid out in Appendix A of this report. 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, addressed 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 on-site at Helensburgh Pier and Kilcreggan Pier on the 22 September 2021. 
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 Auditors
The following auditors conducted this audit.   
Team Member Initials Company, Designation
Monty Smedley MJS
ABPmer, Principal Maritime Consultant
Lead Auditor for Quality Management Systems (QMS ISO 9001)
Designated Person (PMSC) Argyll and Bute Council
2.5 Auditees
The following individuals participated in the audit.   
Team Member Initials Role/Designation
Allan Finlay AF Piers and Harbours – Technical Officer
Gavin Walker GW Kilcreggan & Helensburgh Pier Master
Julie Hendry JH Marine Operations – Admin Officer
Scott Reid SR Marine Operations Manager

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3 Audit Summary
Number Key Measures
Ten-point ‘health check’
1 Duty Holder 0 2 5
2 Designated Person 0 2 2
3 Legislation 0 0 1
4 Duties and Powers 0 16 26
5 Risk Assessment 4 1 1
6 MSMS 1 4 8
7 Review and Audit 0 1 3
8 Competence 0 9 3
9 Plan 1 0 2
10 Aids to Navigation 0 1 2
Total 6 36 53
The summary presented in the above table identifies that, for the ten-point health-check, Argyll and
Bute Council as the marine facility owner and operator of Helensburgh and Kilcreggan Piers is found
not to be fully compliant with the requirements of the Port Marine Safety Code. The following non-
compliances were recorded:
 There are no marine risk assessments for Helensburgh or Kilcreggan Piers.
 There is no documented stakeholder engagement with marine risk assessments.
 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 default one-year review frequency. Users may set their own review frequency.
 The MSMS does not address dynamic risk assessment [see the GtGP (DfT, 2018) Section 4.4].
 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.
 Whilst A&BC produces a Marine Safety Management System (MSMS) [referenced as version 11,
dated May 2020]; there is no Annex for either Helensburgh or Kilcreggan Piers. The MSMS
Manual is applicable to marine operations at all locations. The specific processes and
procedures relevant to the pier operations at Helensburgh and Kilcreggan are not included
within a dedicated Annex as they are for other ports, harbours and piers operated by A&BC.
The PMSC audit identified 36 observations relating to improvement opportunities for management
consideration, the detailed findings being presented in Appendix A. Marine operations and quayside
checks were also carried out, 3 observations were identified, the detailed findings being presented in
Appendix B. The following points identify the more significant items:
 The A&BC training matrix does not include the Kilcreggan Pier Master or Pier Operatives.
 Incidents are not logged into MARNIS as there is no specific database for Helensburgh or
Kilcreggan.

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 Helensburgh and Kilcreggan Piers have not received internal audits, it is recommended that
internal audits at piers should be factored into the internal audit schedule for A&BC.
 The Kilcreggan Pier webpage on A&BC’s website links a third party ‘UK Ports and Harbours’
page which has out of date contact information.
 There is no contact information for Kilcreggan Pier in the Admiralty List of Radio Signals (ALRS)
volume 6. As the pier is permanently staffed, providing contact information would be
advantageous.
 The ‘Rates on vessels’ covers all of A&BC’s marine facilities (both statutory and non-statutory).
Note 2 of the port-and-harbours-rates page’ states that: “All vessels are liable for dues at the
Basic Rate”. Helensburgh and Kilcreggan Piers are not Statutory Harbour Authorities, powers
to charge for use of the facility is expected, however powers to levy dues are not available.
 The MSMS contains various sections of national guidance, some of which are generic in nature
and not tailored to A&BC’s specific circumstances. The MSMS should be fully reviewed to
remove extraneous information and provide tailored procedures to each port, harbour and pier.
 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. It is recommended that policy
is separated from the body of the MSMS manual and presented as a policy pack (or similar).
 There are no formal AtoN on Kilcreggan Pier. The need for Aids to Navigation to mark
Kilcreggan Pier should be reviewed.
 At Kilcreggan Pier, during mooring operations head protection was not observed. With heaving
lines thrown to the pier, this activity should be subject to a risk assessment to consider if any
additional Personal Protective Equipment (PPE) is required.
 At Helensburgh the pier is closed to marine traffic, a Notice to Mariner to this effect has been
issued; however, there are no signs apparent to seaward that would convey this message to
mariners approaching by vessel.
The following areas of best practice were noted:
 All eight Councillors of the Harbour Board, plus the Council’s Executive Director of Development
and Infrastructure Services (as Duty Holder) have attended training run on 14 May 2021. 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.
 Provision of bathymetric surveys for the piers and their approaches is considered to be best
practice and a commitment by the Council’s in its duty of care for pier users.
 An Oil Pollution Response Plan is in place, which has been approved by the MCA. Given the
size of marine operations at Helensburgh and Kilcreggan Piers a response plan is recognised as
an area of best practice.
 At Kilcreggan Pier, the pedestrian access routes, on site management by the pier staff and
waiting area at a dedicated pier building makes for safe and efficient marine operations. The
pier buildings have been newly refurbished, the layout and maintenance of the Kilcreggan Pier
is considered to be an area of best practice.

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4 References
Department for Transport (DfT), 2016.  Port Marine Safety Code.  November 2016. 
Department for Transport (DfT), 2018.  A Guide to Good Practice on Port Marine Operations Prepared
in conjunction with the Port Marine Safety Code 2016.  February 2018. 
Health and Safety Executive (HSE), 2014.  ‘Safety in Docks: Approved Code of Practice and Guidance’
(ACOP)’, Publication L148. 
ISO 9001: Quality Management Systems.  International Organization for Standardization. 
Port Skills and Safety (PSS), 2020.  Guidance on Mooring, SIP 005.  November 2020.
https://www.portskillsandsafety.co.uk/resources/sip-005-guidance-mooring-operations 
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 
4.1 Websites
http://www.ports.org.uk/port.asp?id=389 
https://www.argyll-bute.gov.uk/helensburgh-pier 
https://www.argyll-bute.gov.uk/marine-safety-management-system 
https://www.argyll-bute.gov.uk/moderngov/ieListDocuments.aspx?CId=567&MId=14305 
https://www.argyll-bute.gov.uk/piers-and-harbours-argyll-and-bute 
https://www.argyll-bute.gov.uk/ports-and-harbours-vessels/ports-and-harbours-rates-vessels 
https://www.facebook.com/KilcregganFerry

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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 Aids to Navigation
BPA British Ports Association
CEO Chief Executive Officer
CERS Consolidated European Reporting System 
CFL CalMac Ferries Ltd
CHA Competent Harbour Authority
Code Port Marine Safety Code
DfT Department for Transport
DGHAR Dangerous Goods in Harbour Areas Regulations
DRA Dynamic Risk Assessment
DSHAR Dangerous Substances in Harbour Areas Regulations
GLA General Lighthouse Authority
GtGP Guide to Good Practice
Hi-viz High Visibility
HSE Health and Safety Executive
IMO International Maritime Organization
ISO International Organization for Standardization
KPI key performance indicator
LATON Local Aids to Navigation
LLA Local Lighthouse Authority
LPS Local Port Service
LSE Lifesaving equipment 
MAIB Marine Accident Investigation Branch
MarNIS Maritime Navigation and Information Services
MCA Maritime and Coastguard Agency
MGN Marine Guidance Note
MSMS Marine Safety Management System
MV Motor Vessel / Merchant Vessel
n/a Not Applicable
NtM Notices to Mariners
PEC Pilotage Exemption Certificate
PFSO Port Facility Security Officer
PFSP Port Facility Security Plan
PMSC Port Marine Safety Code
PPE Personal Protective Equipment
PS Paddle Steamer 
PSS Port Skills and Safety
QMS Quality Management Systems
RATSA Railways and Transportation Safety Act
Regs Regulations
SAC Special Areas of Conservation
SHA Statutory Harbour Authorities
SIP Safety In Ports
SOSREP Secretary of State’s Representative
SPA Special Protection Area
SWL Safe Working Load

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UK United Kingdom
UKHO UK Hydrographic Office
VHF Very High Frequency
VTS Vessel Traffic Service 
Cardinal points/directions are used unless otherwise stated. 
SI units are used unless otherwise stated.

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Appendices

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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?
Not applicable – Helensburgh and Kilcreggan
Piers are marine facilities and do not have their
own local Acts and Orders.
n/a MJS
Is the Harbour, Docks and
Piers Clauses Act 1847
incorporated into local
Acts and Orders?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.
n/a 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
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).
Observation – 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

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PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
1.10 The Duty
Holder
Does the Duty Holder
(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 visit was organised
in Oban on 24 September 2021. The MSMS is
provided on the Council’s website making it a
simple process to view an up to date copy.
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 eight Councillors of the
Harbour Board, plus the Council’s Executive
Director of Development and Infrastructure
Services (as Duty Holder) have attended
training run on 14 May 2021. 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.
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.
Observation – the Designated Person’s contact
details are not available to the harbour
community (stakeholders).
Recommendation – the Designated Person’s
contact details are made available, for
example, on the Council’s website.
n/a MJS
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
Officer (CEO)
[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

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PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
1.13
Cont.
Chief
Executive
Officer (CEO)
[or
equivalent]]
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 02 September 2021 identifies
reports including the Marine Asset
Management Plan, Oban Bay Harbour Authority
Proposal and the Port Marine Safety Code
report (which includes a Designated Person
Briefing note).
MJS_006
MJS_007
MJS_009
https://www.ar
gyll-
bute.gov.uk/m
oderngov/ieLi
stDocuments.a
spx?CId=567&
MId=14305
MJS
1.16-1.17 The
Organisation’s
Officers
Does the MSMS provide
details of the
organisation’s Officers
and their responsibilities
for marine safety?
Satisfactory – the MSMS, Section 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

Page 19

Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 14
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.
Evidence sighted. Information from the MAIB
and the BPA in the former of safety circulars are
distributed by the Marine Operations Admin
Officer. Anecdotal information suggests that
relevant information shared with the Pier
Operative.
MJS_008
MJS_010
MJS
2.3-2.6 Review
existing
powers
Does the Harbour
Authority have an
understanding of local
legislation?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.
n/a MJS
Are local Acts and
Harbour Orders
referenced in the MSMS?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.
n/a MJS
Have the Harbour
Authority’s existing
powers been reviewed?
Satisfactory – Helensburgh and Kilcreggan Piers
have been considered for inclusion into new
Statutory Boundaries proposed as part of a
consolidated harbour act. Evidence seen.
MJS_048
MJS_049
MJS
Is the organisation’s
jurisdiction mapped and
clear?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.
n/a MJS
2.7-2.11 Use of formal
Risk
Assessment
Have risks associated
with marine operations
been assessed and a
means of controlling
them deployed?
Non-compliance – there are no marine risk
assessments for either Helensburgh or
Kilcreggan Piers (an exercise was previously
carried out in circa 2014 but records could not
be located).
Recommendation – the review and creation of
a set of marine risk assessments for each of
the Pier facilities.
n/a MJS
How does the
organisation ensure
those undertaking marine
risk assessment are
competent in the role?
Satisfactory – the Pier Master for Helensburgh
and Kilcreggan has received training in the
creation and review of marine risk assessments.
Observation – the Pier Master has a read-only
view of MARNIS. Anything that needs logging
must be passed to the Marine Operations
Admin Officer.
Recommendation – consider how staff with
read-only access are able to maintain skills
following marine risk assessment training.
n/a MJS

Page 20

Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 15
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
Are stakeholders
included in marine risk
review/assessments?
Non-compliance – there is no documented
stakeholder engagement on marine risk
assessments.
Recommendation – marine risk assessment
should be consulted upon with pier users and
other relevant stakeholders.
n/a MJS
Does the MSMS
prescribe the review
frequency for risk
assessments?
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, 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.
Recommendation – the Harbour Authority
expectation 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
Is a system of Dynamic
Risk Assessment used?
Non-compliance – 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 pier staff.
MJS_001 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.
Non-compliance – whilst A&BC produces a
Marine Safety Management System (MSMS)
[referenced as version 11, dated May 2020];
there is no Annex for either Helensburgh or
Kilcreggan Piers. As a Statutory Harbour
Authority and Marine Facility owner/operator,
the MSMS Manual is applicable to marine
operations at all locations. The specific
processes and procedures relevant to the pier
operations at Helensburgh and Kilcreggan are
not included within a dedicated Annex as they
are for other ports, harbours and piers operated
by A&BC.
Recommendation – ensure that marine
operations for Helensburgh and Kilcreggan
Piers are included in the MSMS.
MJS_001 MJS

Page 21

Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 16
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
2.15 MSMS
standards and
KPIs
Does the MSMS 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 objectives
with measurable 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
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. Section
3.1 of the MSMS includes the Kilcreggan Pier
Master and Pier Operative within the line
diagram.
MJS_001 MJS
2.17 MSMS
Consultation
Are forum/consultation
meetings held?
Satisfactory – the MSMS Section 4 addresses
‘Consultation’, with sections on consultation
policy, statutory consultation and consultation
with interested parties. Locally, the Cove and
Kilcreggan Community Council meetings are
held (every second Tuesday of the month) at
which Pier Master is invited to attend. The
Kilcreggan Ferry User Group also meets to
discuss the ferry travel and harbour
developments, the Pier Master is an invitee to
this group.
Observation – consultation is not detailed in the
MSMS.
Recommendation – a section on consultation
is added to the MSMS documenting
Kilcreggan and Helensburgh engagement.
MJS_001
https://www.fa
cebook.com/K
ilcregganFerry
MJS
2.18 Competence
standards
Are personnel qualified
and trained for their
marine safety role?
Satisfactory – a training matrix is provided for
the Harbour Authority, this identifies the
Essential, Required, Advantageous and Not
Required training. Helensburgh is unmanned
but is periodically visited by Pier staff from
Kilcreggan. The Pier Master is included in the
training certification record which identifies that
the following qualifications are held: VHF
Operator, Oil Spill 4P, Marine Risk Assessment,
First Aid, PFSO, PMSC Internal Auditor, Counter
Terrorism Awareness and Responsible Person
(training). Plus e-learning modules from LEON.
MJS_001
MJS_014
MJS_015
MJS

Page 22

Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 17
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.18
Cont.
Competence
standards
Are personnel qualified
and trained for their
marine safety role?
Observation – the training matrix does not
include the Kilcreggan Pier Master or Pier
Operatives.
Observation – it is not clear what the terms
‘Essential’ and ‘Required’ mean on the matrix.
Observation – the training matrix identifies
roles and named individuals. As the matrix is a
list of training against specific job roles, the
names of individual post-holders are not
necessary.
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 the Pier Master.
Recommendation – review the matrix to
ensure it includes the Kilcreggan Pier Master
and Pier Operative roles.
Recommendation – provide definitions for the
terms used on the matrix.
Recommendation – the removal of names
from the Harbour Authority’s training matrix
(note: training records do require individual
named employees).
Recommendation – review the wording of the
MSMS Section 6.3 and updated to the current
process.
MJS_001
MJS_014
MJS_015
MJS
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.
The sheet contains two worksheets (tabs), the
first documents training records and the second
documents the role requirements. Individual
staff are identified with dates of training and
certification held in day/month/year format.
The Pier Master maintains a local copy of
certification.
MJS_001
MJS_014
MJS_015
MJS_019
MJS

Page 23

Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 18
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.18
Cont.
Competence
standards
Is there a list of the
organisation’s staff,
training received,
qualifications held and/or
experience required for
their role?
Observation – it is not clear if the ‘role
requirement’ tab in the Training Record
spreadsheet is current or has been superseded
by the separate spreadsheet ‘Harbour Training
Matrix 2021’.
Observation – the training records worksheet
(tab) indicates the date of attendance on
courses, qualifications expiring are shown in
red.
Observation – the layout of the ‘Training
Records’ could be improved by adopting the
same or similar list as used in the matrix. This
would allow for an easier comparison.
Observation – the training records worksheet
(would appear) to document Harbour Masters
and Assistant Harbour Masters, plus the Marine
Operations Admin Officer. Other personnel are
not included.
Recommendation – any redundant
information or tabs are removed. One version
of the matrix prevents ambiguity.
Recommendation – the addition of an
attendance and expiry dates (as two columns)
to clarify information.
Recommendation – organising the training
record sheet to match the training matrix
course list.
Recommendation – the Harbour Authority
considers how it wishes to maintain staff
training records. Evidence suggests that some
roles are monitored centrally (for example,
Harbour Masters) with Pier/Marina Operatives
monitored at a local level.
MJS_001
MJS_014
MJS_015
MJS_019
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. Incidents at Helensburgh and
Kilcreggan include:
Helensburgh:
 2021: Two drowning fatalities.
 ongoing: Lifesaving equipment damage.
Kilcreggan:
 1980s: Vehicle driven down the pier and into
the water, resulting in the death of the driver.
 Various: Small yachts, requesting port of
refuge assistance.
 2021: contact damage caused by the Paddle
Steamer (PS) Waverly whilst alongside.
MJS_001 MJS

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 19
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.19-2.22
Cont.
Incident
reporting and
investigation
Cont.
Does the MSMS identify
the organisation’s
instruction regarding:
 reporting
 recording of incidents
 investigation
 enforcement (if
relevant).
Observation – incidents are not logged into
MARNIS as there is no specific database for
Helensburgh or Kilcreggan.
Recommendation – databases are created for
Helensburgh and Kilcreggan.
MJS_001 MJS
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. With the removal of the local police
officer, the method used to obtain police
support is to call 101 or 999. There is however,
good communications with Boarder Force who
have visited the Pier Master to provide a point
of contact.
MJS_001 MJS
GtGP 13.9 Incident
publication
Does the Harbour
Authority disseminate
information from
accident investigations?
Not applicable – there has been no incident
investigations at Helensburgh or Kilcreggan
Piers requiring publication.
n/a 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’.
MJS_001 MJS
2.24 Monitoring
performance
and auditing
Has the MSMS been
subject to audit (internal
and/or external)?
Satisfactory – the last external audit of the
MSMS was conducted in October 2018 at:
Campbeltown, Oban, Port Beag, Cuan Ferry Slip
and Easdale Ferry. This meets the expectation
of the GtGP for an external audit every three
years.
Observation – Helensburgh nor Kilcreggan Piers
have not received internal audits.
Recommendation – internal audits at Piers
should be factored into the internal audit
schedule for A&BC.
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. As Helensburgh
and Kilcreggan Piers are not SHAs, there are no
enforcement powers.
MJS_001 MJS

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 20
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendation Evidence
Reference Auditor
Cont.
2.25
Cont.
Enforcement
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
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.ar
gyll-
bute.gov.uk/m
arine-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 and
service providers about
safe navigation?
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 to
confirm its current state of compliance with the
Code. Letter evidenced.
MJS_023 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?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities and
therefore have no jurisdictional area.
n/a MJS

Page 26

Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021    Argyll and Bute Council
ABPmer, November 2021, R.3730  | 21
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.  A&BC also
issue Notices to Mariners (NtM) for any works
or marine notification related to either
Helensburgh or Kilcreggan Piers.   
MJS_001
MJS_003
MJS
3.5 Open port
duty
Is the port or harbour
subject to Open Port
Duty’?
Not applicable – Helensburgh and Kilcreggan
Piers are marine facilities owned by A&BC, they
are not subject to Open Port Duty.  ‘Piers and
Harbours Rates (vessels)’ charges are advertised
on the Council’s website.   
https://www.ar
gyll-
bute.gov.uk/po
rts-and-
harbours-
vessels/ports-
and-harbours-
rates-vessels 
MJS
3.6-3.6 Conservancy
duty
How does the harbour
authority conserve the
harbour?:
 Survey as regularly as
necessary
 Place navigation marks
in optimum positions
 Keep ‘vigilant watch’
for any sea bed
changes
 Keep hydrographic
records
 Ensure hydrographic
information is
published
 Update UKHO with
chart information.  
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 Helensburgh was conducted on
02 July 2019 and the last bathymetric survey at
Kilcreggan was conducted on 03 July 2019
Information was passed by the survey
contractor to UKHO.  Evidence sighted.  It
should be noted, that the provision of
hydrographic survey for Helensburgh and
Kilcreggan Piers is provided as a duty of care to
port users as a marine facility owner; and for
operational reasons to monitor depth for the
ferry services.  Provision of bathymetric survey
for an area which is not a Statutory Harbour
Authority is considered to be a best practice
approach.   
MJS_001
MJS_046
MJS_047 
MJS

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 22
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
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_026 MJS
GtGP 1.9.11,
7.8
Licensing,
Regulating
Harbour
Works and
Dredging?
Does the harbour
authority have the power
to licence works?
Satisfactory – Helensburgh and Kilcreggan Piers
are not SHAs, any marine works will require a
Marine Licence from Marine Scotland. A NtM is
issued for all works that are notifiable to
mariners.
MJS_003 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.
 Compliance with
‘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
Helensburgh and Kilcreggan Piers 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_031
MJS
3.9 Civil
Contingency
Duty
Does the MSMS include
reference to the Harbour
Authority’s obligations as
a Category 2 responder?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities and
therefore are not Category 2 responders under
the Civil Contingencies Act.
MJS_038 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. Given the size of
Helensburgh and Kilcreggan Piers, this is
recognised as an area of best practice.
MJS_027
MJS_032
MJS

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021    Argyll and Bute Council
ABPmer, November 2021, R.3730  | 23
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 – the Harbour Authority carries out
exercises (as a Group function).  The Pier
Master (Kilcreggan) attended 4P Training
course on 12 March 2020.  There is oil pollution
response equipment held on site at Kilcreggan,
for Helensburgh the equipment is stored less
than a mile away (at Blackhill).   
Observation – there have been no training
exercise for oil pollution response at
Helensburgh or Kilcreggan using the Pier
Master and Pier Operatives.   
Recommendation – the scheduled exercise
(actual, or table top) for Oil Pollution response
specific to Helensburgh or Kilcreggan Piers. 
n/a MJS
3.10-3.11 Harbour
Authority
Powers and
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.  
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.   
n/a MJS

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ABPmer, November 2021, R.3730  | 24
A.4 PMSC Section 4 – Specific Duties and Powers
PMSC / GtGP
Reference Subject Evidence Required 
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
4.2 Appointment
of Harbour
Master
Is there a Harbour
Master appointment for
the port?
Satisfactory – a job description for the role of
Pier Master at Kilcreggan is held on file by the
Council, dated 31 January 2007   
Observation – the job description does not
identify duties associated with Helensburgh Pier.       
Recommendation – the job description is
reviewed to ensure it is specific to the role at
Kilcreggan and Helensburgh Piers.   
MJS_050 MJS
4.3-4.5 Byelaws Does the organisation
have powers to make
Byelaws, are these
published?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities and
therefore do not have powers to issue byelaws
as SHAs.   
n/a MJS  
Date of last byelaw
review?
Not applicable – no issued Byelaws.    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?
Not applicable – the Pier Master does not have
powers to issue Directions.     
n/a MJS
4.8  General
Directions
Are the powers of
General Directions
available to the
Harbour?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities and
therefore do not have powers to issue General
Directions.   
n/a MJS  
When were General
Directions last reviewed?
Not applicable – no issued General Directions.      n/a MJS
4.9 Harbour
Directions
Are Harbour Directions
used and published?
Not applicable – no issued Harbour Directions.      n/a MJS
4.10
GtGP 6.4
Dangerous
Vessels
Does the MSMS (or
other plan) make
provision for giving
directions to dangerous
vessels?
Satisfactory – the Pier Master can stop a
dangerous vessel from using the A&BC owned
facility (as the representative of the asset owner)
but is not able to use powers under the
Dangerous Vessels Act 1985.   
Observation – information relating to the
expected action for the Pier 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.  
n/a MJS

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ABPmer, November 2021, R.3730 | 25
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
Cont.
4.10
GtGP 6.4
Cont.
Dangerous
Vessels
Is the role of the
Secretary of State’s
Representative (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?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.
n/a MJS
Is vessel traffic
monitoring information
passed to the MCA by
the quickest means?
Not applicable – the piers are not used by any
vessels requiring CERS reporting.
n/a MJS
Has the need for
VTS/LPS been reviewed
recently?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities.
n/a 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.
Observation – there is no specific instruction on
the actions to take if a professional mariner is
suspected of a drink or drugs offence when on
duty.
Recommendation – the creation of a
procedure to inform the Authority’s officers of
their expected action for a drink or drugs
offence under the RATSA 2003.
MJS_001 MJS
4.11
GtGP 9.0
Pilotage Is the port a CHA? Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
Has the requirement for
pilotage been reviewed?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS

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PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
4.12
GtGP 9.4
Pilotage
Directions
Are Pilotage Directions
issued?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
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 to 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 international
regulations on the
training and certification
for pilots from IMO
resolution A960?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
GtGP 9.5.43 Pilotage Does the authority
operate an effective Pilot
Fatigue Management
System?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
4.15-4.16
GtGP 9.5
Pilot
Exemption
Certificates
Is a clear process for the
issuing of PECs
published?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
Are the requirements
equivalent to those for
an authorised pilot?
Not applicable – the Organisation is not a
Competent Harbour Authority.
n/a MJS
GtGP 8.7.15-
8.8.10
Port Passage
Plan
Is there a published
passage plan, or
information allowing
mariners to create a
passage plan?
Satisfactory – both Helensburgh and Kilcreggan
Piers are identified on the Council’s website.
Observation – the webpage for Helensburgh
states that: “Vessels should contact the Harbour
Master in advance to establish availability and
directions on berthing”. The NtM number 01/18
titled ‘Helensburgh Pier Temporary Closure’
informs users the pier is close to vessel traffic.
Observation – the Kilcreggan Pier webpage links
a third party ‘UK Ports and Harbours’ page which
has out of date contact information:
http://www.ports.org.uk/port.asp?id=389
Recommendation – updating the webpage
berthing arrangement with information from
NtM 01/18.
Recommendation – a dedicated webpage for
Kilcreggan Pier is created (as used for other
A&BC Ports, Harbour and Piers).
MJS_003
https://www.ar
gyll-
bute.gov.uk/pi
ers-and-
harbours-
argyll-and-
bute
https://www.ar
gyll-
bute.gov.uk/h
elensburgh-
pier
MJS

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ABPmer, November 2021, R.3730 | 27
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
Cont.
GtGP 8.7.15-
8.8.10
Cont.
Port Passage
Plan
Is there a published
passage plan, or
information allowing
mariners to create a
passage plan?
Observation – there is no contact information for
Kilcreggan Pier in the Admiralty List of Radio
Signals (ALRS) volume 6. As the pier is
permanently staffed, providing contact
information would be advantageous.
Recommendation – contacting UKHO to
request inclusion of Kilcreggan Pier contact
details into ALRS Volume 6.
MJS_003 MJS
GtGP 8.10 Recreational
navigation
Are recreational users of
the harbour considered?
Not applicable – not considered relevant at this
time. Helensburgh is not in use for vessel
berthing and Kilcreggan Pier is a dedicated ferry
berth.
n/a MJS
4.17-4.20 Collecting
Dues
Are dues clearly defined? Satisfactory – A&BC publish a ‘Rates on vessels’.
The process for setting charges uses a
benchmarking exercise with other local ports.
Charges are increased at the rate of inflation.
Observation – the ‘Rates on vessels’ covers all of
A&BC’s marine facilities (both statutory and
non-statutory). Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities,
powers to charge dues are not available. A
charge to use the marine facilities is expected,
however the term ‘dues’ is inaccurate. Note 2 of
the port-and-harbours-rates page’ states that:
“All vessels are liable for dues at the Basic Rate”.
Recommendation – that wording is revised on
the webpage to ensure that ‘dues’, as a
charge, is not inaccurately stated.
https://www.ar
gyll-
bute.gov.uk/p
orts-and-
harbours-
vessels/ports-
and-harbours-
rates-vessels
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:
 Helensburgh Pier has 2 fixed green vertical
aids (Category 3).
 Kilcreggan Pier has no formal navigation aids.
Checking of the AtoN forms part of the pier
asset inspection regime.
Observation – there are no formal AtoN on
Kilcreggan Pier.
Recommendation – the need for Aids to
Navigation to mark Kilcreggan Pier should be
reviewed.
MJS_045 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 as:
 Cat 2 = 99.6% (target is 99%)
 Cat 3 = 100% (target is 97%)
MJS_044 MJS

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PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
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 and with respect to
marking of wrecks. These is no history of
wrecks, derelict, or abandoned vessels in the
harbour.
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
GtGP 9.4.17-
9.4.21
Pilot Launches Do pilot boats meet
statutory requirements
and appropriate Codes?
Not applicable – Helensburgh and Kilcreggan
Piers are not Competent Harbour Authorities
and therefore has no requirement to operate a
pilot boat.
n/a MJS
GtGP 10.0 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
using the piers.
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 Kilcreggan Pier
Inspection on 31 July 2018 evidenced.
MJS_001
MJS_004
MJS_005
MJS
GtGP 10.4 Diving
Operations
(recreational)
Is there a process for
managing recreational
diving?
Not applicable – Helensburgh and Kilcreggan
Piers are not Statutory Harbour Authorities,
therefore control of recreational diving cannot
be exercised.
n/a MJS

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ABPmer, November 2021, R.3730 | 29
PMSC / GtGP
Reference Subject Evidence Required
For Compliance Evidence of Compliance Recommendations Evidence
Reference Auditor
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”. As hot works are not
carried out at Helensburgh or Kilcreggan, there
is no history of using the ‘Hot Work Permit’.
MJS_001 MJS
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 Pier
Master stated that bunkering does not occur at
Kilcreggan.
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. Any works are associated with A&BC
contracted services and would be pre-notified to
the Pier Master (anecdotal information).
anecdotal
information
MJS

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ABPmer, November 2021, R.3730 | 30
B Quayside and Mooring
Visual inspection of Helensburgh Pier and Kilcreggan Pier. Both inspections included the layout of the piers, their berthing, mooring and life-saving appliances
provide. The pier inspections were undertaken on Wednesday 22 September 2021.
B.1 Quayside Observations: Helensburgh Pier and Slipways
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 – access to the slipways was clear of
debris and obstructions. One slipway was adjacent
to civil engineering works, meaning that its access
was temporarily unavailable. The Pier area was
clear of debris and obstructions and arranged as a
pedestrian walkway.
MJS
Disabled access for passengers
or leisure users?
Satisfactory – pedestrian access is self-managed.
Metal access steps from the sea had been removed
to prevent use. Pier head access steps were behind
a barrier to prevent use.
Observation – the pier is closed to marine traffic, a
Notice to Mariner to this effect has been issued;
however, there are no signs apparent to seaward
that would convey this message.
Recommendation – the installation of a sign,
positioned to inform vessel Masters and crew
approaching from seaward, that the pier is closed
to marine traffic.
MJS
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the pier decking is appropriate for
pedestrian use. Grill decking has been fitted to
allow wave penetration and dissipation of wave
energy at the seaward end of the pier.
MJS
ACOP 211-223
SIP 014
Rescue and
Lifesaving
equipment (LSE) at
the water’s edge
Is there appropriate means of
egress from the water?
Satisfactory – the slipway has stone steps; the pier
head has water access ladders with hand grabs
fitted.
MJS
Is there appropriate LSE at
quay edge?
Satisfactory – the pier has lifebelts and recovery
ropes fitted. All life rings were in place at the time
of inspection (one life ring had been recently re-
fitted).
MJS

Page 36

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ABPmer, November 2021, R.3730 | 31
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 – mooring bollards are provided along
the edge of the pier, and around the pier head.
The pier is no longer used for vessel mooring.
Observation – should the pier be used for mooring
in the future, the bollards should be inspected,
painted, numbered and their SWL ascertained. See
image B1.
Recommendation – if the pier is used for
mooring in the future, mooring fixtures must be
inspected and maintained.
MJS
Are the bollards numbered? Not applicable – Helensburgh pier is not used by
vessel traffic, bollards not in use.
MJS
Are the bollards labelled with a
Safe Working Load (SWL)?
Not applicable – Helensburgh pier is not used by
vessel traffic, bollards not in use.
MJS
Are the bollards appropriate to
the vessel being handled?
Not applicable – Helensburgh pier is not used by
vessel traffic, bollards not in use.
MJS
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – wooden vertical fendering sections
are installed on the jetty head.
MJS
Is the condition of the
fendering in good order?
Satisfactory – wooden vertical fendering appeared
to be in good condition.
MJS
Are chaffing plates used on
the Pier edge?
Satisfactory – wooden pier edge timber is used as a
base to fix the pedestrian railings.
MJS
ACOP 232-235
SIP 005
SIP 014
Lighting Is lighting appropriate and
appear to be in compliance
with ACOP ‘safety in docks’
and the PFSP?
Satisfactory – lighting installed along the length of
the pier and appeared adequate for the intended
purposes.
MJS
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – a full length of the pier, including the
pier head is pedestrianised.
MJS
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – signage provided along the pier. MJS

Page 37

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ABPmer, November 2021, R.3730  | 32  
Image B1. Helensburgh Pier, mooring bollard Image B2. Helensburgh Pier, derelict decking section

Page 38

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ABPmer, November 2021, R.3730 | 33
B.2 Quayside Observations: Kilcreggan Pier
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
PMSC 3.0
GtGP 8.11.19
ACOP 207-208
SIP 014
Access Is the quayside and its access
locations clear of debris and
obstructions?
Satisfactory – access to the pier was clear, walkways
were segregated (access and egress) with clear
pedestrian information and fenced areas.
MJS
Disabled access for passengers
or leisure users?
Satisfactory – the pier provides for disabled access
along its length. Pier Operatives assist passenger
boarding.
MJS
Is the type and condition of
quayside surface appropriate
to the operation?
Satisfactory – the pier surface and condition appear
in good order. The Pier Operative provided clear
and timely instructions to passengers regarding
embarkation and disembarkation from the ferry.
MJS
ACOP 211-223
SIP 014
Rescue and
Lifesaving
equipment (LSE) at
the water’s edge
Is there appropriate means of
egress from the water?
Satisfactory – the pier had an access ladder at the
pier head which is fitted with grab handle holds.
MJS
Is there appropriate LSE at
quay edge?
Satisfactory – the pier had lifesaving equipment
along its length.
MJS
SIP 005 Bollards and
securing
equipment
Does the general condition of
bollards appear to be in good
order?
Satisfactory – mooring points used by the ferry
were observed to be the upright pier supports
(designed for this purpose) plus stag-horn bollards
which were noted to be in good condition.
MJS
Are the bollards numbered? Satisfactory – mooring points are not numbered;
this is not considered necessary given the size of
the pier and the typical mooring configuration
used.
MJS
Are the bollards labelled with a
SWL?
Satisfactory – mooring staghorns have information
plates with SWL shown.
MJS
Are the bollards appropriate to
the vessel being handled?
Satisfactory – mooring bollards and pier upright
supports are considered, in the opinion of the
auditor, to be more than adequate for the size of
vessel being handled.
MJS
SIP 005 Fenders Is the fendering appropriate to
the vessel being handled?
Satisfactory – fendering is fitted to the pier outer-
face upright supports, two rubber D-Section on
each fender pile at the head of the pier.
MJS
Is the condition of the
fendering in good order?
Satisfactory – fendering appeared to be in very
good condition. Replacements were made
following the PS Waverley incident in 2021.
MJS
Are chaffing plates used on
the Pier edge?
Satisfactory – wooden pier capping fitted around
the perimeter of the berthing face.
MJS

Page 39

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ABPmer, November 2021, R.3730  | 34
Reference Subject Evidence Required 
For Compliance Observation Recommendations Auditor
ACOP 232-235
SIP 005
SIP 014
Lighting Is lighting appropriate and
appear to be in compliance
with ACOP ‘safety in docks’
and the PFSP?  
Satisfactory – ample lighting installed, with points
along the pier.   
MJS
ACOP 58-60 Layout Is adequate separation
delineated between quayside
operations?
Satisfactory – pedestrians wait at the dedicated pier
building making the distance to the boarding point
as short as possible.  The pier buildings have been
newly refurbished.  The layout and maintenance of
the Kilcreggan Pier is considered to be an area of
best practice.   
MJS
ACOP 82 Signage Is appropriate signs and
markings provided
Satisfactory – pier signage evident at the root of
the pier prohibiting vehicle access, fishing and
cycling.   
MJS

Page 40

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ABPmer, November 2021, R.3730 | 35
B.3 Mooring Operations
Observation of procedures, equipment and Personal Protective Equipment (PPE) for the mooring and unmooring of the Motor Vessel (MV) Chieftain during the
period of 15:00 to 16:00 hr on Wednesday 22 September 2021.
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
GtGP 10.6.1
ACOP 42
SIP 005
Communication Is there direct communication
between ship and shore
personnel?
Satisfactory – vessel Master observed the Pier
Operative and instructed the deck hand to provide
lines ashore.
MJS
Is communication controlled
via a supervisor?
Satisfactory – vessel Master provides instruction
and direction to the crew.
MJS
Is there adequate
communication with mooring
launch?
Not applicable – mooring launch not used. MJS
Are hand signals used and
appropriate?
Not applicable – no shore signals observed. MJS
GtGP 11.7
SIP 005
Planning Toolbox talk or equivalent
conducted?
Not applicable – not observed at time of visit. MJS
Are mooring personnel ready
by an appropriate time?
Satisfactory – shore personnel were present in
ample time to take the vessel’s lines.
MJS
Is the mooring operation
planned?
Satisfactory – Pier Operative takes the vessel’s lines
on a well-practiced routine.
MJS
Is the mooring pattern
appropriate to the quay/vessel
and weather conditions?
Satisfactory – the mooring pattern, in the opinion
of the auditor, is appropriate to the vessel and the
berth.
MJS
GtGP 10.6
SIP 005
Use of other craft Do tugs remain clear of
mooring lines?
Not applicable – no tugs used. MJS
Is a mooring launched used? Not applicable – mooring launch not used. MJS
SIP 005 Self-mooring Does the vessel self-moor? Satisfactory – Pier Operative (ashore) takes the
vessel’s lines, self-mooring is not used.
MJS
SIP 005 Line handling Are mooring lines kept clear of
fenders?
Satisfactory – Pier Operative places lines on the
upright pier supports, fendering is not fouled. At
mid to low tide, a lower embarkation point is
available. The observation was carried out at high
water and did not observe lower tidal states.
MJS
Do mooring personnel appear
to be aware of snap-back
zones?
Satisfactory – Pier Operative (ashore) stood in an
appropriate location to take and handle lines.
MJS
Do mooring personnel avoid
stepping over lines or standing
between lines and quay edge?
Not applicable – not relevant given the mooring
pattern.
MJS

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021 Argyll and Bute Council
ABPmer, November 2021, R.3730 | 36
Reference Subject Evidence Required
For Compliance Observation Recommendations Auditor
Cont.
SIP 005
Cont.
Line handling
Are multiple lines ‘dipped’ on
bollards?
Not applicable – not observed. MJS
Are messenger lines thrown
appropriately?
Satisfactory – messenger lines were thrown in a
considered manner by the vessel’s crew.
MJS
Are mooring personnel
‘backed-up’ on heavy lines?
Not applicable – not observed. MJS
Do mooring personnel release
heavy lines appropriately?
Not applicable – not observed. MJS
Mooring personnel using
appropriate handling?
Not applicable – not observed. MJS
Are heaving lines weighted? Satisfactory – appropriate heaving line seen (i.e.,
not dangerously weighted).
MJS
SIP 005 Use of equipment Is the SWL of bollards
appropriate to the load being
placed on?
Satisfactory – mooring points are appropriate for
use by the vessel seen.
MJS
Are mooring lines used at an
appropriate angle for the
infrastructure?
Satisfactory – the mooring pattern for the vessel
alongside the pier was appropriate.
MJS
Are mooring lines maintained
at an appropriate length
throughout the operation?
Satisfactory – the mooring line length was
appropriate for the vessel, the MV Chieftain did not
stay alongside the pier for very long, due to the
wave conditions on the day.
MJS
ACOP 58-67
SIP 014
Operational
control
Is there concurrent activity
alongside the mooring
operation?
Not applicable – there is no concurrent activity
(single user berth).
MJS
Are non-mooring personnel
kept separate from the
operation?
Satisfactory – areas of activity between the Pier
Operative, CFL vessel crew and pedestrians
maintained with an appropriate degree of
separation.
MJS

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Port Marine Safety Code - Audit: Helensburgh & Kilcreggan Piers 2021    Argyll and Bute Council
ABPmer, November 2021, R.3730  | 37
Reference Subject Evidence Required 
For Compliance Observation Recommendations Auditor
GtGP 11.4
SIP 005
Personnel and
equipment
Are mooring personnel
wearing appropriate PPE?
Satisfactory – all personnel observed working along
the quay were wearing appropriate PPE, including
safety footwear, buoyancy waist coat, high visibility
(hi-viz) jacket and trousers.  In addition, foul
weather gear and an auto inflation lifejacket were
available to pier staff.   
Observation – during mooring operations head
protection was not observed, with heaving lines
thrown to the pier, this activity should be subject to
a risk assessment.   
Recommendation – the risk assessment for Pier
Operative mooring operations is reviewed to
consider if any additional PPE is required.  
MJS
Cont. 
GtGP 11.4
SIP 005
Cont. 
Personnel and
equipment
Are shore side mooring lines
in good condition?
Not applicable – lines deployed at the pier were
vessel’s own lines.     
MJS  
Is adequate manning provided
for the handling of lines and
means of access?
Satisfactory – manning levels for mooring and
passenger management is adequate. 
MJS
Is any additional mooring
equipment used appropriate
and in good working order?
Satisfactory – all mooring equipment observed was
in good working order and well maintained. 
MJS

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