Until the publication of Division 238, vessels assigned to port or coastal missions were governed by Division 222, a text mainly oriented towards cargo vessels. This regulatory mismatch posed major constraints for operators of small service vessels. Division 238 now offers a lighter framework, better adapted to the realities of the field.
A clearly defined perimeter for NAC vessels
Division 238 applies to Coastal Service Vessels (CSVs), i.e. vessels of less than twenty-four meters in length, carrying out specific missions in coastal areas: harbor work, assistance to pleasure craft, buoy tending, surveillance or short-distance shuttles.
It distinguishes between several types of navigation (sheltered, coastal, semi-offshore) and adapts regulatory requirements according to the area of operation. This modular approach facilitates the integration of a wide variety of vessels under a single regulatory umbrella.
Simplified design and reduced technical requirements
Division 238 simplifies construction rules for Category A and B vessels, notably in terms of stability, watertightness and subdivision. It is partly based on the standards for small pleasure craft, but with specific requirements for professional use.
The reduction in weight also applies to electrical installations and motorization, with tolerances adapted to the power installed, while maintaining a level of safety in line with international standards.
Crew safety and operations management
The new division imposes equipment standards directly related to the number of people on board, the duration of missions, and the distance from the coast. Vests, means of communication, distress beacons and fire-fighting equipment are specified according to simple grids.
It also clarifies the operator's responsibilities, introduces the obligation of training adapted to the navigation zone, and requires operational documentation, including a risk prevention plan and a simplified logbook.
A response to the needs expressed by marinas
This regulatory change has been eagerly awaited for several years by port managers and operators of small multi-purpose vessels. The vessels concerned are often locally-built, and are used to maintain port facilities or accompany leisure boating.
Division 238 finally offers them specific legal recognition, easing constraints while giving operators a sense of responsibility. It is a lever for structuring coastal services, while guaranteeing a minimum level of safety.
Gradual implementation and support
The text provides for a staggered entry into force, with transitional provisions for existing vessels. Operators must adapt their fleets to the new classes defined, and integrate the requirements into their internal procedures.
Professionals are advised to contact the ship safety centers (CSN) to check compliance and, if necessary, take steps to regularize the situation. An application guide is expected in the coming months to make the text easier to read.
Division 238 fills a regulatory void and lays the foundations for a better-regulated professional maritime practice in coastal areas. Its success will depend on how widely it is disseminated, on the support offered to small structures, and on the extent to which it is adopted by all coastal users. It remains to be seen how this reform will influence the future construction of harbor service vessels in France.
