On March 20, 2023, Transport Canada launched an online consultation on the proposed requirements for engine cut-off switches (ECOS) on small vessels.
On this page
Our proposal
To increase boater safety and align Canadian requirements with the U.S., Transport Canada may introduce requirements so that engine cut-off switches are installed on new vessels that:
- are less than 8 metres (26 feet)
- have an engine or engines that can produce at least 511 Newtons (115 pounds of force) of static thrust or 2.2 kilowatts (3 horsepower) of power in total, and
- have a primary helm station that isn’t in an enclosed cabin
We may also require operators to link themselves to an engine cut-off switch if their vessel fits the description above and already has an ECOS.
Methodology
As part of the consultation, stakeholders were asked the following questions:
- Do you agree with the proposed requirements for installing ECOS on new vessels, as described in the proposal?
- Do you agree with the proposal to require operators to link themselves to an ECOS if their vessel has one?
Stakeholders were also invited to provide written feedback on the proposed requirements through TC’s Let’s Talk portal or via email.
What we heard
Survey responses
In total, 341 people participated in the survey. Results from the survey indicated that:
- 69% of participants agreed with the proposed requirement for installing an ECOS
- 50% of participants agreed with the proposed requirement for operators to link themselves to the ECOS if their vessel has one
Let’s Talk Transportation feedback
In total, 96 people provided written feedback through the Let’s Talk portal and via email. The feedback is summarized below.
Support for the requirements
Around one-quarter of respondents fully supported the proposed requirements, noting that the requirements were common sense, and with some suggesting that they should be implemented on all pleasure craft, regardless of size. Respondents also noted that the requirements are needed to:
- mitigate risks with high-speed crafts
- help determine responsibility in accidents, and
- prevent injuries and save lives
Some supporters indicated that the requirements should only apply to new vessels. One respondent expressed concern that future requirements could be stricter and apply to older vessels, while another recommended making the requirements as clear and concise as possible. Another respondent was concerned that operators would forget to connect themselves to the ECOS switch.
In addition to ECOS requirements, one respondent suggested that operators should also be required to wear personal flotation devices.
We also saw support from a marine industry group that noted that the proposed requirements would help to harmonize Canadian and U.S. requirements and contribute to safer waters in North America.
Partial support for the requirements
Around half of the respondents partially supported the proposed requirements, but they disagreed with the parameters of the proposed application. This feedback is grouped by theme below.
Vessel length
10 respondents supported the requirements, but proposed that these should apply specifically to vessels ranging from 14 feet to 22 feet (or 4.2 metres to 6.7 metres). These respondents also noted that some vessels pose less risk for falling overboard, like those with a full canvas enclosure, or those that operate at a low horsepower (e.g., 3 horsepower).
2 respondents also noted that wearing a physical lanyard on larger boats is impractical since operators need more freedom of movement.
Vessel type and construction
10 commenters supported the requirements, but believed their application should depend up on the vessel’s type or construction. Some of these respondents noted that the requirements would be impractical for vessels with outboard motors, and that a solution would need to be developed for vessels with a second outboard motor at the stern.
Other respondents noted that there are times where operators need to move around on sailboats while they’re being operated, which would make a physical connection to an ECOS difficult.
1 respondent suggested that requirements be relaxed for vessels where the outboard motor is operated from a cockpit, while another suggested that sailboats with enclosed sides be completely exempt from the requirements.
2 respondents agreed with the requirements, but only for personal watercraft or pleasure craft.
Vessel activity
19 respondents supported the requirements, but believed they shouldn’t apply during certain activities.
11 respondents noted that mandatory tethering to an ECOS would affect a person’s ability to fish, troll, or angle, especially when trying to control a fishing rod and landing net. These respondents noted that, in some cases, the sudden stop of an engine could increase the risk of injury or damage to fishing equipment.
5 respondents noted that TC should consider requiring mandatory tethering to an ECOS when a boat travels above a certain speed, or above a displacement speed.
2 respondents raised concerns about mandatory tethering when performing regular boating activities, like docking, unloading and anchoring. These respondents suggested closer alignment with U.S. requirements, which do not require operators to be attached to the ECOS when the vessel is idling or performing docking maneuvers.
1 respondent suggested that a better approach be developed for when an operator should be tethered to an ECOS.
Mandatory wearing of an ECOS
12 respondents agreed with the proposed requirement to have an ECOS installed on new vessels, but disagreed with the requirement for operators to wear them, noting that at times they can create safety issues or be impractical.
Opposition to the requirements
Around one-quarter of respondents fully opposed the proposed requirements.
8 respondents indicated that the proposed requirements are unnecessary, are an example of government overreach, and are TC’s attempt to collect more money from ticketing.
6 respondents stated that there isn’t enough data to show that there is a safety issue that requires ECOS. They also noted that ECOS could create more safety issues.
6 respondents raised concerns with the Government of Canada’s ability to enforce the requirements, suggesting that it would be difficult for enforcement agencies to verify compliance, and that many operators would simply choose not to follow the requirements. Other respondents indicated that enforcement efforts are already lacking and, as such, these new requirements wouldn’t be properly enforced.
4 respondents opposed the concept of retrofitting vessels, noting that it would be costly, and not feasible for some vessels. However, the proposed updates would only apply to new vessels.
2 respondents opposed the requirements, believing that ECOS technologies can be expensive and unreliable.
Definitions and clarity
A few respondents would like to see clearer definitions for the terms “enclosed helm station”, “lanyard”, “tether”, and “enclosed cabin.”
3 other respondents requested clarity on whether the requirements would allow vessels already in operation to continue without adopting the measures.
Some respondents also wanted clarity on when a tether would be required, or when exactly the requirements would apply (e.g., when the vessel is in operation), and on what vessels (e.g., sailboats with outboard motors, small commercial vessels etc.).
1 respondent also asked whether the requirements would apply depending on a vessel’s factory length, or its length following after-market modifications. Another respondent asked what should be done with vessels equipped with ECOS but that have missing parts that can’t be acquired.
Other comments
We received a few comments suggesting that TC focus on other issues, such as pleasure craft operator competency and requirements for personal flotation devices.
1 respondent noted that education on safe boating could be more beneficial than introducing ECOS.
Next steps
The proposed updates to the Small Vessel Regulations, along with a more detailed description of the updates, are targeting pre-publication in the Canada Gazette, Part I, in spring 2025. Pre-publication will be followed by a 60-day comment period for stakeholders.
The feedback we received from this consultation will inform the development of the proposed updates.
If you wish to be notified of the pre-publication of the proposed updates to the Small Vessel Regulations, please contact cmac-ccmc@tc.gc.ca and ask to be added to the distribution list.
For any other questions or comments on this regulatory proposal, please contact: mssregulations-reglementsssm@tc.gc.ca.