Re: [PSUBS-MAILIST] submarine kit-builder's society rules

[Jon Wallace <jonw@psubs.org>]

Hi Hugh,

Lots of good points in your email and worthy of much discussion.

1) Police Ourselves.
I think you are correct regarding defending ourselves against regulation 
by policing ourselves. I know there are many others who agree with this 
philosophy as well because it gets brought up at every convention. We've 
begun policing ourselves by recommending people build as closely to ABS 
rules as possible, not for certification purposes as we all know the 
cost is too high for home-builders, but because those guidelines 
represent a good set of rules for fabrication and operation. If the 
guidelines are followed closely enough, it *could* be said that the only 
difference between your sub uncertified, and your sub certified, is a 
piece of paper. We also have our own set of standards and guidelines for 
things that apply specifically to the home-built recreational market but 
are not covered by ABS. This seems like a reasonable place to start 
policing ourselves and I think is minimally invasive in terms of 
"freedom". There will always be people who don't want anyone to tell 
them what to do, and frankly those people need to go ahead and do their 
own thing alone. You bring up a good analogy with SCUBA and I'm sure I 
don't have to detail the similarities between that and our submarines.

2) P-subs Survey/Certificate.
I'd have to know more about why we would want our small subs certified, 
and also what the "less expensive" certification would be based upon. I 
certainly understand the reasoning from a safety perspective, however 
for any other reason related to recreational use I'd be more inclined to 
adopt the philosophy of policing ourselves and fight any projected 
regulation that way. For commercial purposes involving passengers I'm 
not sure how we would differentiate a home-built sub from any other 
commercial sub. The logical method would seem to be design depth of the 
vessel but I'm not sure that would stand up to scrutiny. In a 
multi-person submersible, a passenger probably has an equal chance of 
being killed in a catastrophic failure at 100 feet as they do at 1000 
feet. I suspect we would run up against a very black/white argument by 
those who care about these things (CG, insurance companies) which be 
something on the order of; "If you want to use your sub to make money 
with passengers, get it certified the regular way. If you can't make 
enough money to pay for that certification and also make a profit, then 
you are going into the wrong business." If anything, I would expect they 
would want to put more stringent requirements on a unique home-built 
vessel rather than one fabricated by a company employing people who have 
experience making many subs.

A "less expensive" certification for doing commercial work WITHOUT any 
passengers I think is much more justifiable.

3) Licensing.
We could come up with our own licensing scheme, again policing 
ourselves. However, nothing like this will ever take effect without some 
dedicated people putting alot of time and effort into it. It can't be 
arbitrary or capricious, and it will have to be well thought out to get 
people to buy into it. Attempting at such an implementation and failing 
to carry through with it will be more costly than doing nothing to begin 
with.

I'm for anything that will make our group stronger and project upon us 
positively in the eyes of regulatory authorities and our own industry 
partners. Your proposal comes at a good time since we can talk about 
this formally and informally in July when we meet in Florida.

Jon



Hugh Fulton wrote:
> Wil et all,
>
> The trouble is that I think that we will be fighting a losing battle. 
> I think that we are similar to, but way behind, the aircraft industry. 
> We are in the “microlight division”. No need for regulation but I 
> think to defend it we are going to have to police it ourselves long 
> term. We should be aiming for a P-Subs license and getting support 
> from the Coastguard and Maritime services from various countries. When 
> I first started sCUBA in the 60’s we were all self taught, made our 
> own etc. I went to Europe and could not get a tank filled without a 
> ticket and came back home and first thing I did was get a basic SCUBA 
> ticket.
>
> I think that we are headed that way. We can fight it or we can show 
> responsibility and get a “microlight sub” classification. I believe 
> that Yacht / boat builders can get a design done and get their boats 
> surveyed without having to have it done by Lloyds, ABS etc. I think if 
> we adopt that as an attitude and we can get new designs, concepts etc 
> whether the “f---“ word the “C—“ word or in conventional steel etc we 
> might just get a viable game plan listened to. I think this is a 
> fairly good road for P-Subs to go down and develop and has merit. Why 
> have to follow the same rules and costs as a Ship or airliner which is 
> where the big rule boys come from. I think that if we put together a 
> set of rules and approached one of the approval bodies, just one of 
> them might see reason to reduce their costs for a lesser approval and 
> support us. If I were in charge of their marketing and new business I 
> would certainly sit up and listen.
>
> My proposal would be to have a set of calcs that can be followed or a 
> minimum FEA programme that can be used for unusual shapes. Perhaps if 
> it is an unusual design then a couple of tests of models supported by 
> a full pressure test. If a registered engineer did the calcs or signed 
> them off we could get a rating like they rate countries A+, AA+, A-, 
> BB whatever. The emphasis needs to be on proving the design by 
> pressure test. If we set a 1.5 times test instead of the 1.25 and 1.3 
> with an inspection afterwards supported by weld X-rays then shouldn’t 
> that be recognized? So what do you gurus think. We need to get it so 
> it does not cost a bundle but gets some recognition, and show that we 
> are a responsible group. The biggest concern is liability and I know 
> that engineers are notorious nowdays for diving for cover.
>
> So am I gooing to get shouted down or have you older members already 
> shelved that idea?
>
> Hugh




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