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

2010/6/7 Hugh Fulton <hc.fulton@gmail.com>

Hi Jon,
I have looked at the Lloyds rules and they more or less say that if you have
designed to some code approved in a country and can produce material certs
that are responsible then they are prepared to accept those as opposed to
ABS who say thou shalt only have ABS approved materials and ABS design code.
I may be talking out of school here a little but in essence there is a
difference in approach. However Lloyds would have nothing to do with me as
they said they would only get involved in Defence vessels or in Offshore
vessels such as oil rigs. I would hazard a guess, standing to be corrected
by Phil, that he has found that Lloyds would have been easier to meet in the
early days than ABS. I would be interested in his comments on comparison of
the different agencies.

Getting back to acceptance. First of all who is policing the rules? Not
ABS or the likes. It is the insurance companies, coastguard, police and
Maritime agencies. Therefore our aim should be to pacify and ingratiate
ourselves with them. IN this country you cannot head offshore without
getting a classification of seaworthiness. Cat 3 for local, Cat 2 for
coastal, Cat 1 for offshore and Cat 0 for Worldwide racing. You can ring up
the Yachting association and get an inspector to Class your boat. You have
to have G-Z acceptable and minimum safety devices suitable for each
classification. Current electricians certificate of compliance etc. All we
want are two classifications not 4. The yacht or launch surveys are for a
period of time and the value of a boat / vessel is often determined by
whether it is in survey or not and what survey it is meeting. Most sales of
vessel are subject to a surveyors report. They have reached a level of
sophistication with their industry that the insurance is dependant on the
classification and survey as it should be. ASME have differing joint
efficiencies based on whether the weld is not x-rayed, 10% X-rayed or 100%
x-rayed. We could propose a similar basis as it already exists for pressure
vessels.

Aeroplanes can get experimental status. Microlights can be sold commercially
which don't have to meet full FAA rules. I built and flew my own build of
hang glider many years ago but when I went to fly at a club's field they
wanted me to meet their basic inspection. ( I failed ) When I wanted to Race
my car on a circuit it had to pass scrutineering. ( I passed) The motor
industry have their own scrutineering standards and those with enough
experience are qualified to do it. The same goes for us. It is all very
well to chase a number of people to get them to bring their subs to a
convention but I think it is time to have scrutineering in place. Imagine
Mr Pilipenko ( got bless his cotton pickin socks) bringing his sub along
because he had paid his dues and then we lost him. We would never hold our
heads up again. We could get Vance ( again bless his cotton pickin' socks)
as our first scrutineer. (Sorry Vance) But you get the idea.

It would be very hard to determine the boundaries as to make it for vessels
for 3 persons and under would bring criticism from some quarters but they
still have the option of ABS etc. The line would have to be drawn somewhere
but it needs discussion and perhaps this is where the members only thread
could be taken up so it does not clog the site. It is a mammoth undertaking
but it is something that I am working on to get approval of craft in New
Zealand that are not prohibited by ABS +A1 Classification. ABS is a lot
easier in USA than it would be here in the sticks. I used to be on a
standards committee for compressors in NZ so I don't see it as
insurmountable. Insurance companies are not stupid and would listen. I can
get the Comsub without any classification and no survey insured for $5000
p.a. with a $20k excess.

The argument of if you want to make money you have only one choice does not
wash with Launches and Yachts. The survey requirements are less than ABS
but are responsible. However they put a lot more onus on the skipper and
his training and qualifications. Divers are able to take paying people out
for commercial tours etc. They are self regulating. As I said before we
are going to be regulated more than less and we have a way of influencing it
by leading from example. If we do this the industry will mature. If we
don't we will always be regarded as risk taking amateurs. An aeroplane which
has been certified or is a microlight is very dependant on the skill of the
pilot. Microlights are even more prone to turbulence than heavier craft.
There are many parallels and we should, in my view, look seriously at them.
P-subs is getting more sophisticated from what I can see even though I have
only been associated for a relatively short time.

ABS, and others are more Accounting historians than leading edge design
advisors. When a new design has been proven and there are rules made to
explain why the new technologies are safe then the ABS, Lloyds etc of the
world will adopt the new designs and make rules for them. Work in Progress.
One of the basic rules of ABS is the 30" to freeboard from the hatch. Not
many meet this but are still safe. Enough of me rabitting on. Over to you.

Chs, Hugh

-----Original Message-----
From: owner-personal_submersibles@psubs.org

[mailto:owner-personal_submersibles@psubs.org] On Behalf Of Jon Wallace
Sent: Monday, 7 June 2010 7:04 p.m.
To: personal_submersibles@psubs.org

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

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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