Hi Hugh,I understand more clearly now where you are headed with this. There are two reasonable courses of action that I think we could take to address this issue which we should probably discuss and decide first, before talking about details since the details will likely change depending upon the course we choose. The first would be to work with one or more certifying agencies (and at this point I don' t think it matters which one) to see if we could get a "class" of vessel defined for home-builts. The second would be to form our own "in-house" classification (self-regulating) based upon some criteria and try to "sell" that to various entities such as insurance companies, marine inspectors, etc. I think either course may be a tough sell, but that shouldn't stop us from trying if the group thinks it is worthy. Are there any other options (besides doing nothing)?
You mentioned at the end of your email, the 30 inch freeboard requirement to the hatch and how many do not implement this, but still operate their sub safely. After the 2010 ABS changes came out, I questioned some of their newest rules (do one man subs really need a hatch closed indicator?) and although I was a proponent of bringing all the sub standards into one section (it use to be spread out all over the place) I was surprised to see that Section 11 of Rules for Underwater Vehicles was inclusive of "passenger submersibles", which use to also be a separate section and in my opinion still should be. This subtle change means that ALL subs now must meet many of the requirements that use to affect only passenger subs even if we have no intention of carrying passengers. The cynical side of me interpreted this as the possible beginning of a strategy to curtail, or rope in, p-subs type vessels given that our group is continuing to expand and get visibility. I decided to approach ABS to suggest that we start a dialog to determine how PSUBS could interact with ABS in a constructive manner to participate in the assessment of and evaluation of future rule changes that might affect our vessels. On 1/15/2010 at 1:36pm, I wrote Luiz Feijo at ABS and asked for a contact in regards to the Underwater Vessel Rules. Luiz wrote me back at 5:42pm on the same day providing me the name of Charles Dunlap and giving me his email address. On 1/24/2010, I wrote Charles Dunlap explaining our group, giving him some history of the group, and asked him how we could participate with ABS as I described above. I never received a reply from Mr. Dunlap, so I wrote back to Luiz Feijo on 2/2/2010 and explained that I had written to Dunlap as he had suggested but received no reply. I included the email that I sent to Dunlap and then asked Feijo if Dunlap might be on vacation or not receiving email, and whether there was someone else we could contact. I never received a reply from Feijo. I'm a firm believer that a non-response to an email is a statement and I found it interesting that in the first case Luiz Feijo responded to me the same day, but in the second case he never responded at all. Based upon that experience, I'm pretty sure that ABS is not interested in talking to us even though they do talk to MTSMUV. I would love to be wrong in my assessment, but my gut feeling is that there are people who are subtly working against us because we are either a threat to some existing entity, or we are still perceived as "weekend warriors" with little discipline who represent a risk to the industry. I had planned to talk about this (and still do...it's part of my slide set) at our member business meeting in July. That brings us to self-regulation and self-classing. At the 2008 convention in Maine, the members at our business meeting determined that self-classing would be a good idea if not just for our own use and purposes. The justification at that time was described similarly as you did in your email, primarily a potential incident with a Mr. Pilipenko type member and submersible and how to avoid becoming entangled in such an incident. We set up a committee and left Maine believing that we were onto something good that was going to push us forward light-years. Within a month the committee disbanded because a majority of the members believed their participation in it would cause them to be legally liable for various potential law suits that might stem from "classing" someone elses submersible. At that time we were talking about classing vessels based upon how close they were built and operated according to ABS standards. At "Class A" vessel was ABS certified, but we didn't expect to have any of these. A "Class B" vessel was one that COULD be certified if the owner had the desire to spend the money for a certification, meaning it met all ABS guidelines but just didn't have a piece of paper saying so. A "Class C" vessel did not meet enough ABS guidelines to be certified, but the owner could demonstrate with enough confidence to the committee that it was safe for the diving parameters it was designed for. A "Class D" vessel was deficient in enough ABS guidelines that it should be restricted in its operations. A "Class E" vessel was experimental (fiberglass, concrete, etc). The primary purpose for the classification was to have some control over PSUBS sponsored diving operations to avoid any incidents with submersibles that might not quite be up to par. Theoretically, a Class-D vessel would be easier to spot and might not be permitted to dive at a PSUBS sponsored event. I was disappointed that this (or some other classification definition) never materialized because I think it would have helped to facilitate better fabrication through competitive pressure. Theoretically at least, nobody wants to be the only owner of a "Class D" vessel and would work towards bringing it up to a higher classification. Better for them, and better for the organization. I do plan on broaching this topic again, possibly in time for the July meeting.
We should define the pros/cons of each approach. Jon Hugh Fulton wrote:
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 pressurevessels.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 $5000p.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 haveonly 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
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