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RE: [PSUBS-MAILIST] submarine kit-builder's society rules
Well, that did bring a few responses as I expected but I think that the
point that Jon has made is that ABS are already moving towards tighter
regulation and have made it clear that they don't want to talk to amateurs.
I am suggesting fighting that move but still using the same engineering
concepts. I did not propose that we come up with a new set of rules but I
proposed using existing rules with a lesser imposition. Those who don't
want to get any classification are still entitled to follow that path. I am
merely saying that if we have a less expensive option than the full monty
ABS then we may find that more people would go for that certificate which I
proposed would be administered by one of the classification agencies. I
gave examples of other sports where there are other options. Just for the
records, I am progressing with ABS and it is very painful. Some seem to
think that I want to abandon the tried and true. Read again. I spent over 9
months writing a manual for Atlas Copco on designing high pressure
reciprocating gas compressors. I do not advocate taking short cuts. If
there is no support, so be it. I believe if we do nothing we will get
gobbled up. Already listening to the threads we have to be careful not to
mention submarines but should only mention water toys. I would like to find
a way that P-Subbers can call their subs what they are without big brother
stomping on us. Kittredge got ABS by showing proof of test without
submitting everything that has to be submitted these days. It would be nice
to have that same recognition. Regards, Hugh.
-----Original Message-----
From: owner-personal_submersibles@psubs.org
[mailto:owner-personal_submersibles@psubs.org] On Behalf Of Jon Wallace
Sent: Tuesday, 8 June 2010 3:11 a.m.
To: personal_submersibles@psubs.org
Subject: Re: [PSUBS-MAILIST] submarine kit-builder's society rules
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
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
>
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