Re: [PSUBS-MAILIST] prepare for congressional intervention

[Jon Wallace <jonw@psubs.org>]

Because the ABS (GL, Lloyds, etc) standards are so widely known and 
accepted by industry and regulators, I'm having a hard time imagining a 
situation in which we would be criticized for following such standards 
except what I've seen on this list by people who believe they can do as 
well without them.  However, we do have our own standards and guidelines 
already which were originally intended to be all encompassing as you are 
suggesting here, but evolved into being an "addendum" that incorporates 
content specific to recreational submersibles that is important to us 
but not specifically covered by industry standards.

Main Menu -> Resources & References -> Standards & Guidelines -> PSUBS 
Guidelines
http://www.psubs.org/guidelines/PSUBS/
Here you will find Design Guidelines for Personal Submersibles, 
Construction Guidelines for Personal Submersibles, and Operating 
Guidelines for Personal Submersibles.  You will also find logs of RFC's 
submitted to add, modify, delete these rules as well as when the rules 
were adopted.  Also note there is a form for psubbers to submit 
proposals for changes to any of the documents.  You probably remember 
earlier this year that we adopted a specific SUBCONN electrical 
connector as a "standard" for psubs.  That proposal went through this 
RFC process in which we create the RFC and send it out to PSUBS members, 
and then define a time period (usually 30 days) for comments from our 
members.  Any changes are incorporated into the final draft which is 
then voted upon by the membership.  This process provides structure and 
guarantees that all members can suggest changes, have input to a 
proposal that may affect them philosophically or financially (if 
equipment is required), and also has a "vote" on a proposal.

The original rules were carved most from US Coast Guard requirements and 
federal law since there was no reason to duplicate existing content in 
publicly available documents by any of the certifying agencies.  You 
will see from the log entries that only three rather innocuous changes 
have been submitted since 2007, which I think would tend to support the 
argument that most of us are not "rule hungry tyrants" (my own 
words...nobody has called us that...yet) or paranoid about congressional 
intervention.  I believe most of them are just common sense things that 
are not unreasonably restrictive.

Jon



Jens Laland wrote:
> My proposal is that we continue making our own documents.
>
> In doing so we could include (cut and paste) sections and paragraphs from
> third part documents.
>
> We should also consider to modify such sections and paragraphs as we see
> fit to better suit our own type of vessels and operations.
>
> Then, at least we will have some documentation of our own to show the
> authorities when the said next-event comes.
>   



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