[PSUBS-MAILIST] Submersible Rules

[Jon Wallace via Personal_Submersibles]

Alan, I was a politician for 13 years.  Happy to be out of that venue.

Commercial is a seriously overloaded term confusing without context.  I 
think from a regulatory perspective the origin of a submersible is 
unimportant.  Not that I want to stick a fork in the eye of a dead horse 
(hey, did you ever think we'd get to use THAT phrase again), but from a 
regulatory perspective how do you judge an A1 classed submarine from a 
commercial fabricator against an A1 classed submarine from a home-builder?

Existing law appears to center upon current use of the vessel which 
makes sense because vessels can be re-purposed, re-inspected, and 
re-certified for a different life than it was originally intended and 
USCG has regulations to allow this.  The simplest example of this would 
be adding a small motor to a vessel originally manufactured as a row 
boat.  I cannot find a USCG definition for "commercial vessel", only 
"commercial service".  So I think we should think in terms of service, 
not manufacturer.

Jon


On 7/20/2017 3:01 AM, Alan via Personal_Submersibles wrote:
> Thanks Jon,
> you should be a politician!
> With regard to a category for non classed subs that are built 
> commercially;
> this is an issue encountered in other industries.
> You can build a boat in your garage & sell it on ebay, but if you build
> 50 of them then you are categorised as  commercial, however the same 
> boat will
> now need to comply with industry standards.
> Graeme Hawke is pushing the boundaries with his unclassified subs; his 
> latest dragon submersible has I think 24 hrs life support instead of 3 
> or 4 days that ABS or GL require!
> Our current certification regulations may be extreme for shallow 
> diving vessels,
> but relevant for commercial deep diving vessels.
> I wouldn't want to be draughting any rules, as on the one hand you 
> don't want an
> unsafe sub taking an unwitting public down; but what is safe? In other 
> underwater sports
> such as scuba diving, you can buy equipment that numerous people die 
> using every
> year (146 World wide 2016).
> There is the bionic dolphin that could potentially dive under the 
> water at speed &
> entangle in an obstacle giving you a short period of time to get out 
> if you survived
> the impact. Also in the mix are ambient subs, wet subs & scooters!
> Would be pleased for you to get involved with the decision process if 
> you felt
> inclined!
> Regards Alan
>
>