----- Original Message -----
Sent: Tuesday, July 18, 2006 20:16
Subject: Re: [PSUBS-MAILIST] They're Just
"Guidelines" !
Shipmates,
I have never had a submersible classed (by ABS, Lloyds or Det Norske
Veritas) or certified (by the USCG), so I am not a "hands-on expert" by any
means. But I did take the trouble to collect and read all of the
primarly classing and certification documents in preparation for my
presentation on standards to the 2004 Psubs Convention. So I am willing
to share my understanding of what I read, for what it is worth.
As to the issues of getting a concrete hull classed or certified, I doubt
any of these conservative organizations would permit you to explore these
uncharted waters when other technologes have proved themselves. As to
whether you could use a "recreational submersible" for something like farming,
which sounds to me to be either commerical or experimental,
I would doubt that too. This is simply the impression I have after
wading through all of these documents. This is personal opinion
only.
I put together a few handouts for my 2004 presentation. But since
so few folks attend the conventions, I am sure most folks have never read
it. Let me repeat it here. If you guys like it, we might even
clean it up a little and put it on the website.
"Safety Standards for Personal Submersibles
"The community of private submarine builders has not yet reached the
level of organizational maturity that would allow us to publish our own
standards and best practices for the design, fabrication, construction,
testing, operation, maintenance and decommissioning of personal
submersibles. Because of this, we refer our members to the excellent
guidance materials developed by the commercial submersible industry by
organizations such as the American Bureau of Shipping (ABS), Lloyd's Register
(LR) and the United States Coast Guard (USCG), among others.
"Submersibles produced for commercial use are both classed, by a
standards organization, and certified, by a government entity. Without
classing, neither the submarine nor its occupants can be insured.
Without certification, industrial submersibles are unable to operate within
the three mile limit of this or other nationss. Because of the
considerable expense of classing and certifying personal submersibles (which
easily exceeds the cost of construction), it is extremely unusual for the
owner of a personal submersible to seek either classing or
certification. Most personal submersible owners forgo insurance, and
avoid the requirement for certification by limiting their operations to
recreational use only. It is therefore a recommend best practice for each
builder to take the responsibility to read and apply, to the extent possible,
the safety standards published by and for the commercial submersible
industry.
"The USCG recognizes and defines the legal category "recreational
submersible" as those submersibles manufactured or operated primarily for
pleasure, or leased, or rented or chartered to another for the latter's
pleasure. These vessels are registered and regulated in an identical
manner with motorboats, and are required to meet only those criteria required
of all motorboats of their length (requirements increase with length).
These requirements include such items as life jackets, fire extinguishers and
signaling devices. The requirements for these devices become more
demanding as boats exceed the lengths of 16, 26, 40 and finally 65 feet.
The overwhelming majority of personal submersibles qualify to be treated by
the USCG as
recreational submersibles".
"Submersible safety standards are not self-contained, but rather refer
out to other standards that are then included in the standard by
reference. Lloyds rules for classing submersibles, for example, refers
out to the standards published by the American Society for Mechanical
Engineers (ASME), whose standards in turn refer out to the standards developed
by the American Society for Testing and Materials (ASTM). How many
affiliated references need to be acquired and followed is left to the
discretion of the individual submersible developer, and will probably reflect
the degree of complexity or innovation in his or her design.
"The two most important documents for a US submersible developer, as luck
would have it, are both free of charge on the internet. The primarly
classing document is the ABS publication entitled Rules for Building and
Classing Underwater Vehicles, Systems and Hyperbaric Facilities (2002), while
the primary certification document is the USCG publication entitled Guidance
for Certification of Passenger Carrying Submersibles (1993). References
for these and other documents are listed below.
"The USCG guidelines are recommended but not required for recreational
submersibles. The USCG does have requirements, however, that must be
addressed. First, the submersible operator must comply with the
regulations on boating contained in the Code of Federal Regulations
(CFR), Subchapter S- Boating Safety, Parts 173-183 (life jackets, fire
extinguishers, etc.). When registering your submarine in your state, the
state will notify you of all USCG requirements...you need not contact the USCG
yourself. Second, the submersible operator must comply with any
operating restrictions imposed by the USCG Captian of the Port (COTP).
The COPT is essentially the USCG regional manager, and appears to exercise
broad authority over his or her area of responsiblity. In addition to
the USCG, other government entities (such as a state government or the
National Park Service) may impose their own restrictions on operations
within their areas of authority.
"The general process followed by both ABS and the USCG (there is
considerable duplication of effort between these bodies during classing and
certification) is as follows. First, plans, calculations and data are
submitted and approved prior to any construction activity. Next, both
materials and fabrication processes are inspected and approved. Third,
non-destructive testing of all systems is completed. Fourth, operational
tests and trials are conducted. Fifth, the submersible is classed and
certified. Finally, the submersible is inspected (surveyed) on a
scheduled basis thereafter in order to maintain its class and
certification. Both ABS and the USCG provide guidelines for each stage
of this process. It is a process that all submersible builders should
consider to be a best practice for the community.
References:
1. Rules for Building and Classing Underwater Vehicles, Systems and
Hyperbaric Facilities (2002) ABS.
2. Guidance for Certification of Passenger Carrying Submersibles
(1992) USCG.
3. Safety Standards for Pressure Vessels for Human Occupancy (2002)
American Society of Mechanical Engineers.
4. Rules and Regulations for the Construction and Classification of
Submersibles and Underwater Systems (1989) LR
5. Guidelines for the Design, Construction and Operation of
Passenger Submersible Craft (2001) International Maritime Organization.
6. Safety and Operational Guidelines for Undersea Vehicles (1974-
out of print) Marine Technology Society.
7. Handbook of Acrylics for Submersibles, Hyperbaric Chambers and
Aquaria (2003) by Jerry D. Stachiw, Best Publishing Company.
-----Original Message-----
From:
katsurencho@yahoo.com
To: personal_submersibles@psubs.org
Sent: Tue, 18
Jul 2006 8:01 AM
Subject: RE: [PSUBS-MAILIST] They're Just "Guidelines"
!
A lot of states don't requie registration for vessels with no power,
other than arms or legs!!! Usually they require registration for sail boat,
and then sometimes not for under certain lengths.
The USCG has most of their regulations on the internet. Be sure to
read the first part, that tells where and to who the regulations apply. I
would do a search under US Coast Guard. It's been a while. it's either
uscg.gov or uscg.mil, probably gov.
They have their instructions (books) that can be downloaded. The
bad part is that there may be area that are defined or intreperted from one
USCG area to another, but not many.
Bob Duncan
"Jay K. Jeffries"
<bottomgun@mindspring.com> wrote:
George,
This is
not completely accurate. The Coast Guard has no jurisdiction over
non-navigatable waters such as a quarry. Also, previously some States
do not require registration for vessels under a certain length (not sure if
this is still applicable).
Jay K.
Jeffries
Andros
Is., Bahamas
Natura
nihil fit in frustra
— Nature
does nothing in vain
From:
owner-personal_submersibles@psubs.org
[mailto:owner-personal_submersibles@psubs.org] On Behalf Of George
Slaterpryce
Sent: Monday,
July 17, 2006 9:23 AM
To:
personal_submersibles@psubs.org
Subject: Re: [PSUBS-MAILIST] They're
Just "Guidelines" !
If it
has motors, can carry passengers, and goes in the water... then the coast
gaurd has jurisdiction over it and you need to register it (get a hull
number and pay your taxes on it).
If
you want to use it for commercial purposes, you need a certifying agency to
check it out, and certifying agencies like to be involved from the planning
process on.
George H.
Slaterpryce III
That's MR. PIG. to
you!
----- Original
Message -----
Sent: Sunday, July
16, 2006 11:57 AM
Subject: RE:
[PSUBS-MAILIST] They're Just "Guidelines"
!
I suppose that
would be one way of doing it. But you might try calling first to see
if they believe they have jurisdiction or requirements for submersible
operation. Perhaps more information would be helpful regarding
your definition of "human occupancy". You don't need
certification from anyone if you're just using the sub for yourself or
taking passengers for free. If you want paying passengers, then I
think you'll need Coast Guard certification for the vessel and a "captain"
certification from them. It's been a long time since I had my boat,
but I believe those were the conditions for a vessel that was "for
hire". Of course, that only applies to waterways in which the Coast
Guard has jurisdiction. You don't need ABS certification unless you
are looking for insurance on the vessel. In that case, I assume the
insurance company would dictate who they required to perform the
inspection for certification.
I don't have a
definitive answer for you Brian. Just recalling some of the issues
I've heard about in the past.
-----Original
Message-----
From:
owner-personal_submersibles@psubs.org
[mailto:owner-personal_submersibles@psubs.org]On Behalf Of Brian Cox
Sent: Sunday, July 16, 2006 1:02
AM
To: personal_submersibles@psubs.org
Subject: Re: [PSUBS-MAILIST]
They're Just "Guidelines" !
So you just motor up to the coast guard dock with your 50' X 8'
dia concrete sub and say " I need my sticker"
? I'm sure they would have no idea what they were
looking at. But I guess if you had all of your floatation
devices, flares, anchor, radio, they would pass you. What do you
think?
-----
Original Message -----
Sent: Saturday,
July 15, 2006 15:03
Subject: RE:
[PSUBS-MAILIST] They're Just "Guidelines"
!
Wouldn't the
coast guard be the guiding authority?
I have a
hypothetical question concerning pressure vessels for human
occupancy. What if the material that is being used is not
addressed in the "guidelines" in the PVHO handbook? The
material I'm thinking of is concrete, would certification by an
engineer as to the strength of the material suffice ?
Also say a
pressure vessel for human occupancy was built and say that this
pressure vessel was only going to be lowered in and out of the water
with a crane. If the pressure vessel was certified by a
qualified engineer would that be different than Lloyds of London or the
ABS certifying a submarine? Doug Farrow, any thoughts on
this?
The
only easy day was Yesterday.
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