From: sealordone@aol.com
Reply-To: personal_submersibles@psubs.org
To: personal_submersibles@psubs.org
Subject: Re: [PSUBS-MAILIST] They're Just "Guidelines" !
Date: Tue, 18 Jul 2006 23:16:31 -0400
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
â?? 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 -----
From: Jon Wallace
To: javascript:parent.ComposeTo('personal_submersibles@psubs.org');
Sent: Sunday, July 16, 2006 11:57 AM
Subject: RE: [PSUBS-MAILIST] They're Just "Guidelines" !
Brian,
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.
Jon
-----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" !
Jon,
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?
Brian
----- Original Message -----
From: Jonathan Wallace
To: javascript:parent.ComposeTo('personal_submersibles@psubs.org');
Sent: Saturday, July 15, 2006 15:03
Subject: RE: [PSUBS-MAILIST] They're Just "Guidelines" !
Hi Brian,
Wouldn't the coast guard be the guiding authority?
Jon
-----Original Message-----
From: javascript:parent.ComposeTo('owner-personal_submersibles@psubs.org');
[mailto:owner-personal_submersibles@psubs.org]On Behalf Of Brian Cox
Sent: Saturday, July 15, 2006 4:22 PM
To: javascript:parent.ComposeTo('Personal_Submersibles@psubs.org');
Subject: [PSUBS-MAILIST] They're Just "Guidelines" !
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?
Brian Cox
The only easy day was Yesterday.
Do you Yahoo!?
Get on board. You're invited to try the new Yahoo! Mail Beta.
________________________________________________________________________
Check out AOL.com today. Breaking news, video search, pictures, email and
IM. All on demand. Always Free.