Re: [PSUBS-MAILIST] They're Just "Guidelines" !

Doug,

Finally got the opportunity to read this entirely this evening. The information is invaluable, particularly the list of references, as I had missed several. The effort is much appreciated, thank you.

Joe

>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: onal_submersibles%40psubs.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.
>________________________________________________________________________
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