Safety At Sea - 3/17/2007 Minutes - ISAF Revisions
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Submissions are now invited for the 2006 ISAF Annual Conference. Please note the submission deadline is 1ST AUGUST 2006. The attached Submission form should be completed and return to the ISAF office via email: secretariat@isaf.co.uk or by fax: + 44 2380 635 789. Notes for completing the Submission form In accordance with ISAF Regulation 1.1, submissions can only be accepted from Member National Authorities (MNAs), International Class Associations, Committee Chairmen, the ISAF President and/or the Executive Committee. Recognised Class Associations may make submissions to change their class rules. In the proposal if relevant
please detail the current reference or policy, with the proposed
changes set out. New
words and phrases should be bold
and underlined, deleted text should be If the submission proposes a
change to existing Articles, Regulations, the Racing Rules, or other
ISAF Codes and Rules, please quote the relevant reference or policy. Please define clearly the
reasons for making this submission.
For further information on the ISAF submissions process please contact Vicky Jinks on + 44 23 80 63 51 11 or email secretariat@isaf.co.uk. Title: 3.03.1 Hull Construction Standards (Scantlings)
Subtitle:
ISAF Special Regulations, Section 3 – Structural Features,
Stability and Fixed Equipment A submission from the A submission from the UNITED STATES SAILING ASSOCIATION Proposal: 3.03.1 A yacht defined in the table above shall have
been designed, built, maintained,
modified and repaired in accordance with the requirements of either: a) the EC Recreational Craft Directive for Category
A (having obtained the CE mark), or b) the ABS Guide for Building and Classing Offshore
Yachts in which case the yacht shall have on board either a certificate
of plan approval issued by ABS, or written statements signed by the
designer and builder which confirm that they have respectively designed
and built the yacht in accordance with the ABS Guide, or c)
ISO 12215 Category A, with written statements signed by the designer and
builder which confirm that they have respectively designed and built the
yacht in accordance with the ISO standard, d) except that a race organizer and
class rules may accept Current
Position: 3.03.1 A yacht defined in the table above shall have
been designed and built in accordance with either: a) the EC
Recreational Craft Directive for Category A (having obtained the CE
mark), or b) the ABS
Guide for Building and Classing Offshore Yachts in which case the yacht
shall have on board either a certificate of plan approval issued by ABS,
or written statements signed by the designer and builder which confirm
that they have respectively designed and built the yacht in accordance
with the ABS Guide, c) except that a race
organizer and class rules may accept other evidence of suitability of
design and build when that described in (a) or (b) above is not
available, provided that the requirements of (a) or (b) have never been
refused due to unsuitability of the boat. Reason:
The Offshore
Special Regulations provide a series of recommendations for the
construction and outfitting of yachts for offshore racing. If adopted by
the race organizers in the Notice of Race, they become regulations for
the race. Developed in response to accidents at sea, the “Special Regs”
have provided an increased level of safety for those participating in
ocean racing. The rules are reviewed and updated continuously as needed
to reflect changes in design, construction or outside influences. A
current rule however opens a loophole for inherently unsafe designs. One of the
longest standing rules establishes minimum construction standards.
Although construction standards for yachts have existed for over a 100
years (Herreshoff’s, Lloyds, Lawley’s, etc.), it was in response to
the 1979 Fastnet tragedy that the first set of rules were developed by
the ITC for modern yachts. Published in draft form in the early 80’s
and codified in 1986, these formed the Guide for Building and Classing
Offshore Racing Yachts by the American Bureau of Shipping (ABS).
As with all ABS rules and guides, the regulations provided two levels of
compliance. “Plan approval” constituted a review of the designer’s
drawings and calculations by ABS engineers. “Plan approval with
survey” also included the presence of a certified surveyor during
construction to ensure that the vessel was built to the plans. Updated
in 1994 in response to results from various round the world races, it
was also updated in 1997. This last update was brought about by
unfavorable legal action, where ABS realized that the risk versus reward
for “classing” small craft with untrained crews was uneconomical.
The update limited ABS plan approval to vessels between 79 and 100 feet.
ABS continues to provide limited “plan approval with survey” for
small craft at higher rates than is normally considered reasonable for
small craft.
As the
Special Regs required compliance with ABS, a system where the designer
and builder certified that the vessel was designed and built in
accordance with the ABS Guide was adopted. As these certificates were
required to be inspected, the designer’s and builder’s professional
reputations would be questioned if discrepancies were found. Although
this caused some issues with older vessels where the designer had passed
away, or the builder was no longer in business, those situations were
rare. In rare cases of homebuilding, an independent engineer was
required to evaluate the design for compliance.
During the
late 90s the CE standards for small craft began to develop. The
structural requirements were initially based on the ABS Guide and were
later modified to take in to account a more accurate understanding of
the loads and materials. An important difference with the CE standards
is that a company or homebuilder, without any engineering background,
can self-certify the structural design and construction. In the case of
yacht building companies, their reputation is again on the line. Two years
ago the Special Regs rule reached its current form:
3.03.1 A
yacht defined in the table above shall have been designed and built in
accordance with either:
c) except
that a race organizer or class rules may accept other evidence of
suitability of design and build when that described in (a) or (b) above
is not available, provided that the requirements of (a) or (b) have
never been refused due to unsuitability of the boat. The second
section is the earlier ABS compliance route. The first section allows
for CE compliance, which does not require any engineering background to
certify the structural design of small craft (below 12m) or home-built
craft. The third section allows for a race organizer to issue a
favorable decision on the suitability of design and build of the vessel
for offshore racing. This last option is very troubling. In addition to
allowing the race organizers to take on a tremendous amount of
liability, it allows for unskilled personnel to determine what is
acceptably designed and built for offshore conditions. This could mean
that a boat not suited for offshore racing would be allowed to race by
well-intentioned, but unknowledgeable race organizers.
The
implication of that loophole was probably not anticipated by the rule
makers when the rule was initiated, but the result has been that boats
not adequately built for offshore racing have participated in those
races. For example, recently the new owner of a race boat asked me to
look at damage sustained by the boat in an offshore passage. The owner
wished to race the boat in the Newport-Bermuda Race and the boat had
received trophies in two other offshore races. After looking through the
boat I was suspicious that the boat did not meet the ABS standards. I
contacted the designer and was informed that the boat in fact did not
meet the ABS standards and had never been submitted for review.
Nonetheless, the race organizers had approved the vessel for offshore
racing. Luckily the damage was not severe. This was probably due to the
fact that the previous owner believed that the vessel had never seen
conditions worse than 30 knots and sea state 4.
The current
wording of the rule allows for essentially “inshore” racing boats to
race offshore. While the primary issue with this is one of insufficient
construction and safety, the questions of fairness and trends is also
important. If an older offshore racing vessel built to the ABS or CE
standard races against an inshore design, clearly the lighter built boat
will be more competitive (if it manages to finish). Once the word is out
that to be competitive you must sail an inshore design offshore, the
trend will be for lightly built boats to race offshore. That essentially
means that the intention of the rule is bypassed completely.
An
additional problem is the limitation in the rule’s preamble that the
boat only needs to be “designed and built” in accordance with the
standards, but not maintained or repaired. This has allowed
modifications that compromise the yacht’s integrity. To remedy this situation the committee should consider revising the rule to either drop option c), or to reword it such that it tightens the definition of suitability. That could be that the design meets the requirements of an established scantling rule, or is checked by an engineer familiar with yacht structures. It seems ironic that a vessel is required to carry a large amount of safety gear, while the basic platform could be inherently unsafe. The 1998 Sydney Hobart demonstrated that the boats built to ABS came through with few problems, but that the boats not built or maintained to established standards could have significant problems. It also showed that simply doing the race numerous times before was not enough evidence to demonstrate that a vessel was sound for all the conditions it might see in the race. If the rule is not tightened, we could be looking at another wide-scale tragedy.
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