US SAILING

Safety At Sea - 3/17/2007 Minutes - ISAF Revisions



2006 ISAF Submission Process
3.08.2 Hatches and Companionways
 

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 struck through. Please detail new proposals or policy in its entirety.

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.

Authorisation to make a submission:

(Note: (In accordance with regulations 1.1, 1.3 & 1.4, a submission may only be made by a duly authorised person.  Please detail name of authorised person).

Name of Authorised Person:

Position:

     

     

Contact:

     

(Note:  Please give a contact name and e-mail address for any queries)

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:  3.08.2 Hatches and Companionways

Subtitle:  ISAF Special Regulations, Section 3 – Structural Features, Stability and Fixed Equipment
Offshore Committee
Special Regulations Sub-committee

     

A submission from the A submission from the UNITED STATES SAILING ASSOCIATION

     

Proposal:

3.08.2 A hatch shall be:

      a) so arranged as to be above the water when the hull is heeled 90 degrees. Hatches over lockers that open to the interior of the vessel shall be included in this requirement. A yacht may have a maximum of four (two on each side of centerline) hatches that do not conform to this requirement, provided that the opening of each is less than 0.071 sq m (110 sq in). Effective for boats of a series begun after January 1, 2009, a written statement signed by the designer or other person who performed the downflooding analysis shall be carried on board. For purposes of this rule the vessel’s displacement condition for the analysis shall be the Light Craft Condition LCC (in conformity with 6.3 of the EN ISO 8666 standard and 3.5.1 of the EN ISO12217-2 standard).

Current Position:

3.08.2 A hatch shall be:

      a) so arranged as to be above the water when the hull is heeled 90 degrees.

Reason:

This rule has been in place for many years, and it requires for CAT 0-4 that all hatches will remain above the waterline when the vessel is heeled 90 degrees. It seems like a reasonable rule, but the problem is that this will exclude many of the existing craft racing today as,

1) Many off center hatches or opening ports would be in violation if strictly interpreted the way indicated by ISAF (“Use the worst possible loading condition.”)

2) Older designs would not be grandfathered and changes are very expensive

3) Narrow, heavy displacement boats might not meet it with standard hatch sizes, but they may be so stable and under canvassed that the risk of down flooding is quite a bit less than modern lightweight designs.

4) Without any definitions defining in what condition the yacht would be assessed, the rule lacks any real direction for designers

5) It is not clear if cockpit locker hatches are included.

A good question is why, if the rule has been around a while, that this problem did not surface before? The answer is twofold. The first comes down to inspection. I know that when I was inspecting boats for the Single-handed Transpac, this rule was not inspected as it would require either a capsize test, or a statement from the designer. No explanation is needed of the problems and complaints that would be encountered by forcing a capsize test!

The problem with a designer certification is the lack of direction on the load conditions as described above. I asked a number of inspectors, and none indicated they had ever checked this rule. As no one either inspects for it, or certifies it, the rule is essentially meaningless.

The second reason this just now came up is the new ISO requirements for Owner's Manuals. This requires a much greater documentation of the vessel's capabilities than before. This rule just went in to force, and builders have not caught up with it.

Another possible reason that this has not been brought up before is the lack of incidents related to fore hatch down flooding. I went back through the US Hanson awards and also talked with other US Safety at Sea Committee members and none could remember a case where a US yacht was lost due to forehatch down flooding while the boat was on its side.

Here is an example of the ambiguity inherent for not describing the displacement condition, in a new design of a moderate weight cruiser/racer, the designer calculated the following for the forehatch edge immersion:

LPS is 126 degrees and stability index is over 130

ISO Max Operating Condition  (20 people, no equipment)             85 degrees

Normal Full Load (10 people)          86

Half Load                                     88

IMS Sailing Condition                     90

IMS Measurement Condition           94

Lightship                                      96

An additional problem is that the ISO Max condition is defined by the owner, and the full load condition is defined by the designer. In the full load condition the 10 people were assumed to include six down below. If all 10 were in the cockpit the hatch is out of the water at 90 degrees. The basic problem is that when a boat is on its side it is very sensitive to fore and aft weight placement.

Because of that, do we need to incline all boats to 90 to verify the rule requirement? This is done in many offshore racing craft (IMOCA 60, Box 40, etc.), but is costly and dangerous, and is not likely to be popular. An alternative is to use one of their rules, not require the heeling compliance check and instead ask for a letter of compliance from the designer. To avoid problems with older designs, we could grandfather existing craft. This should not cause a significant safety issue as it appears few racing yachts have been lost due to downflooding through the hatches (with the exception of a number of smaller yachts lost through locker hatch flooding through to the main cabin.)

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