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: 3.08.2 Hatches and Companionways 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: 3.08.2 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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