HOW TO CHANGE THE INTERNATIONAL SAILING FEDERATION SPECIAL REGULATIONS GOVERNING OFFSHORE AND OCEANIC RACING INCLUDING US SAILING PRESCRIPTIONS

This describes the process and time line for submitting proposed changes to the 2008-2009 International Sailing Federation Special regulations Governing Offshore and Oceanic Racing including US SAILING Prescriptions:

The US SAILING Safety at Sea Committee must have all submissions to review by March 10, 2007.  At the Spring Meeting of US SAILING, the Safety at Sea Committee will deliberate and vote on each item.  Next, the US SAILING Offshore Committee then deliberates and approves.  Next, the US SAILING Board of Directors deliberates and approves any submission that would go to ISAF.  Then, all submissions must be in the ISAF office by early July 2007.

Then the US SAILING delegation at the fall meeting of the ISAF Special Regulations Committee votes on each countries submissions (including our own), along with the delegations from the other countries. The International Sailing Federation Special regulations Governing Offshore and Oceanic Racing including US SAILING Prescriptions are published every other year (even years). That done, US SAILING then adds US SAILING Board approved US SAILING Prescriptions and publishes the booklet "International Sailing Federation Special regulations Governing Offshore and Oceanic Racing including US SAILING Prescriptions" that are used in the U.S.  Copies of this booklet are normally required to be aboard yachts racing in U.S. waters that invoke this book in the Notice of Race. Order a copy here - International Sailing Federation Special Regulations Governing Offshore and Oceanic Equipment and Preparation for 2006-2007 including US SAILING Prescriptions.

 

MAKE A SUBMISSION FOR CHANGING THE ISAF SPECIAL REGULATIONS OR ANY US SAILING PRESCRIPTION

ISAF SPECIAL REGULATION NUMBER:

TARGET REGULATIONS:  ISAF      US SAILING Prescription
Note: If the US SAILING Board Approves any item, by default it will be a US SAILING Prescription, unless ISAF also approves it.

SUBMITTED BY (name):

SUBMITTER'S EMAIL ADDRESS:

PROPOSED WORDING (in its entirety): 

EXPLANATION (answer the question: Why is this good?)

EFFECTIVE DATE: January 1, 2008

 

WHAT IDEAS ARE PROPOSED FOR CHANGE IN 2008?

The US SAILING Board of Directors approved the US Safety at Sea Committee submissions.  These will be consider by the ISAF Special Regulations Sub-Committee in November 2008.  If ISAF does not adopt any of them, they will be US SAILING Prescriptions in the 2008-2009 book.

ISAF SR NUMBER: 3.03.1
TARGET REGULATIONS: ISAF
SUBMITTED BY: Dr. Paul Miller

CURRENT WORDING: 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.
US SAILING prescribes that 3.03.1(c) shall not apply in 2007.

PROPOSED WORDING:
(note: no change in category, MoMu0,1,2)
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, when that described in (a), (b), or (c) above is not available, the signed statement by a naval architect or other person familiar with the standards listed above that the yacht fulfills the requirements of (a), (b), or (c).

EXPLANATION:
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:
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 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.

ISAF SR NUMBER: 3.08.2
TARGET REGULATIONS: ISAF
SUBMITTED BY: Dr. Paul Miller

CURRENT WORDING:
 3.08.2 A hatch shall be:
      a) so arranged as to be above the water when the hull is heeled 90 degrees
US SAILING prescribes that 3.08.2(a) shall not apply in 2007. 

PROPOSED WORDING:
(note: no change in category, Mo0,1,2,3,4)

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).

EXPLANATION:
The current rule reads:

3.08.2 A hatch shall be:
a) so arranged as to be above the water when the hull is heeled 90 degrees

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 Singlehanded 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 downflooding. I went back through the Hanson awards and also talked with other SASC members and none could remember a case where a US yacht was lost due to forehatch downflooding 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.)

ISAF SR NUMBER: 3.14.6 c)
TARGET REGULATIONS: ISAF
SUBMITTED BY: Glenn McCarthy

CURRENT WORDING:
c) A taut lanyard of synthetic rope may be used to secure lifelines provided the gap it closes does not exceed 100 mm (4 in).

PROPOSED WORDING:
After the sentence, Add: This lanyard shall be replaced annually at a minimum.

EXPLANATION:
ISAF sent an announcement out in recent years making sailors aware of known failures. We have seen these same failures in the U.S. UV degradation, wear and tear, and even sharp weld splatterings have caused these lanyards to fail. Regular maintenance would remove UV degradation, wear and tear and would let sailors know by inspection that they have a sharp edge cutting their line if required to replace annually.

ISAF SR NUMBER: 4.28.2
TARGET REGULATIONS: ISAF
SUBMITTED BY: Stan Honey

CURRENT WORDING:
None.

PROPOSED WORDING:
4.28.2 For MoMu 1, 2. Require in January 2012 and recommend until then that each yacht shall be equipped with an EPFS (e.g. GPS) capable of immediately recording a man overboard position from each helm station.

EXPLANATION:

ISAF SR NUMBER: 5.02.5
TARGET REGULATIONS: ISAF
SUBMITTED BY: Skip Allan

CURRENT WORDING:
5.02.5 It is strongly recommended that:
a) a harness and safety line SHOULD comply with EN 1095 (ISO 12401) or near equivalent.

PROPOSED WORDING:
Delete 5.02.5 a)

Rationale

5.02.1 states  “each crew member shall have a harness and safety line that complies with EN 1095 (ISO12401) or equivalent with a safety line not more than 2m in length”.

This supersedes 5.02.5 a)

 

 

 

XXXXXXXXXXXXX

ISAF SR NUMBER: 4.28.2
TARGET REGULATIONS: US SAILING PRESCRIPTION
SUBMITTED BY: Stan Honey

CURRENT WORDING:
None.

PROPOSED WORDING:
For Category MoMu1. US Sailing intends to require in 2012 that each yacht sailing in a category 1 event must have a button located at each helm location that when pressed enters the current location of the yacht as a "MOB" waypoint in the yacht's GPS.

EXPLANATION:
Many GPS's have a "MOB" button today, but it can take too long for a crewman to run below to press the button when somebody falls over. Very few GPS's today have a simple "contact-closure" input to allow a simple pushbutton to be installed remotely to trigger the "MOB" function. The statement of the intention of US Sailing to require such a function in 2012 will provide an incentive for GPS manufacturers to offer such a feature in upcoming products in order to gain the marketing advantage that their GPS meets future requirements.

ISAF SR NUMBER: 3.14.6 c)
TARGET REGULATIONS: ISAF
SUBMITTED BY: Glenn McCarthy

CURRENT WORDING:
c) A taut lanyard of synthetic rope may be used to secure lifelines provided the gap it closes does not exceed 100 mm (4 in).

PROPOSED WORDING:
After the sentence, Add: This lanyard shall be replaced annually at a minimum.

EXPLANATION:
ISAF sent an announcement out in recent years making sailors aware of known failures. We have seen these same failures in the U.S. UV degradation, wear and tear, and even sharp weld splatterings have caused these lanyards to fail. Regular maintenance would remove UV degradation, wear and tear and would let sailors know by inspection that they have a sharp edge cutting their line if required to replace annually.

ISAF SR NUMBER: 5.02.1, 5.02.5
TARGET REGULATIONS: ISAF
SUBMITTED BY: Skip Allan

CURRENT WORDING:
5.02.1 each crew member shall have a harness and safety line that complies with EN 1095 (ISO12401) or equivalent with a safety line not more than 2m in length

5.02.2 At least 30% of the crew shall each, in addition to the above be provided with either:-
a) a safety line not more than 1m long, or
b) a mid-point snaphook on a 2m safety line

PROPOSED WORDING:
Each crew member SHOULD have a harness and safety line that complies with EN 1095 (ISO12401) or equivalent with a safety line not more than 2m in length.

EXPLANATION:
5.02.1 currently says "SHALL have a harness and safety line that complies with EN 1095 (ISO12401) or equivalent."
5.02.5 says "STRONGLY RECOMMENDED that:- a) a harness and safety line SHOULD comply with EN 1095 (ISO 12401) or near equivalent."