Australian National Standard for Buoyancy and Stability after Flooding

[mflapan]

Dear All

Public comment is being sought on a new draft standard and regulatory impact statement on Buoyancy and Stability after Flooding.

The standard is applicable to Domestic Commerical Vessels in Australia, but is also used by New Zealand, and from time to time by countries in the Pacific, South East Asia and the Middle East.

The draft standard has been written using a more performance-based approach to bridge the gap between small recreational boat standards and SOLAS standards applicable to large ships. You can download the draft standard, RIS, invitation to comment and comment forms from the NMSC website at:

http://www.nmsc.gov.au/yoursay_2.html

Public comment closes on 19 December 2008. The chapters in the draft standard illustrate the performance-based approach that underlies the provisions.

CONTENTS
Chapter 1 Preliminary
Chapter 2 Buoyancy and stability after flooding outcomes and solutions
Chapter 3 Determining the applicable requirements for buoyancy and stability after flooding
Chapter 4 Measures to control consequences of swamping
Chapter 5 Measures to control consequences of local flooding
Chapter 6 Additional or alternative measures to control consequences of grounding
Chapter 7 Additional measures to control consequences of collision
Chapter 8 Criteria for buoyancy and stability after flooding
Chapter 9 Requirements for the effectiveness of watertight compartments to provide additional buoyancy
Chapter 10 Requirements for the effectiveness of low-density flotation materials and air chambers to provide additional buoyancy
Chapter 11 Information on buoyancy and stability after flooding

Annex A Summary of hazards
Annex B Functional analysis of requirements for buoyancy and stability after flooding
Annex C Additional buoyancy calculation
Annex D Guidance on the distribution of additional buoyancy to achieve level flotation
Annex E Test procedure for level flotation
Annex F Tests for low-density flotation materials
Annex G Warning symbols

THe Public comment form should be used for providing public comment. It can printed from the web as a PDF, or downloaded from the web as a word document. I hope that some of you might take the opportunity to comment.

Regards
Mori

[Ad Hoc]

is it trying to do 'anything' more than which is already coverd by the HSC code or MCA/EU reg's?

[mflapan]

Thanks for the question.

Yes. I think there is a difference in that it:

1. Establishes a performance-based structure that increases understanding while allowing for greater flexibility in solution.

2. Bridges the gap between the requirements applicable to small workboat tinnies and quite substantial passenger vessels by providing a graded approach which provides appropriate controls that are relevant to the relative risks. The standards you quote do not cover the field to the same extent.

3. Deals with many aspects of survey that are normally left to the murky environs of surveyor discretion and exemptions. The proposal provides much greater clarity of requirements and consistency of outcome. It has been prepared on the basis of recording what a competent surveyor would apply if called upon to use discretion.

But hey! Don't rely on what I might say. You are very welcome to judge for yourself!

Regards
Mori

[Landlubber]

No, Australia is in such a mess with "Uniform" shipping regulations they would not know which way their arses point.

The old USLC is still a current regulation as well as the new NSCV above, they are copies of the old LLoyds originally but they certainly are not UNIFORM as the name suggest. Every state has their own department and they all have different interpretations of how things are done, some are crazy some are slack, but they have been playing around with this for years and years.
I have the original version the paperback, the print out that they insisted we pay for to get "up to date" only to find out that nothing had changed, and the new NSCV as far as it goes., typical bureauocrats, incompetant, have a committee meeting bullshit that has gone on for years and cost many a boatowner heaps of money for nothing, simply because some dimwit surveyor insists on having his way or nothing.

[Ad Hoc]

mfalpan

1. All class rules allow this. So how is this any different? It is the role of the naval architect to present "evidence" to convince the approving authority that a design warrants a different approach to the prescriptive rule!

2. The MCA small craft regs covers it all, that which isn't the HSC code and EU 98/18 does....anything outside is not worthy of the expensive of true design/survey...ie a canoe!!

3. If a naval architect is unable to pick apart the "murky interpretations" that a surveyor has, and point out aspect in rules for further justification, then the naval architect should choose another profession.

The rules are clear for all, naval architects/plan approval/ surveyors etc.

I don't see what these Oz rules are trying to do that is not already being done and has been done for many years...i think Landlubber summed it up well. When I last used the USL code, it was a joke....if it has "grown up", it will only, at best, mirror that which is already in existence!

[mflapan]

Ad hoc

By all means, put your comment forward using the process specified in the invitation to comment. It will be reviewed by the reference group of industry and government representatives.

Regards
Mori

[mflapan]

Dear person who signs himself "We do not know, what we do not know!"

The governments of Australia are currently investigating what can be done to eliminate the multiple jurisdictions and replace them with a single jurisdiction. Given your comments, I trust that you will be active in your support for the proposal.

The following is an extract from the announcement:

Consultation Regulation Impact Statement

On 25 July 2008, Australia's transport ministers (ATC) agreed to
recommend to the Council of Australian Governments (COAG) in October
that, subject to the outcome of regulatory impact assessments, COAG
endorse in-principle the establishment of a single national system
for maritime safety regulation administered by the Australian
Maritime Safety Authority (AMSA). Currently across Australia,
maritime safety is regulated by more than 50 pieces of legislation
administered by eight independent maritime safety agencies. The
national system would be part of ATC's national action plan, A New
Beginning for Transport, which encompasses a number of key national
reforms designed to cut down red tape in the transport and logistics
sector and deliver more consistency in the way transport is regulated
across Australia.

Transport Ministers agreed that, subject to the outcome of the
regulatory impact assessment, they support a national approach to
maritime safety regulation and are inclined towards broadening the
application of the Commonwealth Navigation Act 1912 to apply to all
commercial vessels. This will involve AMSA becoming responsible for
regulating vessel design, construction, equipment, vessel operation
(eg safety management systems) and crew certification and manning. In
exploring the arrangements which would underpin a national system,
Ministers agreed to explore the option of existing State and Northern
Territory maritime agencies being the delivery agents for regulatory
services under individual agreements with AMSA.

The first step in the process to establish a single national system
will involve the preparation of a Regulatory Impact Statement (RIS)
for consideration by transport ministers in November. The purpose of
the RIS is to ensure that any new or amended regulations avoid
unnecessary compliance costs and restrictions on competition. The RIS
is required to: describe the case for action; explore the range of
regulatory options; assess the costs and benefits of alternative
options; and to consult effectively with key stakeholders.

Attached is a consultation version of the RIS at

http://www.infrastructure.gov.au/maritime/safety/files/Consultation_RIS.doc (Join in browser if link broken)

which will be used for consulting stakeholders. It is intended to
generate feedback about the costs and benefits of the options which
will be reported and assessed in the final RIS. The final RIS will
include a detailed cost-benefit analysis, and recommend a preferred
approach. Consultations will be held throughout September to October
2008 in all states and the Northern Territory.

The proposed schedule is as follows:

8 - 9 September Hobart, Launceston

11 September Perth

15-16 September Adelaide, Port Lincoln

22-24 September Cairns, Airlie Beach

26 September Brisbane

30 September - 2 October Warrnambool, Melbourne, Lakes Entrance

7 October Darwin

9 October Sydney

While you are too late for the consultations, I understand that you can still comment on the consultation regulatory impact statement if you are very quick.

See http://www.infrastructure.gov.au/maritime/safety/consultation.aspx

Written submissions on this Consultation RIS were due by 15 October 2008 but the date has been extended. To find out more contact them directly.

Submissions should be sent to: maritime_ris@concepteconomics.com.au

or by post to:
Maritime RIS
Concept Economics
PO Box 5430
KINGSTON ACT 2604.

Regards
Mori

[Ad Hoc]

mflapan

If i find time to go through their rules i shall indeed make comments. Since no point reinventing the wheel!

[Ad Hoc]

Just had a quick scan through them.
What is clear is that apart from being a brave attempt, it is really to try and legislate for 'leisure craft' which are not usually part of flag/class approvals. And as such it is trying to improve poor/reckless seaman ship of these boats.
Since for any "other vessel" there exists a plethora of rules which said vessels must already comply with, in one form or another.
So, for the Capt or day tripper in a Cray fishing boat or water skier etc etc, these rules are for them.

Why not just make everyone have a licence, like they do in the US (one of the few systems in the US that is actually worth copying) and make the licence renewable every year or biannually etc. If an accident occurs, they have their licence taken away etc...just like a car!

This document is trying to cover too many bases and too many philosophies....it cant! There will be problems and consequnces down the road later once it goes into force.

[mflapan]

...I have the original version (of the Uniform Shipping Laws Code) the paperback, the print out that they insisted we pay for to get "up to date" only to find out that nothing had changed, and the new NSCV as far as it goes., typical bureauocrats, incompetant, have a committee meeting bullshit that has gone on for years and cost many a boatowner heaps of money for nothing, simply because some dimwit surveyor insists on having his way or nothing.

I forgot to mention that the USL Code has been available for downloading free of charge for 4 years on the NMSC website at http://www.nmsc.gov.au/uslcode_1.html

The USL Code 2008 came in on 2 October 2008 and can be downloaded (again free of charge) from http://www.nmsc.gov.au/USL_Code_2008_Main.html

Regards
Mori

[mflapan]

Just had a quick scan through them.
What is clear is that apart from being a brave attempt, it is really to try and legislate for 'leisure craft' which are not usually part of flag/class approvals. And as such it is trying to improve poor/reckless seaman ship of these boats.


Dear Ad Hoc

Just to clarify the application of the proposed standard for bouyancy and stability after flooding. It is intended for application to commercial vessels and not private recreational vessels. These commercial vessels could vary from 60 metre coastal passenger ships and 80 metre coastal cargo ships to small workboats and fishing boats used on rivers and estruaries. The operators are already certificated.

To everyone else,

Just a reminder that public comment closes on 19 December 2008. Your participation in the public comment process would be welcomed.

You can download the draft standard, Regulatory Impact Statement, invitation to comment and comment forms from the NMSC website at:

http://www.nmsc.gov.au/yoursay_2.html


Regards
Mori

[Ad Hoc]

mflapan
Exactly, that's my point. These rules, applicable for commerical vessels, there is nothing new. Hence why reinvent the wheel? HSC, EU98/18 and SOLAS cover everything.

[mflapan]

Dear Ad hoc

Have you actually tried to apply these standards to a diverse range of commercial vessels? Restricted offshore fishing boats less than 24 metres for instance? Or 8 m water taxis carrying 24 people at speeds of about 20 knots? Or ferries that operate at 15 knots which would be subject to the HSC Code by virtue of the speed/displacement formula contained in the HSC Code? None of the standards you quote will provide good practical solutions without intervention and creative interpretation. When these standards are applied, to provide a workable outcome designers and builders have to rely on the application of surveyor discretion with all the uncertainty and inconsistency that that can bring.

I understand your concerns to avoid a plethora of different standards. Where practicable, we have also attempted to adopt an approach similar to that which you have suggested. For example, the NSCV standards for construction refer directly Lloyds Rules as the deemed to satisfy standard for vessels up to 35 metres (other CS rules can also be used but would normally require the vessel to be classed). You can view this standard at http://www.nmsc.gov.au/documents/NSCV/PARTC3.pdf

You will note however that the construction standard does not just rely on Lloyds rules. Alternative standards are also specified for certain smaller vessels as the scantlings that arise from Lloyds rules are not always consistent with accepted industry practise.

Quite apart from the practical necessity of developing what might be (hopefully) improved standards that better addresses the needs of our stakeholders, there is also the matter of evolution. By your approach, we would still be relying on the first sets of standards ever published, albeit updated from time to time by the publishers. There would no progress and no innovation outside the relatively cumbersome machinery of major international standards.

The predecessor to the National Standard for Commercial Vessels, the USL Code, was developed in Australia 30 years ago allowing the use of a wide range of construction materials for commercial vessels including FRP and Aluminium. While the USL Code has its faults and limitations, it was years ahead of the acceptance of such materials by many other national maritime authorities. It is my personal observation that this could well have helped create the environment that lead to Australia being at the cutting edge of commercial high speed craft development in the 1980s and 1990s.

The standards we develop today will shape the domestic fleet in 20 years time. A part of the vision for the future is that our standards should focus on safety outcomes rather than prescriptive solutions. Hence the NSCV incorporates a performance-based approach that differs from that used in many contemporary maritime standards. To find out more about this approach, might I suggest you refer to a paper that I wrote on the subject of Equivalent Solutions at:

http://www.nmsc.gov.au/documents/Equivalent%20solutions%20-%20How%20do%20they%20work.pdf

So even when we just call up an existing standard, we need to overlay the performance-based approach so that it fits in with the broader objectives of our work, allowing alternative performance based solutions.

I hope this gives you some insight into the approach of the NMSC in drafting the NSCV. Perhaps you might now be able to look at the draft standard within the context of this background.

Regards
Mori

[Ad Hoc]

mflapan
Well, I'm getting confused with your position. You previously mentioned 60m and 80m vessels, and now you're talking about 8m taxis all in the same breath! As for smaller vessels, yes, MCA small craft rules are very good. But I have also designed 8m, 14m vessels working as river taxis to the DSC & HSC code

There are always going to be some vessels which push the envelope of what is really applicable. Regardless of this fact, whenever i hear someone saying:
"..None of the standards you quote will provide good practical solutions without intervention and creative interpretation.."
This means either the naval architect has not taken all design considerations and their implications into account pre-contract and post contract find it next to impossible to satisfy (ie poor design) or that is the role of the naval architect, is simply that, to create solutions that work given the existing legislative frame work.!
Case in point....my colleague and I design a SWATH vessel with 4 independent hulls. From the outset it would not or could not fit into any "existing rules" nor satisfy stability requirements. Yet, we made it work....being creative, and pre-contract NOT post.

"...By your approach, we would still be relying on the first sets of standards ever published, albeit updated from time to time by the publishers..."
No, this is not what i am saying and your attempt to say otherwise is disingenuous. IF you feel current rules are not applicable, you make representations to IMO, ICAS et al to get the rules changed. I am on several committees doing exactly this. One committee I am part of helped shaped the new update in the HSC rules with regards to "Gcoll" and stability. If you think its wrong, make a representation to get the rules changed! This committee is currently looking at getting the prescriptive rules changed (especially where old anomalies exists, to be a philosophy based rule to demonstrate an 'equivalence', for novel designs).

The reason why Oz excelled in the 1980s/90s is not down to the USL code. That just reflects your lack of understanding of the nature of the High-speed market and what is required.

It has given me an insight, but hasn't really changed my opinion.

[mflapan]

Dear Ad hoc

Thanks for your views. Given your extensive background, you are just the sort of person we would like to see consider the draft standard and provide comment. I hope you can try to go beyond your initial impressions and perhaps see the draft for what it is; merely a technical proposal for the application of buoyancy and stability after flooding requirements. Perhaps it might help if you think of the proposed draft as being just another proposal to one of your international technical committees.

I was interested in your having designed small craft to the DSC Code and the HSC Code. How did you approach the issue of collision accelerations exceeding 12g under the HSC Code 1996? Did you have to reinterpret the relevant clause or did everyone wear seatbelts? Have you tested the viability of your DSC and earlier HSC Code designs against the more stringent damage requirements of the HSC Code 2005?

The fast craft standard we have developed provides a graded approach between the full HSC Code and the requirements for conventional vessels so you don't get the situation that just because a boat goes half a knot faster, the requirements increase enormously. You can view that standard at:
http://www.nmsc.gov.au/documents/NSCV/Part_F_Sect_1C_Edition_1_x_23.pdf and you can read a paper explaining the rationale behind this standard at:
http://www.nmsc.gov.au/documents/NewRiskBasedStd.pdf

A lot of the content of the NSCV is concerned with providing a bridge between the different sets of established standards so the outcome is consistent with a performance-based approach.

Yes I agree that participation on international committees is important (I too am on such committees). However, you will appreciate that governments need reasonably rapid and direct means by which to implement policy. At the same time they have to be sensitive to the needs of their stakeholders. The processes surrounding the development of international standards do not always satisfy the immediate priorities of governments. For example, we implemented a recreational boat standard some years back that originally proposed adoption of the ISO Small Craft Standards. However, this had to be modified to accept other standards because of the ISO standard not yet been completed and also the fact that many recreational boats in Australia are sourced from the USA or exported to the USA.

My views on the potential contribution of the USL Code on the development of high speed craft in Australia came about during my working with Incat Designs for 3 years. As you say, it would be wrong to attribute the Australian success in high speed craft to the USL Code. However, I stand by my statement that it contributed to that success, creating an environment that supported those talented people who were prepared to innovate and push the envelope. Unfortunately, over the years the USL Code has itself become obsolete and no longer supports innovation in the way that it did. That is why we are reviewing our standards.

Regards
Mori

[Ad Hoc]

Mori

If i had time i would, hence the quick review i gave. I have far too much to do between now and submission date. NO time to even eat!!

Designing vessels that are "above" 12g is a matter of interpretation and making good representation tot he regulatory authority that is administring the vessel. Some Flag sates are very accommodating some are not. Some naval architects can provide sufficient "arguments" to allow dispensations and others are not. I'm not saying it is easy, but a reasoned and a sensible approach, not a heated one, usually works best. BUT, as i said before, all this must be done pre-contract. Doing it post-contract will lead to disaster. However, if, at the end of the day all avenues have been exhausted and a seat for 12g with a harness is required, then so be it. (Just make allowances pre-contrcat should this end up to be the case!!) Would you drive your car at speed and not wear a seat belt??....the rules are for passenger safety, not for the whims of the naval architect.

The "hovercraft designers" were always to most vocal in these committee meetings, for obvious reasons. Not having to design to the HSC code previously (under CAA) came as a shock to them! However, given the number of "units" made compared to the "norm"; what is being done, listening to the minority and giving it a majority voice, does that make sense? There are always going to be losers, in any set of prescriptive rules. So long as those of the vast majority are well "serviced" the objective is achieved, passenger safety.

[mflapan]

Dear Ad Hoc

Thanks for the response. I think we have mutual understanding even if not agreement.

One of the vexing questions regarding seat belts and small high speed craft is the concern that you are strapped in should the vessel flip over, etc. I think you would need to be careful to balance the potential benefits of seat belts against the protential risks. There is an interesting paper presented by a colleague of mine that describes such an occurrence at http://www.nmsc.gov.au/documents/Lugg%20David-%20paperThrill_Rides5.pdf. The result had persons been wearing seat belts would almost certainly have been fatal. By the same token, I have heard of incidents where people have been thrown from high speed vessels as they passed over the wake of another boat, and then run over by their own boat as it circled. The question of seat belts needs more in-depth analysis, possibly on a vessel by vessel basis.

Best regards
Mori

[Ad Hoc]

Mori
This is where the 2 issues are being blurred when they should not.
"...the concern that you are strapped in should the vessel flip over, .." Well, which is the concern here??...it seems you are focusing on the passenger in the seat belt. What about the vessel??..if there is a possibility of the vessel flipping, it shouldn't be allowed.
Remember the "Elk test", for the Mercedes A-class car?...a small magazine performed a simple tight turn test and it flipped....so Merc redesigned it to prevent it.
If there is a real concern that the vessel will flip, the vessel should not be allowed anywhere near the sea!
Your focus on a problem is wrong!

Secondly, there are many citings of people in car crashes who say "I would have died if i wore a seat belt"..i know of several myself. YET, there is a significantly higher number whose lives have been SAVED by wearing a seat belt.
I think you really need to address the philosophy of where the risk is, the risk, on what you have cited, is the vessel itself. It is considered risky for people/passengers in such a vessel, do not let the vessel touch the water!

[mflapan]

Dear Ad hoc

If I understand your reasoning correctly, vessels should never sink, so lifesaving equipment is superfluous!

Safety is not black or white but shades of grey. We cannot guarantee safety. The best we can do is provide for relative safety. The standards use the concept of defence in depth to reduce to acceptable levels the probability of catastrophic consequence. An expressed example of defence in depth is contained in Clause 1.6.2 of the NSCV fire safety standard at: http://www.nmsc.gov.au/documents/NSCV/NSCV%20Part%20C%20Section%204%20-%20Edition%202%20V3.pdf

If you look at the Fast Craft standard, it does contain provisions intended to reduce the probability of flipping, however, they cannot guarantee this will never happen.

The philosophy we apply is to focus on safety outcomes rather than prescribed solutions. That means that we try to look at the issue on its merits rather than just assuming that the prescriptive solution for a motor vehicle is the best solution for the maritime environment. But please note that just because I am prepared to entertain rational arguments against a prescriptive solution does not mean that I reject the prescriptive solution, or that the arguments against it will prevail. It just means that I have an open mind.


Regards
Mori

[Ad Hoc]

The role of a Flag state is ostensibly to stop ANY vessel going to sea...why?..if it doesn't go to sea, there is no safety risk. Simple.
So, rules are set to prevent a vessel going to sea....but a vessel does of course go to sea. Therefore such rules are made to ensure all risks are mitigated as much as possible.
So, as a flag state is must ask itself this very simple question. Which is greater risk, a vessel flipping or a passenger strapped in, when a vessel flips.
It is as simple as that.
If the concern is the vessel, then what do you do about this risk, have measures that prevent it 100% or 70% or 50% and so on...this is where representations to the Flag state are made and sensible approach taken..is the vessel inherently risky?..if the bottom line is yes, it should not go to sea. If the risks have been mitigated as much as possible, then the flag state and its rules, have done their job, to protect the passenger.
Prescriptive rules are for guidance...how a flag state administers them is a different matter. Ego, address the way your flag sate administers such rules. Yet you are going down an every increasing set of prescriptive rules, rather than a proper "equivalence based" philosophy, as the HSC Code is slowly doing. Problem with this is requires approval officers as being very educated and knowedgable, not computer programmers who tick boxes off in a check list of rules.

[mflapan]

Dear Ad hoc

You are correct in saying that the HSC Code represents significant progresss towards a more performance-based approach relative to SOLAS.

Workable standards need a balance between performance and prescription. The two concepts are not mutually exclusive. We are drawing from both prescriptive and performance based approaches in the NSCV, hopefully combining the best aspects of prescription (convenience) with the best aspects of performance (flexibility). To this end, we have adopted a number of the performance characteristics of the HSC Code and modified them to reflect a performance-based structure pioneered by the Building Code of Australia that has been refined in the light of their experiences over a 15 year period.

An observation that I might make on the HSC Code is that it appears to still be in a state of development. My impression is that it is becoming more prescriptive over time relative to earlier editions and the DSC Code. I understand this is in response to concerns that the threshold for compliance with performance-based 'motherhood' statements is sometimes difficult to establish and can be inconsistently interpreted. Prescription in itself is not a bad thing, as it provides a tangible statement of what is hopefully agreed good practice. Prescription only becomes a problem when compliance can only be measured against the prescribed solution rather than the safety outcome. Likewise, reliance on performance approaches alone tends to be inefficient as everyone has to re-invent the wheel each time they use it. That is why we are taking a hybrid approach.

Yes, you are right that performance based approaches require higher levels of competence in both proponents and approvers. This is discussed in my paper on equivalent solutions.

Regards
Mori