Australian National Standard for Buoyancy and Stability after Flooding

Discussion in 'Stability' started by mflapan, Oct 23, 2008.

  1. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
  2. Ad Hoc
    Joined: Oct 2008
    Posts: 7,184
    Likes: 1,105, Points: 113, Legacy Rep: 2488
    Location: Japan

    Ad Hoc Naval Architect

    is it trying to do 'anything' more than which is already coverd by the HSC code or MCA/EU reg's?
     
  3. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
  4. Landlubber
    Joined: Jun 2007
    Posts: 2,640
    Likes: 124, Points: 0, Legacy Rep: 1802
    Location: Brisbane

    Landlubber Senior Member

    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 ******** 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.
     
  5. Ad Hoc
    Joined: Oct 2008
    Posts: 7,184
    Likes: 1,105, Points: 113, Legacy Rep: 2488
    Location: Japan

    Ad Hoc Naval Architect

    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!
     
  6. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
  7. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
  8. Ad Hoc
    Joined: Oct 2008
    Posts: 7,184
    Likes: 1,105, Points: 113, Legacy Rep: 2488
    Location: Japan

    Ad Hoc Naval Architect

    mflapan

    If i find time to go through their rules i shall indeed make comments. Since no point reinventing the wheel!
     
  9. Ad Hoc
    Joined: Oct 2008
    Posts: 7,184
    Likes: 1,105, Points: 113, Legacy Rep: 2488
    Location: Japan

    Ad Hoc Naval Architect

    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.
     
  10. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
  11. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member


    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
     
  12. Ad Hoc
    Joined: Oct 2008
    Posts: 7,184
    Likes: 1,105, Points: 113, Legacy Rep: 2488
    Location: Japan

    Ad Hoc Naval Architect

    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.
     
  13. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
  14. Ad Hoc
    Joined: Oct 2008
    Posts: 7,184
    Likes: 1,105, Points: 113, Legacy Rep: 2488
    Location: Japan

    Ad Hoc Naval Architect

    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.
     

  15. mflapan
    Joined: Oct 2005
    Posts: 81
    Likes: 9, Points: 0, Legacy Rep: 154
    Location: Sydney, Australia

    mflapan Junior Member

    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
     
Forum posts represent the experience, opinion, and view of individual users. Boat Design Net does not necessarily endorse nor share the view of each individual post.
When making potentially dangerous or financial decisions, always employ and consult appropriate professionals. Your circumstances or experience may be different.