Fed. Seaworthiness Regulations on Recreational Boats >20ft & <65ft?

Discussion in 'Boatbuilding' started by zstine, Dec 3, 2019.

  1. zstine
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    zstine Junior Member

    I'm interested in manufacturing recreational sailboats greater than 20ft, less than 100ton/65ft. I understand I have to register as a manufacture and put a HIN on my boats. I understand the manufacture self-certifies with fed req's and there are addition voluntary regs like ABYC and independent orgs like NMMA will certify to a set of standards. BUT I want to know what minimum federal requirements I need to self-certify to. I have read USCG boatbuilders handbook, and some of the CFR 46 & 33 requirements. I see capacity and flotation req's for vessels under 20ft. I see Gasoline system (not Diesel), I see lighting requirements and fire suppression, etc.... but I see nothing that says the boat must float!! I MUST BE MISSING SOMETHING!?

    I have not found anything requiring any stability, down-flood angle, hull integrity req's, wave-slap pressure requirements, heck not even a requirement for hull valves on through hulls.
    Can someone point me to where the federal regulations are for self-certification of recreational boats?? seems like the wild west...
    Thanks
     
  2. TANSL
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    TANSL Senior Member

    I think you have not searched in depth. I cannot believe that the USCG does not have rules on stability and other issues related to boat safety. But, if you want to look at the ISO standards, which are essential in Europe for a boat to acquire the "CE" mark and can be commercialized, there are more than 125 standards that regulate absolutely all aspects that a small boat between 2.5 and 24 must meet. m of length
     
  3. zstine
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    zstine Junior Member

    Thanks, Yes I understand there are many other organizations that regulate boat building and design. But they are voluntary and while I may chose to comply with certain req's of ISO, ABYC, etc. I want to know "what is my legal requirement to self-certify for USA Federal regulations"? I cannot really believe that USCG doesn't regulate eithert, but I have been unable to find specific federal code that applies. For example, 46 CFR part 170 Stability Requ's for Inspected Vessels does not apply...
     
  4. TANSL
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    TANSL Senior Member

    Why don't you resort to international regulations. All countries must comply with them, which are, let's say so, the "minimum to comply". SOLAS, for example, is very complete. COLREG is very interesting. MARPOL, it's worth reading. "Load Lines Regulations", I recommend them. IMO publications are also very good, ... But in my opinion, and of course I can be wrong, no regulation is as complete as ISO standards. And all the rules that I have just quoted are not voluntary but mandatory.
     
  5. gonzo
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    gonzo Senior Member

    No, there are no regulations that specifically target seaworthiness on recreational craft. The regulations by the USCG are in the CFR. It is available for free online. ABYC requires that you join to get access to all standards. The USCG defers to ABYC and NMMA on many of the regulations. There is also NFPA for fire protection. You have not missed the point that the requirements appear to be random and disorganized. I think that you should hire someone to go over the boats you plan to build and help you meet the regulations. Also, get a lawyer to take care of liability issues. Even if you comply with every regulation, it does not mean you could be liable.
     
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  6. DCockey
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    DCockey Senior Member

    You have already found the answer to you question. Regulations https://www.uscgboating.org/regulations/index.php?m=r

    No, you are not missing anything. There are no USCG or other US federal requirements governing capacity, required floatation, etc which apply to boats for recreational use between 20 feet and 65 feet. I don't believe there are any rules for boats between 20 feer and 65 feet carrying six passengers or fewer for hire which are sometimes refered to as 6-pac or uninspected vessels. (I'm not familar with rules for boats over 65 feet and don't know what regulations, if any, apply to boats over 65 feet for non-commercial recreational use or carrying six or fewer passengers for hire.) Also not all boats under 20 feet in length are covered by the USCG maximum capacity and floatation requirements. For example sail boats, catamarans, canoes and kayaks, and inflatable boats are not covered by the maximum capacity and floatation requirements.

    More searching will not yield any USCG rules on stability and related for recreational boats over 20 feet in length because they do not exist.

    My understanding is some builders of recreational boats in the US follow some or all of the relevant ISO standards for assorted reasons even though they are not legally required for recreational boats sold in the US.

    USCG requires all boats to meet applicable COLREG rules for lights, sound signals and similar when on US Federal waters, but nothing about stability or maximum capacity. My understanding is SOLAS does not apply to boats under 24m/79 feet in length nor to boats which do not make international voyages. I do not know of any provisions of MARPOL which govern stability or vessel capacity.
     
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  7. gonzo
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    gonzo Senior Member

    Only boats under 20 feet need to display a maximum capacity.
     
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  8. DCockey
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    DCockey Senior Member

    And not all boats under 20 feet.
     
  9. zstine
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    zstine Junior Member

    Thanks Gonzo.. crazy to me not to have statutes requiring minimal seaworthiness. I am in the business planning stage and wish it was more clear what compliance was going to involve especially from a time & money perspective. I've seen $20k per model estimates for ISO cert itself (never mind the design / build cost of compliance), and since I'm looking at very custom / one-off designs, that becomes quite an expense on every boat. I will have to be very precise and lawyer up when contracting a boat. There may be circumstances when non-compliance is desirable to the customer or the builder. And it's not clear how a builder can be held liable for not meeting standards that are not required by law unless it is negligent. of course what is/is not negligent is open for interpretation. In 1975 Tartan installed the head on my boat below the waterline without an anti-siphon loop. If the joker leaks, the toilet overflows and the boat could sink. This doesn't meet ABYC today, but you could argue that it is not negligent. Unfortunately, I don't have an ABYC membership yet and can't easily review those specs at the moment... still learning
     
  10. zstine
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    zstine Junior Member

    Thanks David C. for verification/clarification. I used to work for Elec. Boat building subs for the Navy and the ship's contract has nicely laid out specifications... This recreational boat building really is the wild west!
     
  11. DCockey
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    DCockey Senior Member

    Building nuclear subs for the Navy is probably the most highly regulated and constrained ship building in the US. I was recently talking to several engineers who work at Bath Iron Works building surface vessels for the Navy and they said the culture at EB was more strict and rigid than at BWI even though they have the same parent company.

    I'm not aware of US boat builders paying for third party ISO certification unless they are planning to export to the EU or another market which requires third party certification. You can use the ISO standards without paying for third party certification.
     
  12. zstine
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    zstine Junior Member

    Yeah, I probably would not seek ISO CE cert initially. The $20k figure came from a white paper MJM yachts published (Boston Boat Works, LLC). So they are ISO certified and I'm sure others are, as you said, for export, etc... https://mjmyachts.com/wp-content/uploads/2019/05/ISO-CE-cert-whitepaper.pdf
     
  13. DCockey
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    DCockey Senior Member

    Thanks for the link. I knew that MJM advertised their boats as meeting ISO requirements for Class A waters but did not know they were third party certified.
     
  14. fallguy
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    fallguy Senior Member

    Most of the standards are poor, imo.

    Outboards, for example, are poorly governed.

    I suggest you build to higher standards than US, at least in some areas.

    Read the US regs for builders; it will give you a good baseline and will probably leave you with a few questions as it did me. I am sure some will defend it, but a for instance would be the amount of egress required per bunk. See if you can find that.
     

  15. DCockey
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    DCockey Senior Member

    In what respect?
     
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