b'SAFETY MATTERSSAFETYPVA Stands up EngineeringSub-Committee to Address TechnologyERIC CHRISTENSEN // PVA DIRECTOR OF REGULATORY AFFAIRS & RISK MANAGEMENTT he adage regulations lag technologyin the standard as of the date of incorporation,ated in order to provide expert guidance, lessons has never been more apparent than inso unless the regulations are updated, a UL orlearned, as well as the latest and the greatest the last few years.Advances in alter- NFPA standard from 1995 is the baseline forknow how. We are dedicated to partnership with native fuels such as LNG, hydrogen, and am- regulatory compliance and not the latest editionCG ENG and in utilizing the expertise of our monia, electric propulsion, LED lighting, etc.,or revision of the standard. For older vessels thisassociate members who design systems and man-havechallengedaregulatoryframeworklastcanbeadvantageousfromagrandfatheringufacture the equipment installed on our vessels. revised in the mid-1990s. When the small pas- standpoint, but for designers and builders ofAs all vessel systems become more complicated, senger vessel regulations were updated in 1996,vessels today it can be problematic. more complex, and modern and new innovative your propulsion options were gasoline, diesel,and novel systems are introduced, it is necessary or wind. At that time, electronically controlledWherethereisdeviationproposedtothethat a special skill set for analysis, interpreta-engines were still novel design, lead acid batter- standards in the regulations, there are a coupletion, and training is acquired for the PVA.ies were the standard, and LED lighting wasoptionsequivalencyandspecialconsider-not a viable option in the marketplace. ation. Equivalency is determined at the CoastThe sub-committee is made up of both vessel Guard Headquarters level which means thatand associate members and has the ability to The evolving technology has challenged vesselthe proposed alternative component, standard,add additional expertise as needed for a partic-operators, naval architects, and suppliers whoor system has been deemed equivalent in per- ular project.want to incorporate the latest technology butformance to that published in the regulations are hamstrung by a dated regulatory schemeand has satisfied the Coast Guards concern that requires new technology to be evaluatedforsafety,security,andenvironmentalpro- The sub-committee from the ground up, often on a case-by-casetection.Equivalenciescanbevessel-specific basis. That takes time and money, especially ifandarecommonlyacceptedbylocalCoastdetermined illegal a vessel operator is the first one to propose theGuard throughout the life of the vessel. Special use of new technology. The U.S. Coast Guard,considerationisgrantedatthelocalOfficertampering may increaseas our primary regulator, is also constrained byin Charge Marine Inspection (OCMI) level, the regulations they are charged to enforce. where local conditions dictate the need or al- risk and vulnerability REGULATORY FRAMEWORK lowance to deviate from a specific requirementfor inspected in the regulations. Special consideration is only TheregulationsaremadeupofaseriesofapplicablewithinthespecificOCMIzonepassenger vessels.requirements that must be met for a domesticwhere granted. An OCMI in another zone is passengervessel,oranyotherCoastGuardnot obligated to accept the determination in inspected vessel, to operate on the navigabletheir operating area.watersoftheU.S.TherearerequirementsThe first project taken on by the sub-commit-forelectrical,mechanical,fireprotection,ENGINEERING SUB-COMMITTEE tee was a review of materials associated with and structural that rely on standards that areAt the PVA Convention at MariTrends 2022,so-called right to repair initiatives currently incorporated into the regulations by reference.membersoftheSafetyandSecurityCom- at the state legislative level and to make a rec-What that means is that the Coast Guard hasmittee, seeing an opportunity to leverage theommendation to the PVA Board of Directors takenanexistingstandard,suchasanUn- expertise and experience of vessel and associatewhethertojoinaCoalitionAgainstIllegal derwrites Laboratories (UL) standard for anmembers, proposed the formation of the En- Tampering.Ifenacted,therighttorepair electrical component or a National Fire Pro- gineering Sub-Committee, which was quicklyinitiatives could give individuals access to soft-tection Association (NFPA) standard for fireembraced by the full committee and membersware used in control systems to diagnose and suppression systems, and made it a require- of the PVA Board of Directors. In establishingeffect repairs. It could also allow individuals ment to meet that standard. Naval architectsthe sub-committee, Capt. Mike McElroy withto bypass safety or environmental settings on designtothestandards,buildersconstructWendella Sightseeing Boats in Chicago statedmachinery.Thesub-committeeheardfrom vesselsusingthestandards,vesseloperatorsin the charter documents the purpose of theengine and control system manufacturers and maintain the vessel to the standards, and thesub-committee: drew a clear distinction between diagnosis and Coast Guard marine inspector evaluates com- repair and illegal tampering.pliance to the standards. Asanindustrywerecognizethatthereare lessons learned that are being lost concerningAfter thorough discussion, the sub-committee When a standard is incorporated by reference inequipment life span, shelf life, installation, anddetermined illegal tampering may increase risk the regulations, it is frozen in time. Regulatoryin actual application. PVA has recognized thatand vulnerability for inspected passenger ves-compliance is tied to the requirements specifieda special engineering task force needed to be cre- sels for the following reasons. FOGHORN 24'