IWA press release about LFP Guidance Note

[thingumybob]

1 hour ago, IanD said:

So are there published authors and accreditation for the BSS advice notes, or BSS regulations in general, or ISO standards? Why is this any different?

 

Given the amount of abuse and vitriol that this has attracted towards anyone who has stuck their head above the parapet (i.e. me), I'm not the least bit surprised that the other authors have not been publicly named (with their qualifications listed) as you suggested -- these are people with relevant knowledge/experience doing it voluntarily and on their own time, they're not paid to be pilloried... 😞

 

(though I can assure you that this information was sent to the IWA and CA when the document was submitted for approval -- and which means it's not "professional", according to the definition of the word, and doesn't "purport to be" either)

 

A list of references could be added in the next revision, but given that nothing in the document is lifted/quoted directly from any of them I'm not sure how helpful this would be -- it did include all the relevant ISO standards as well as parts of MCA550 and other publications and training about lithium batteries, several of which have been mentioned here. And the problem with a lot of those references is that they're not easily understood or designed for the casual reader, and would undoubtedly be misinterpreted -- MCA550 in particular has some horrendous requirements which are completely inappropriate for canal boats (but are appropriate for flagged vessels like seagoing commercial electric passenger ferries). Also it has no UK standing on the inland waterways, so zero direct relevance to boaters... 😉 

 

The concern about credibility has been noted by the JWG, they can read posts on CWDF too -- we'll have to decide what can be done (if anything) to convince people of this next time we meet. But I get the impression that whatever is said some people will never be satisfied, and just pivot to something else to complain about... 😞 

 

The people who wrote it are not bureaucrats determined to impose loads of pointless rules on boaters, they are mainly boaters themselves who want to help stop problems with LFP installations coming back to bite boaters (including them) in the future. It's not a conspiracy, unless you're wearing a tin hat... 😉 

 

I'll say this one last time -- AFAIK there is nothing in the Guidance Note advice that doesn't have a solid grounding in electrical installation knowledge or LFP properties or the standards and other documents or normal safety precautions as applied to other things on boats, and shouldn't even conflict with "common sense" (except where that's wrong, which it often is). It was reviewed (and had a couple of modifications suggested) by three independent "industry experts" outside the JWG, who were happy with it. And it's *advice*, so if you're a DIY/hybrid LA/LFP installer who wants to ignore it, go ahead, that's your decision... 🙂 

 

For anyone who thinks that "wider consultation" with boaters would have done anything other than massively delaying it due to endless (and often ill-informed or misunderstood and repetitive) arguments, I suggest you re-read the CWDF threads on the subject... 😉 

"AFAIK there is nothing in the Guidance Note advice that doesn't have a solid grounding in electrical installation knowledge or LFP properties or the standards and other documents or normal safety precautions as applied to other things on boats, and shouldn't even conflict with "common sense" ".  

 

And I'm afraid that is exactly why it's a document that will lack credibility because it lacks stated foundations. And to make the observation that "the problem with a lot of those references is that they're not easily understood or designed for the casual reader" also indicates a lack of appreciation of the purpose of credible references. Essentially, without them you're saying "Trust me". The answer to that is "Why?". And that's not being disrespectful, it's being logical. 

[IanD]

19 minutes ago, thingumybob said:

"AFAIK there is nothing in the Guidance Note advice that doesn't have a solid grounding in electrical installation knowledge or LFP properties or the standards and other documents or normal safety precautions as applied to other things on boats, and shouldn't even conflict with "common sense" ".  

 

And I'm afraid that is exactly why it's a document that will lack credibility because it lacks stated foundations. And to make the observation that "the problem with a lot of those references is that they're not easily understood or designed for the casual reader" also indicates a lack of appreciation of the purpose of credible references. Essentially, without them you're saying "Trust me". The answer to that is "Why?". And that's not being disrespectful, it's being logical. 

Go on then -- what would make you happy? Actual workable suggestion, not just a complaint?

 

Here are some references for you:

 

MGN 550 Am 1 -- doesn't apply to private boats on inland waterways, or indeed at sea...

https://www.gov.uk/government/publications/mgn-550-mf-amendment-1-electrical-installations-guidance-for-safe-design-installation-and-operation-of-lithium-ion-batteries/mgn-550-mf-amendment-1-electrical-installations-guidance-for-safe-design-installation-and-operation-of-lithium-ion-batteries

 

ISO 23625:2025 -- will cost you £326 (but not a required standard in the UK)

https://knowledge.bsigroup.com/products/small-craft-lithium-ion-batteries-3

 

BM lithium training course -- will cost you £275+VAT (warning: strong emphasis on offshore)

https://www.britishmarine.co.uk/training/our-courses/electrical-courses/introduction-lithium-ion-battery-installations-small-craft

 

Was that useful? 🙂 

Edited August 19 by IanD

[thingumybob]

11 minutes ago, IanD said:

Go on then -- what would make you happy? Actual workable suggestion, not just a complaint?

My first recommendation is to designate this document as a contribution to discussions rather than as a new public 'guide' . I'm happy to contribute as part of an inclusive discussion with all stakeholders to arrive at a single document that has relevant and accredited content. It's not something to do as a response to a Forum item. I do have a bit of pedigree in this area. 

[BoatingLifeUpNorth2]

1 hour ago, IanD said:

not wanting to have to rip up or refit existing installations

This will be the main concern to many boaters with Lithium batteries located in the living space. If anything should come of the guidelines wording “isolated from the living space” with regards to the BSS and if it becomes a BSS requirement. The majority will have to rip out and refit existing installations.

 I’m seeing new builds costing several hundreds of £1000’s with batteries in the living space. These new builds won’t need a BSS for four years. If the BSS is amended to include “no Lithium batteries in the living space” in say 2 years, these boats would need a major refit to meet this BSS requirement, affecting their BSS, insurance and license.

 The boat builder would deny any accountability for this as the BSS requirement was not in the BSS at the time of build.

 As I say the Lithium in the Living space will be the thing that could have a major impact on boaters.

 
 

Edited August 19 by BoatingLifeUpNorth2

[IanD]

1 hour ago, thingumybob said:

My first recommendation is to designate this document as a contribution to discussions rather than as a new public 'guide' . I'm happy to contribute as part of an inclusive discussion with all stakeholders to arrive at a single document that has relevant and accredited content. It's not something to do as a response to a Forum item. I do have a bit of pedigree in this area. 

That would defeat the primary Guidance Note purpose of providing useful LFP advice to boaters *now* -- or more specifically IWA/CA members, as the document says (but of course all boaters in practice). That's why it was written (and given the title) and why it has been published on the IWA/CA websites, because such information is sadly lacking.

 

The secondary purpose/intention from the JWG is to have it act as a basis for discussions with other organisations, because otherwise there is simply nothing suitable today to start these from, and it is hoped that this will give a good starting point. But this is only an intention -- it has been sent to BSS and insurers and other boating organisations to try and kick off such discussions, but there is no guarantee if/when these will happen (or response yet).

 

If/when these do happen then it will undoubtedly be modified and the terms of reference may (or may not) change, but this can't happen until such discussions take place. You can't run before you can walk... 😉 

 

BTW, what do you mean by "accredited content"? (genuine question)

Edited August 19 by IanD

[Arthur Marshall]

2 hours ago, IanD said:

But there are no paid consultants involved here, nobody (including external advisers) has been paid a single penny.

I know you've said this many times, and I'm sure you're right, as far as you know. You may, and probably are, completely right. But I don't know that for sure (I just know you believe it), and nobody else knows that at all, and most people are, rightly, suspicious of anything that is unattributed. We all know that most of what we read online is unreliable. The internet and many "scientific" publications are full of incorrect, biased and self serving information. I'm afraid that if people aren't prepared to put their name to a document, it indicates rather strongly that they either don't have confidence in it, or are hiding their own financial interest. That's why real scientists welcome peer reviews. This publication is avoiding it, going straight to the legislating bodies like BSS and insurance companies rather than opening the subject up to review and general discussion. It's a "we know better than you, so shut up" attitude that doesn't cut any mustard these days, especially if you refuse point blank to say who "we" are.

And with that, we'll have to agree to disagree.

[NB Thistle]

2 hours ago, Tony Brooks said:

 

The fast charging makes much better use of solar, ttpduch and extent they are often fully charged by mid morning.

 

Because you can use more of their capacity you can use smaller batteries.

I replaced four 110Ah lead acids with 3 lithiums of similar nominal capacity. Combined with a large solar array and a good mooring I have gone from a daily electric budget with the fridge turned off for three weeks over the shortest days and needing to run the engine to power the microwave to only needing one good sunny day in three/four to fully charge the batteries. I haven't run my engine or generator for power since my washing machine was moved onto the inverter back in February and I can only recall a handful of times over the whole winter. Life changing is absolutely the description.

[Tacet]

4 hours ago, IanD said:

 

 

I'll say this one last time -- AFAIK there is nothing in the Guidance Note advice that doesn't have a solid grounding in electrical installation knowledge or LFP properties or the standards and other documents or normal safety precautions as applied to ....🙂 

The guidance note does include remarks relating to insurance (which is one area which doesn't have a solid grounding in electrical matters etc).  If, as you suggest, all of the working group are electrically minded, it seems less than wise to go outside the group knowledge.

 

Having said that, I do think the working group should be commended for providing a sound starting point.

[Arthur Marshall]

35 minutes ago, NB Thistle said:

I replaced four 110Ah lead acids with 3 lithiums of similar nominal capacity. Combined with a large solar array and a good mooring I have gone from a daily electric budget with the fridge turned off for three weeks over the shortest days and needing to run the engine to power the microwave to only needing one good sunny day in three/four to fully charge the batteries. I haven't run my engine or generator for power since my washing machine was moved onto the inverter back in February and I can only recall a handful of times over the whole winter. Life changing is absolutely the description.

I'm genuinely impressed. I had no idea it, combined with solar etc, made such a huge difference.

[MtB]

I think its because you're attempting to solve a non-problem with an over-complicated solution. There has only been one incident so far and that was a professional installation, way out of the ordinary and definitely an outlier. 

 

The actual solution to comprehensive insurance becoming too onerous (which you repeatedly cite as the main reason for publishing your advice) is for boaters to stop buying the comprehensive insurance. It's not as though comprehensive insurance is mandatory.

 

If (and it hasn't happened yet) the conditions for comprehensive insurance get too onerous and the insurers see all their business evaporating, they will moderate their demands in the light of the absence of lots of claims. 

 

 

[David Mack]

10 minutes ago, Arthur Marshall said:

I'm genuinely impressed. I had no idea it, combined with solar etc, made such a huge difference.

One moment, when a group of people volunteer to get together and produce a guidance note, you say they should all be named, you don't trust them, they are all in it for what they can get out of it, scientific publications are full of incorrect, biased and self serving information etc. etc. and the next you are 'genuinely impressed' by advice given on the internet by someone you don't know who is identified only by his boat name!!!!

[MtB]

 

 

 

Edited August 19 by MtB
Numpty edit.

[thingumybob]

3 hours ago, IanD said:

That would defeat the primary Guidance Note purpose of providing useful LFP advice to boaters *now* -- or more specifically IWA/CA members, as the document says (but of course all boaters in practice). That's why it was written (and given the title) and why it has been published on the IWA/CA websites, because such information is sadly lacking.

 

The secondary purpose/intention from the JWG is to have it act as a basis for discussions with other organisations, because otherwise there is simply nothing suitable today to start these from, and it is hoped that this will give a good starting point. But this is only an intention -- it has been sent to BSS and insurers and other boating organisations to try and kick off such discussions, but there is no guarantee if/when these will happen (or response yet).

 

If/when these do happen then it will undoubtedly be modified and the terms of reference may (or may not) change, but this can't happen until such discussions take place. You can't run before you can walk... 😉 

 

BTW, what do you mean by "accredited content"? (genuine question)

 

Sorry, this calls for more than a single paragraph!

 

There is a document published by the British Standards Institution (BSI) titled "A standard for standards — Principles of standardisation - BS0" ; the standards writer's 'Bible' if you like (and, yes, it does encompass Guides and Codes or Practice, too). It has an accompanying document on the drafting of standards, the "Rules for the structure and drafting of UK standards". In there the term 'reference document' is used  and my term 'accredited content' was a quick and slightly crude reference to content from reference documents. Broadly speaking a reference document is a document that the drafting group uses as a source of information, technical background, existing requirements, or evidence when developing the standard. They can include:

- existing British, European or International standards;

- legislation and regulatory material;

- industry codes of practice;

- research papers;

- manufacturers' technical information;

- accident or incident data;

- guidance produced by other organisations; etc

There's more to say about such reference documents if needed. A concern that I and other commentators have expressed is that the IWA/CA text gives no indications of the use of any such reference documents, even though they can be shown to be available. Which leads me nicely to the  observation you made "The secondary purpose/intention from the JWG is to have it act as a basis for discussions with other organisations, because otherwise there is simply nothing suitable today to start these from". That statement can be challenged, not least as I referred to at least four possible starting points in my first contribution on this topic. At a minimum the IET Guide and the BSS Guide seem to be starting points? 

 

I'll leave it there for now. Whether one likes it or not your Guide exists. The idea of further discussion with stakeholders seems likely to have support. The next step would seem to be to extend your envisaged discussions to include the real end users, namely real boaters. The insurers and BSS are not the ultimate end users, they are essentially forms of regulatory body that impose  contractual and safety requirements respectively. By not including boaters, say via boater organisations, any such guidance cannot be considered to reflect all stakeholder interests. Again, credibility will suffer.

[David Mack]

3 minutes ago, thingumybob said:

At a minimum the IET Guide and the BSS Guide seem to be starting points? 

The IET guide was published before the ABC dayboat incident, which has rather changed the context for LFP installations, so its value with regard to LFP safety must now be somewhat open to question.

The BSS guidance was produced in response to that incident. Does it state its reference documents? Are the nnames of the drafters in the public domain? 

Or are different standards being applied to a document produced by volunteers?

10 minutes ago, thingumybob said:

By not including boaters, say via boater organisations,

This guidance has been produced by two boater organisations!

[b00ke23]

1 hour ago, David Mack said:

One moment, when a group of people volunteer to get together and produce a guidance note, you say they should all be named, you don't trust them, they are all in it for what they can get out of it, scientific publications are full of incorrect, biased and self serving information etc. etc. and the next you are 'genuinely impressed' by advice given on the internet by someone you don't know who is identified only by his boat name!!!!

 

But that advice is effectively peer reviewed by other members of this forum. Any duff advice is soon set upon with great vigour as we have all seen many times so it's fairly safe to take it as read.   

[thingumybob]

12 minutes ago, David Mack said:

The IET guide was published before the ABC dayboat incident, which has rather changed the context for LFP installations, so its value with regard to LFP safety must now be somewhat open to question.

The BSS guidance was produced in response to that incident. Does it state its reference documents? Are the nnames of the drafters in the public domain? 

Or are different standards being applied to a document produced by volunteers?

This guidance has been produced by two boater organisations!

There is no definitive conclusion from the ABC incident, which anyway is one case study. And I know folk who would question any claim that IWA represents boaters (but I'm not going down that rabbit hole here!). Now, I've made (and elaborated) various points and responded to various points. So far nothing has changed my position. Now, I'm taking a rest, and awaiting the announcement of an inclusive consultation across all stakeholders. 

[Arthur Marshall]

2 hours ago, David Mack said:

One moment, when a group of people volunteer to get together and produce a guidance note, you say they should all be named, you don't trust them, they are all in it for what they can get out of it, scientific publications are full of incorrect, biased and self serving information etc. etc. and the next you are 'genuinely impressed' by advice given on the internet by someone you don't know who is identified only by his boat name!!!!

Ah, but it's not advice I got, but a description of personal experience. Of course, he may be lying, but it's unlikely. And two other people have said the same. From personal knowledge. As neither of them was GybeHo, I think they're probably telling the truth. In the same way, I accept IanD is, with  good intention and good faith, and as far as he knows, because he's there to be debated with.

And I don't say they're all in it for what they can get. That would as bad as saying they are all pure as the driven wotsit. I'm saying I don't know, and any evidence to indicate one way or another is being deliberately hidden.

Nor did I say "scientific publications are full of incorrect, biased and self serving information". I put "scientific" - as in, say, the endless Daily Mail magic cures for cancer, homeopathy, or a magic glove advertised on FB that will cure my contracted finger without surgery. But perhaps you do believe everything you read. In my view, as I  said, real science isn't afraid of being peer reviewed, but perhaps you missed that in eagerness to have a snipe.

[BoatingLifeUpNorth2]

17 hours ago, Arthur Marshall said:

I'm afraid that if people aren't prepared to put their name to a document, it indicates rather strongly that they either don't have confidence in it, or are hiding their own financial interest

Or maybe, some realise how unpopular they would become on the canal system, if any of the guide lines are adopted by the BSS and insurance companies and become requirements. Especially the no Lithium in the living space or no DIY installs, which would affect 1000’s of boaters.
 For example boaters like @nicknorman and @Jen-in-Wellies who’s systems would be classed as DIY installs, but they seem more than competent to fit a safe system, like many many others.

 Put this into perspective, one incident out of 1000’s of boats, over several years and an un-appointed group of men decide to get together and try to change regulations that could affect 1000’s of boaters.

 There have been more fires caused by solid fuel fires and deaths by Carbon Monoxide poisoning in the last year and probably will be more this winter☹️government/BSS/Insurance action “fit a fire alarm and CO monitor”

 As I say the OP and his friends could become very unpopular if this affects 1000’s of boaters. I have no Lithium fitted, but I’m looking at this with a living in the real world perspective and the ABC boat fire isn’t the go to talk on the canals, contrary to what someone says. I live on the canal full time in a working yard and talk to different boaters every day, unlike the OP so I know a little about life on the canals. Some might disagree with what I say, that’s just life and everyone is entitled to their say and opinion, so I won’t tell you to STFU like some.😂

 

Edited August 20 by BoatingLifeUpNorth2

[EventualBoater]

15 minutes ago, BoatingLifeUpNorth2 said:

Or maybe, some realise how unpopular they would become on the canal system, if any of the guide lines are adopted by the BSS and insurance companies and become requirements. Especially the no Lithium in the living space or no DIY installs, which would affect 1000’s of boaters.
 For example boaters like @nicknorman and @Jen-in-Wellies who’s systems would be classed as DIY installs, but they seem more than competent to fit a safe system, like many many others.

 

 

This was kinda my thought. 

Getting abuse while travelling along the cut for this situation is not something id want my name against.

[IanD]

16 hours ago, Tacet said:

The guidance note does include remarks relating to insurance (which is one area which doesn't have a solid grounding in electrical matters etc).  If, as you suggest, all of the working group are electrically minded, it seems less than wise to go outside the group knowledge.

 

Having said that, I do think the working group should be commended for providing a sound starting point.

It includes comments about insurance because so do all the other public documents/advice (e.g. the BSS flyers), and also sources like the BM lithium training course (which is targeted at installers) -- because this is important to boaters and therefore installers, probably more so (at least in the short term) than BSS.

 

New BSS regs on LFP will take some time to be written (the wheels grind slowly...) and may not affect boaters until their next survey (could be several years away), new "lithium" insurance conditions could affect them at their very next renewal (could be a few months away), and we've already seen this happening since the ABC dayboat incident last year.

 

Since the Guidance Note is intended to advise boaters about LFP installations, it would surely be wrong not to bring the insurance issue to their attention?

 

Thank you for appreciating what we came up with... 🙂 

14 hours ago, thingumybob said:

 

Sorry, this calls for more than a single paragraph!

 

There is a document published by the British Standards Institution (BSI) titled "A standard for standards — Principles of standardisation - BS0" ; the standards writer's 'Bible' if you like (and, yes, it does encompass Guides and Codes or Practice, too). It has an accompanying document on the drafting of standards, the "Rules for the structure and drafting of UK standards". In there the term 'reference document' is used  and my term 'accredited content' was a quick and slightly crude reference to content from reference documents. Broadly speaking a reference document is a document that the drafting group uses as a source of information, technical background, existing requirements, or evidence when developing the standard. They can include:

- existing British, European or International standards;

- legislation and regulatory material;

- industry codes of practice;

- research papers;

- manufacturers' technical information;

- accident or incident data;

- guidance produced by other organisations; etc

There's more to say about such reference documents if needed. A concern that I and other commentators have expressed is that the IWA/CA text gives no indications of the use of any such reference documents, even though they can be shown to be available. Which leads me nicely to the  observation you made "The secondary purpose/intention from the JWG is to have it act as a basis for discussions with other organisations, because otherwise there is simply nothing suitable today to start these from". That statement can be challenged, not least as I referred to at least four possible starting points in my first contribution on this topic. At a minimum the IET Guide and the BSS Guide seem to be starting points? 

 

I'll leave it there for now. Whether one likes it or not your Guide exists. The idea of further discussion with stakeholders seems likely to have support. The next step would seem to be to extend your envisaged discussions to include the real end users, namely real boaters. The insurers and BSS are not the ultimate end users, they are essentially forms of regulatory body that impose  contractual and safety requirements respectively. By not including boaters, say via boater organisations, any such guidance cannot be considered to reflect all stakeholder interests. Again, credibility will suffer.

The guide was written by "real boaters". It deliberately excluded referencing anything regulatory (standards) or to do with RCR/RCD for the reasons stated in the introduction -- that's not what the purpose was, it was primarily to provide *advice* to boaters, and secondarily (hopefully...) to provide a starting point for wider discussions. Anything regulatory will come out of the regulatory bodies/insurers who might take part in those discussions, not the JWG -- there's a division of responsibility here.

If you want to be involved in the regulatory side of it -- which it seems you do, given your experience -- you need to join the appropriate bodies who write the regulations (ISO, BM, BSS).

 

13 hours ago, David Mack said:

The IET guide was published before the ABC dayboat incident, which has rather changed the context for LFP installations, so its value with regard to LFP safety must now be somewhat open to question.

The BSS guidance was produced in response to that incident. Does it state its reference documents? Are the nnames of the drafters in the public domain? 

Or are different standards being applied to a document produced by volunteers?

This guidance has been produced by two boater organisations!

And written by "real boaters"... 🙂 

 

1 hour ago, EventualBoater said:

This was kinda my thought. 

Getting abuse while travelling along the cut for this situation is not something id want my name against.

One of the writers of the report is in a similar situation, having a DIY installation with LFP batteries under the bed. So do you really think the JWG wasn't well aware of the concerns that the Guidance Note would raise?

 

In the end it's pretty much certain that ISO23625 will form the basis for both LFP regulations (BSS/RCR) and insurance company conditions, because -- well, it's an international safety standard, so how could they not do this? So this can't be ignored, because it is going to happen sooner or later... 😞 

 

In ISO23625 there is a lot of flexibility about installations, but the key theme for LFP batteries bigger than 500Wh is that the biggest risk is not an unextinguishable high-temperature fire (like other lithium chemistries) but gassing, because these gases are both toxic (HF, CO, other nasty things) but potentially explosive. This has been in there for several years but pretty much completely ignored by LFP installers, both DIY and professional, probably because they simply weren't aware of it and it's a standard, not a regulation that applies to UK boaters.

 

ISO23625 describes what should be done to reduce the risk from this, there are many options but what they all come down to on the end is that -- just like LPG or petrol fumes! -- such gases need to be vented overboard and not allowed to build up inside the boat where people can breathe them in or they could cause an explosion. The fact that this has now happened (even if only once) even though there have been many explosion-free LFP installations does not change this requirement, it's not going to go away no matter how much boaters might wish for this... 😞 

 

The section in the Guidance Note about this is *advising* boaters that they need to think seriously about the gassing/venting issue, not because the JWG wants to penalise boaters but because if they ignore the issue it's going to come back and bite them at some time in the future. Maybe not tomorrow, maybe not next year, but for sure within a few years. Since when people install things on boats like LFP they expect them to last longer than this without causing problems, this is not something that can be ignored any more when *advising* boaters.

 

So don't shoot the messenger -- it's not the Guidance Note (or the JWG) that is going to make this happen, it's standards and regulations (and insurance). Maybe so long as it's only insurance you can avoid this by not getting comprehensive insurance (but will third-party cover still be valid? -- don't know...), but when it happens with BSS you won't be able to avoid it any more -- and this will happen with or without the Guidance Note, driven by the safety standards like ISO23625... 😞 

 

(actually it's quite possible that without it the regulations/conditions would be even worse -- steel fireproof boxes, automatic fire extinguishers...)

Edited August 20 by IanD

[Alan de Enfield]

13 hours ago, thingumybob said:

 

Sorry, this calls for more than a single paragraph!

 

There is a document published by the British Standards Institution (BSI) titled "A standard for standards — Principles of standardisation - BS0" ; the standards writer's 'Bible' if you like (and, yes, it does encompass Guides and Codes or Practice, too). It has an accompanying document on the drafting of standards, the "Rules for the structure and drafting of UK standards". In there the term 'reference document' is used  and my term 'accredited content' was a quick and slightly crude reference to content from reference documents. Broadly speaking a reference document is a document that the drafting group uses as a source of information, technical background, existing requirements, or evidence when developing the standard. They can include:

- existing British, European or International standards;

- legislation and regulatory material;

- industry codes of practice;

- research papers;

- manufacturers' technical information;

- accident or incident data;

- guidance produced by other organisations; etc

There's more to say about such reference documents if needed. A concern that I and other commentators have expressed is that the IWA/CA text gives no indications of the use of any such reference documents, even though they can be shown to be available. Which leads me nicely to the  observation you made "The secondary purpose/intention from the JWG is to have it act as a basis for discussions with other organisations, because otherwise there is simply nothing suitable today to start these from". That statement can be challenged, not least as I referred to at least four possible starting points in my first contribution on this topic. At a minimum the IET Guide and the BSS Guide seem to be starting points? 

 

I'll leave it there for now. Whether one likes it or not your Guide exists. The idea of further discussion with stakeholders seems likely to have support. The next step would seem to be to extend your envisaged discussions to include the real end users, namely real boaters. The insurers and BSS are not the ultimate end users, they are essentially forms of regulatory body that impose  contractual and safety requirements respectively. By not including boaters, say via boater organisations, any such guidance cannot be considered to reflect all stakeholder interests. Again, credibility will suffer.

 

Having been involved with the writing of specifications for many organisations from BSI to the NCB, Aerospace etc I must agree with much of what you write.

 

Any specification, "best practice' or guidance documents are required to cite the sources of their information - "saying we suggest this is the best way to do something" is not acceptable.

 

How many times are 'facts' quoted on this forum and someone says "you haven't quoted the source" ?

 

For example the ISO 16315 :2021 "Small Ships Electrical Propulsion Systems" (relevant to a growing number here)

 

A large number of relevant specifications are used as sources for the standard - typically - for ISO 16315 .................

 

 

Typically ISO16315 may (for example) say that "Lithium batteries must be in ventilated boxes as per the requirements for petrol engined boats listed in ISO 11105", which in turn may point towards another ISO which could detail the materials that the 'box' must be made of.

[IanD]

16 minutes ago, Alan de Enfield said:

 

Having been involved with the writing of specifications for many organisations from BSI to the NCB, Aerospace etc I must agree with much of what you write.

 

Any specification, "best practice' or guidance documents are required to cite the sources of their information - "saying we suggest this is the best way to do something" is not acceptable.

 

How many times are 'facts' quoted on this forum and someone says "you haven't quoted the source" ?

 

For example the ISO 16315 :2021 "Small Ships Electrical Propulsion Systems" (relevant to a growing number here)

 

A large number of relevant specifications are used as sources for the standard - typically - for ISO 16315 .................

 

 

Typically ISO16315 may (for example) say that "Lithium batteries must be in ventilated boxes as per the requirements for petrol engined boats listed in ISO 11105", which in turn may point towards another ISO which could detail the materials that the 'box' must be made of.

I just explained why we didn't do that -- one reason being that the standards (and other information sources used like the BM training course) are not freely available to the "ordinary boater" that the guidance note is targeted at, so such references are useless to them.

 

Another reason is that if they do manage to get hold of them they'll be swamped with information which is not easy to read/understand and needs careful interpretation, much of which is not relevant to boats on the UK inland waterways (especially MCA 550!) because the standards have to cover all possible applications -- as the standards themselves point out. This is likely to lead to needless worry and misunderstanding for *ordinary boaters*.

 

I know you *love* standards and quoting legalese documents at great length, but I can't see how such a list would have been of the slightest use to boaters -- and I'm equally sure that if we had included one, you (and others) would have taken great delight in pointing out all the potentially "useful" (or not...) ones we *didn't* include -- just like above... 😉 

Edited August 20 by IanD

[Alan de Enfield]

15 minutes ago, IanD said:

I just explained why we didn't do that -- one reason being that the standards (and other information sources used like the BM training course) are not freely available to the "ordinary boater" that the guidance note is targeted at, so such references are useless to them.

 

You can huff and puff all you want - you are simply getting some constructive criticism, from people who have produced similar documents in a professional capacity, you do not need to take it as a personal 'attack'

The quoting of such documents would give your 'paper' much more credibilty, rather than (what seems to be a general view) that it was put together as a 'wish list' by a group of guys meeting in a pub back room somewhere.

If you had quoted the reference documents, it is the 'readers choice' if they wish to know more, but you have not made that possible.

 

You do not cite the papers authors.

You do not cite any reference documents.

You say that there is no 'come back' (deny responsibility) on what you have proposed.

You do not really want any discussion on the paper.

[thingumybob]

16 minutes ago, IanD said:

I just explained why we didn't do that -- one reason being that the standards (and other information sources used like the BM training course) are not freely available to the "ordinary boater" that the guidance note is targeted at, so such references are useless to them.

 

Another reason is that if they do manage to get hold of them they'll be swamped with information which is not easy to read/understand and needs careful interpretation, much of which is not relevant to boats on the UK inland waterways (especially MCA 550!) because the standards have to cover all possible applications -- as the standards themselves point out. This is likely to lead to needless worry and misunderstanding for *ordinary boaters*.

 

I know you *love* standards and quoting legalese documents at great length, but I can't see how such a list would have been of the slightest use to boaters -- and I'm equally sure that if we had included one, you (and others) would have taken great delight in pointing out all the potentially "useful" (or not...) ones we *didn't* include -- just like above... 😉 

And yet again a reason to not have confidence in the content of this guide. Plus I actually find this quite disturbing, that you appear to think boaters are stupid. Making use - in one way or another - of reference documents isn't a no-brainer, it needs to be done while actually understanding the references and their details and limits. Ignoring them because you disagree or can't work out how to refer to them is just Poor Authorship. By all means refer and then maybe interpret for the context, but ignoring them all together is again a case of saying "Trust me, I know what's good for you". I reject that, utterly. It may be challenging to identify provenance, it may be OK to have limited links to reference sources, but to have none, plus to not name what reads to me to be a limited size group (no consultation, you say) is not simply Bad Practice, it is downright questionable practice. You are claiming to write 'sensible advice' relevant to in the order of 35k boats registered to CRT and many thousands more registered elsewhere, and you don't even include them in the development process? No thanks. 

[IanD]

Just now, Alan de Enfield said:

 

You can huff and puff all you want - you are simply getting some constructive criticism, from people who have produced similar documents in a professional capacity, you do not need to take it as a personal 'attack'

The quoting of such documents would give your 'paper' much more credibilty, rather than (what seems to be a general view) that it was put together as a 'wish list' by a group of guys meeting in a pub back room somewhere.

If you had quoted the reference documents, it is the 'readers choice' if they wish to know more, but you have not made that possible.

 

You do not cite the papers authors.

You do not cite any reference documents.

You say that there is no 'come back' (deny responsibility) on what you have proposed.

You do not really want any discussion on the paper.

I do want discussion on the document, which is why I posted on CWDF about it -- though I'm now wishing I hadn't... 😞 

 

I don't want long and pointless discussions about multiple standards that are irrelevant to the target audience -- which is *not* you. I explained the reason for this, which was agreed by the JWG.

 

It's not a "paper" or a "standard", it's a document to try and help boaters.

 

Do you honestly think a list like yours will be in any way helpful to them?

 

4 minutes ago, thingumybob said:

And yet again a reason to not have confidence in the content of this guide. Plus I actually find this quite disturbing, that you appear to think boaters are stupid. Making use - in one way or another - of reference documents isn't a no-brainer, it needs to be done while actually understanding the references and their details and limits. Ignoring them because you disagree or can't work out how to refer to them is just Poor Authorship. By all means refer and then maybe interpret for the context, but ignoring them all together is again a case of saying "Trust me, I know what's good for you". I reject that, utterly. It may be challenging to identify provenance, it may be OK to have limited links to reference sources, but to have none, plus to not name what reads to me to be a limited size group (no consultation, you say) is not simply Bad Practice, it is downright questionable practice. You are claiming to write 'sensible advice' relevant to in the order of 35k boats registered to CRT and many thousands more registered elsewhere, and you don't even include them in the development process? No thanks. 

If you don't like it, you know what you can do...

 

(that's a quote from a song by Jeremy Taylor called "Jobsworth", in case you're unaware of it).