BSS Failure

[carlt]

I disagree, the word "shielding" means a protective barrier, the mere fact that an exhaust is difficult to reach does not mean that it has a shield around it.

Oh come on!

 

If the hull of the boat is shielding part of the exhaust, then that part of the exhaust does not need lagging.

 

Just because it doesn't have "protective exhaust shielding" stamped on it doesn't mean it's not doing a job.

[Boatgypsy]

I may have got the wrong end of the stick, but Rob has I think in the past on several occasions indicated on this forum that publication of such information would be a good idea, and at one stage I thought they were moving towards it.

 

I have never seen anything formally published, and in the end I stopped repeating myself that it would be worth doing.

 

I still think it would be worth doing.

 

My usual example: If someone could prove to me that the use of say a non room sealed LPG fridge, properly maintained, still resulted in significant casualties, I would of course review the data, and maybe modify my boat on the basis of the evidence before me.

 

Instead the BSS seem to have renewed their dislike for these things, and started "strongly recommending" that all new fridge installations are electric, in the absence of any new balanced flue gas fridges being sold. They have not however gone as far as stopping the fitting or replacement of an LPG fridge, once again.

 

However I would like to be convinced that this is more than a knee-jerk reaction, particularly as in my view many people place themselves at greater risk by the dangers they place themselves in trying to recharge batteries. I feel that it is possible that generator related incidents might be as bad a statistic as LPG gas fridge incidents, but I lack the data that would allow me to make my own mind up.

I might be wrong here Alan, but I seem to remember that the reason LPG fridges are no longer available and are frowned upon by the BSS is that there was a significant incidence of corrosion in the burner tube resulting in blockage of the flue and backflow of exhaust gases into the boat. The same fridges being designed for the caravan market didn't have the same problem in caravans where ventilation is easier to acheive. I got rid of my old gas fridge for that reason, although in my case the flakes of rust just kept blocking the gas jet.

 

Oh come on!

 

If the hull of the boat is shielding part of the exhaust, then that part of the exhaust does not need lagging.

 

Just because it doesn't have "protective exhaust shielding" stamped on it doesn't mean it's not doing a job.

OK Carl - I'm trying to envisage this boat of yours where the exhaust system is completely surrounded by the hull, other than by the fact that the hull surrounds everything in it.

 

Yes, if a part of the hull is formed so that it completely shields part of the exhaust, that part would not need additional shielding or lagging, but Dave's point was that his exhaust didn't need any lagging or shielding because it was difficult to reach. In fact he seems to be saying that the difficulty in reaching it means that it is shielded!

 

At no point does the BSS requirement say that an exhaust has to have "protective exhaust shielding" stamped on it - what's your point there Carl?

[ChrisPy]

Oh come on!

 

If the hull of the boat is shielding part of the exhaust, then that part of the exhaust does not need lagging.

 

Just because it doesn't have "protective exhaust shielding" stamped on it doesn't mean it's not doing a job.

I suppose the reasonable test would be if someone down in the engine space or above deck could reach out and come into contact with the hot silencer.

However any such argument like that falls down if the flexible part of the exhaust does not need to be shielded (in lieu of lagging).

[Boatgypsy]

I suppose the reasonable test would be if someone down in the engine space or above deck could reach out and come into contact with the hot silencer.

However any such argument like that falls down if the flexible part of the exhaust does not need to be shielded (in lieu of lagging).

Absolutely, if it can be physically reached it needs to be protected so that it can't burn. Yes there is an inconsistency about flexible pipes, but surely common sense tells you that if you lag the rest of the system you find some way to lag or otherwise shield that flexible section too.

[mayalld]

I disagree, the word "shielding" means a protective barrier, the mere fact that an exhaust is difficult to reach does not mean that it has a shield around it. There is no such thing as an "inaccesible location", all parts of a boat are generally accessible, some more so than others.

 

The BSS checklist at item 2.15.2 states "lagging or shielding must provide complete coverage". I'm afraid the implication is yours, not that of the checklist.

 

Have you read the requirement?

 

Yes, I have read the requirement, and I note that the BSS documentation provides no explicit definition of what shielding is.

 

In the absence of such explicit information, I would have to conclude that I might draw upon the meaning of "shielding" in other safety requirements as being instructive.

 

As such, I look to such documents as my trust old 16th edition book, and conclude that provided a part is positioned such that no person is able to touch it without the use of tools to remove some other part, it is "shielded"

 

 

OK Carl - I'm trying to envisage this boat of yours where the exhaust system is completely surrounded by the hull, other than by the fact that the hull surrounds everything in it.

 

Yes, if a part of the hull is formed so that it completely shields part of the exhaust, that part would not need additional shielding or lagging, but Dave's point was that his exhaust didn't need any lagging or shielding because it was difficult to reach. In fact he seems to be saying that the difficulty in reaching it means that it is shielded!

 

I don't recall making any such statement about any part of MY exhaust system, which is lagged. I merely point out that if a part of the exhaust system cannot be touched then it is shielded.

[Boatgypsy]

Yes, I have read the requirement, and I note that the BSS documentation provides no explicit definition of what shielding is.

 

In the absence of such explicit information, I would have to conclude that I might draw upon the meaning of "shielding" in other safety requirements as being instructive.

 

As such, I look to such documents as my trust old 16th edition book, and conclude that provided a part is positioned such that no person is able to touch it without the use of tools to remove some other part, it is "shielded"

Ah right, so in your case we are talking about some part of the exhaust system that is placed where it is shielded by "some other part". This part completely prevents someone from physically touching the exhaust without, as you say, removing it with tools. Surely we are in agreement that your exhaust is shielded.

 

But in your first post you suggested that the exhaust was shielded merely because it was hard to reach.

 

In reality many boat owners feel that they don't need to shield or lag their exhausts, simply because they would have to get down the engine hole and reach around the engine to touch them.

Edited October 26, 2010 by Boatgypsy

[Boatgypsy]

Dave, perhaps you have not followed the thread from the start. I was responding to this post.

I'm not surprised it rankles. Ours is uninsulated and is much less than two feet under the counter, and it passed fine!

 

Richard

I was suggesting that the examiner who passed his installation had misinterpreted the requirements. A statement I would stand by.

[carlt]

You are young, Grasshopper, but you will learn.

[mayalld]

Dave, perhaps you have not followed the thread from the start. I was responding to this post.

 

I was suggesting that the examiner who passed his installation had misinterpreted the requirements. A statement I would stand by.

 

Yes, I have followed the thread from the start, and I was aware of the specific example quoted.

 

Your response, however, moved the discussion from the specific to the abstract, and made an incorrect assertion about the abstract case.

[Boatgypsy]

You are young, Grasshopper, but you will learn.

It's very nice at my age to be considered young, and I will either learn or hurt my head banging it on walls

[mayalld]

You are young, Grasshopper, but you will learn.

 

Do you have evidence to support that assertion?

[carlt]

It's very nice at my age to be considered young, and I will either learn or hurt my head banging it on walls

You've got a shiny new inspector's cap and I'm impressed by your enthusiasm but your contributions to this thread show that the edges need to be knocked off and you need to learn that common sense has to be taken to a BSS inspection, as well as the tick list.

 

My criteria for an adequately shielded exhaust?

 

Can I reach to wrap some lagging around it? If the answer is "Not easily" then it is adequately shielded.

 

Do you have evidence to support that assertion?

In experience?

 

Yes...This thread (and the other one about petrol) is my evidence that he is an enthusiastic "young" inspector who has learnt the bits written down but now needs to learn to apply the rules practically.

[mayalld]

In experience?

 

Yes...This thread (and the other one about petrol) is my evidence that he is an enthusiastic "young" inspector who has learnt the bits written down but now needs to learn to apply the rules practically.

 

I was referring (slightly tongue in cheek) to the assertion "you will learn"

[FORTUNATA]

I had a similar experience where an examiner seemed to be a bit of a jobsworth so to speak. Seemed to me like he was missing the bigger issues and doing stuff like measuring vents with a tiny tape measure. The main point is boats ought to be built to standard pure and simple so the boat owner doesn't have to be stressed over various issues.

Actually, I prefer to be guided by common sense rather than rules for rules sake. Take my gutterings. I noticed recently they need welding by rights because you can only imagine the devastation caused by boards collapsing when the engine is running below. Not that that's likely but you need to be safe and sure.

For me the other main issues are boat stoves and gas.

If there's a genuine reason why your boat is being subjected to excessive regulation you can actually appeal, if you can show it's passed examinations before. Just take care of the obvious stuff.

 

You are quite right.

 

The silly part is that I did buy the book, and I did go through it!

Unfortunately I had the idea in the back of my mind that anything that appertained to the boat as initially built must be ok as the boat builder would have got it right. I didn't bother to look at those items.

However for a sailaway the builder is not specifically building to the BSS specification as it (the boat) is clearly incomplete.

My builder did warn me that somethings might need to be done, for example, removing the tap handle on the fuel drain cock, but in the excitement of that final pre-launch chat there was far too much detail for me to remember it all, and I think it probably did include the possibility of needing to lag the silencer. I hate being old!

 

I can have no grumble with it being failed, that was my fault as the rules are clear. My grumble is with the rule itself and even there it is mostly irritation rather than scientific disagreement.

[Boatgypsy]

So your view is that an examiner who sticks to the regulations is a "jobsworth" but an experienced and trustworthy examiner is one who will let you get away with whatever you ask him to ignore, as long as he gives you your certificate without question. I'm sure this is a widely held view.

 

I'm not sure where this idea that I am young has come from - I presume it's my good looks in my profile pic, but I'm certainly looking at the wrong side of fifty. And yes I have just passed the boat safety examiners training course, but that is following on from many years of experience of using and working on boats both in terms of repairs, maintenance and fitting out.

 

My knowledge of the BSS hasn't just come about in the last two weeks, I've been working with it as a marine engineer since it came into being. But given that I now have a formal qualification in the subject I do feel able to speak with some authority, wheras before I might have left it to others.

 

There is a frustration in the BSS that some examiners are not applying the criteria as strictly as they should and we all know of cases where that is true. There are some instances of examiners who get caught turning a blind eye and those examiners do get removed from the scheme. I think it worth remembering that if an examiner passes something when it should not have passed and an accident later results, it will be the examiner who is held to account, not the stupid boater who burnt himself to death. Examiners remain accountable for seven years after the date of the examination - even if they have left the scheme. We have to carry very heavy insurance to cover any possible claim against us.

 

I personally know of an examiner who is currently being investigated by the Police after a boat death - the records of his examination will be gone through with a fine toothcomb to make sure that he stuck to the letter of the regulations. Would any of you want to be held to have been criminally negligent for giving a boat a certificate when it shouldn't have had one? I should add that I have no reason to think that this examiner was anything other than professional.

 

Personally, I would rather have my boat examined by someone who doesn't allow me to get away with doing something risky or stupid, even if it does mean I have to spend a bit of money putting something right.

 

I can assure you that I will not be relaxing my standards at any point in my career.

[cotswoldsman]

 

 

Personally, I would rather have my boat examined by someone who doesn't allow me to get away with doing something risky or stupid, even if it does mean I have to spend a bit of money putting something right.

 

 

 

I have not read the complete thread but have to agree I would rather have my boat examined by someone who sticks to all the criteria.

[carlt]

 

Personally, I would rather have my boat examined by someone who doesn't allow me to get away with doing something risky or stupid, even if it does mean I have to spend a bit of money putting something right.

 

I do not see how you could convince me that not lagging an inaccessible bit of exhaust pipe is either risky or stupid....unlike blocking up vents which is allowed, under the present BSS.

 

Could you tell me what other applications, by private individuals, of engines, requires the exhaust to be completely lagged?

 

I have, on a number of occasions, scalded myself slightly, on my car exhaust, yet I see no requirement for lagging, in the MOT and possibly by sheer luck, I am still alive to tell the tale.

[Boatgypsy]

I do not see how you could convince me that not lagging an inaccessible bit of exhaust pipe is either risky or stupid....unlike blocking up vents which is allowed, under the present BSS.

 

Could you tell me what other applications, by private individuals, of engines, requires the exhaust to be completely lagged?

 

I have, on a number of occasions, scalded myself slightly, on my car exhaust, yet I see no requirement for lagging, in the MOT and possibly by sheer luck, I am still alive to tell the tale.

I don't expect to be able to convince you Carl. I suspect you are someone who holds very strong points of view and doesn't change them unless forced by circumstances. Maybe you won't be convinced until there's an incident or accident on your boat. Maybe there never will be and your views will remain entrenched.

 

However, you may well find that if and when you have a BSS inspection, your boat will fail because because the exhaust isn't satisfactorily lagged or shielded - as well, perhaps as a non standard fuel system.

 

There will be many applications where engines exhausts are not lagged - but then the BSS does not apply to them. I'm afraid, like it or not there is a BSS, it is mandatory and you will have to comply with it if your boat is on waters covered by BSS. If you disagree with me, or any other examiner on a fail item, you have the right to appeal it, but it is unlikely that an appeal would be upheld when the wording of the requirement is very clear.

 

Just for the sake of clarity, here it is again:

 

"2.15.2 Are exhaust system components effectively cooled, lagged or shielded?

 

'Dry' exhaust systems, or those parts of 'wet' exhaust systems between the manifold and the water injection elbow, must be effectively lagged or shielded.

 

Lagging must be free of signs of damage or deterioration, and must not be loosely fitted.

 

Lagging or shielding must provide complete coverage.

 

Applicability - all parts of 'dry' exhaust systems must be lagged or shielded including silencers, silencer ends and system joints/connections, except for manifolds and flexible exhaust pipe sections, which do not."

 

I've highlighted the significant word in case you missed it.

 

Interestingly, insurance companies are now using non-compliance as a way to wriggle out of claims, but hey - it's all about personal responsibility

[carlt]

 

"2.15.2 Are exhaust system components effectively cooled, lagged or shielded?

 

'Dry' exhaust systems, or those parts of 'wet' exhaust systems between the manifold and the water injection elbow, must be effectively lagged or shielded.

 

Lagging must be free of signs of damage or deterioration, and must not be loosely fitted.

 

Lagging or shielding must provide complete coverage.

 

Applicability - all parts of 'dry' exhaust systems must be lagged or shielded including silencers, silencer ends and system joints/connections, except for manifolds and flexible exhaust pipe sections, which do not."

 

I've highlighted the significant word in case you missed it.

 

What you fail to take on board is that shielding something is rendering it inaccessible. If the exhaust is inaccessible then it is shielded.

 

I have no problem with complying with the BSS despite its shortcomings but if some jobsworth came along and told me that I had to lag an exhaust that was already adequately shielded, by the structure of the boat, he quite simply would not be paid and sent on his way.

 

I have yet to have a boat fail a BSS inspection, despite never having lagged an exhaust that is adequately shielded by the boat's structure.

[RLWP]

2.15.2 Are exhaust system components effectively cooled, lagged or shielded?

 

What about that word then. If you take it out, you have your argument on a plate. With that word in, the circumstances change the effectiveness. If you can't touch it, and it has no lagging, it is still effectively lagged, because you can't touch it.

 

Good job this stuff has no words in it that require judgement, like effective

 

Richard

[Boatgypsy]

2.15.2 Are exhaust system components effectively cooled, lagged or shielded?

 

What about that word then. If you take it out, you have your argument on a plate. With that word in, the circumstances change the effectiveness. If you can't touch it, and it has no lagging, it is still effectively lagged, because you can't touch it.

 

Good job this stuff has no words in it that require judgement, like effective

 

Richard

 

No, I would say that the word effectively means that whatever arrangement you have, must have the same effect as if it were lagged or shielded. An example might be boxing around the exhaust which prevents it being accessed - which is, in effect, shielding.

 

What would not be acceptable is an exhaust that has no protection other than a reliance on someone not wanting to touch it or having arms a bit too short, or someone with a lack of spinal flexibility so they can't bend down far enough.

 

Strangely I think we may be coming to an understanding here, but , correct me if I'm wrong Carl, you seem to be using this word 'inaccessible' instead of the more obvious word 'shielded'.

 

'Inaccessible' would mean the same as 'shielding' if you intend it to mean - cannot be accessed without removing some part or structure. But if it just means - looks like it might be out of reach - then it doesn't. If you think the two words mean the same thing, why not just stick to the wording under discussion, ie, that in the BSS requirement.

 

Don't you just love pedantry and semantics!

 

What you fail to take on board is that shielding something is rendering it inaccessible. If the exhaust is inaccessible then it is shielded.

No, I haven't! Never even suggested it!

Edited October 26, 2010 by Boatgypsy

[carlt]

.

 

Strangely I think we may be coming to an understanding here, but , correct me if I'm wrong Carl, you seem to be using this word 'inaccessible' instead of the more obvious word 'shielded'.

 

 

You're wrong. I used the word "inaccessible" because you don't seem to understand the term "shielded".

 

I used to design plant in the high performance textile industry. All rollers and nips had to be "adequately shielded", so that people didn't get sucked into the machinery.

 

This meant that the rollers at the front of the machine had to have guards and shields fitted, quite a tricky design problem, when you are trying to feed extremely fragile fibres through.

 

Of course the saving grace was that guards were not required for the rollers deeper within the plant...because they were inaccessible.

 

There is no point trying to convince you of this point but I have never had a boat fail a BSS, in nearly 30 years of inland boating (including boats I have fitted out, professionally) and, if someone came along with your attitude, they would have wasted their journey and I would get another inspector willing to combine the rule book with common sense, to give a fair assessment of my boat.

Edited October 26, 2010 by carlt

[RLWP]

<snip>

 

What would not be acceptable is an exhaust that has no protection other than a reliance on someone not wanting to touch it or having arms a bit too short, or someone with a lack of spinal flexibility so they can't bend down far enough.

 

<snip>

 

Then your interpretation of "effectively" differs from our boat inspectors interpretation. I have a certificate to prove that

 

Richard

 

Blimey, I've been certified

[Boatgypsy]

You're wrong. I used the word "inaccessible" because you don't seem to understand the term "shielded".

 

I used to design plant in the high performance textile industry. All rollers and nips had to be "adequately shielded", so that people didn't get sucked into the machinery.

 

This meant that the rollers at the front of the machine had to have guards and shields fitted, quite a tricky design problem, when you are trying to feed extremely fragile fibres through.

 

Of course the saving grace was that guards were not required for the rollers deeper within the plant...because they were inaccessible.

 

There is no point trying to convince you of this point but I have never had a boat fail a BSS, in nearly 30 years of inland boating (including boats I have fitted out, professionally) and, if someone came along with your attitude, they would have wasted their journey and I would get another inspector willing to combine the rule book with common sense, to give a fair assessment of my boat.

 

Well as I'm obviously intellectually challenged, perhaps you can enlighten me as to the true meaning of the word shielded, because, sad idiot that I am I always thought it meant, as I have already stated, a protective barrier - something placed around or in front of the thing to be protected - shield, from scyld- an Anglo Saxon word for a piece of armour held in front the body to deflect blows.

 

I'm starting to get the impression that you like to argue for the sake of it, rather than to get to a better understanding of something. On here that might be acceptable, but if I had been engaged to inspect your boat and you had been so belligerant, I would have declined the pleasure and walked away.

 

Then your interpretation of "effectively" differs from our boat inspectors interpretation. I have a certificate to prove that

 

Richard

 

Blimey, I've been certified

Yes! Possibly!

 

Are you prepared to say clearly that your exhaust is not effectively lagged or shielded, but you still got a certificate? I'm just interested.

Edited October 26, 2010 by Boatgypsy

[RLWP]

<snip>

 

Are you prepared to say clearly that your exhaust is not effectively lagged or shielded, but you still got a certificate? I'm just interested.

 

Unfortunately I don't have a picture to support this

 

The exhaust silencer is tucked up under the counter towards the left side of the boat and neither this, nor the pipe to the hull is lagged, shielded or insulated. The flexible pipe from the silencer to the engine is lagged. So, the part that you could come into contact with in normal use has additional shielding, and the inaccessible part is not.

 

The inspector specifically noted the silencer and explained that it would pass because of its position

 

Richard

Edited October 26, 2010 by RLWP