BSS Failure

[mayalld]

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.

 

Such a pity that your understanding of what it means is flawed

[carlt]

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

rather like a lump of boat, perhaps?

 

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.

 

I get the same impression about you, although you would also be wearing the shiny cap, tapping your clipboard, judgementally.

 

I engage a BSS inspector based on recommendation about how helpful they are and how they have an understanding of the huge variety of boats that the BSS fails spectacularly to cover.

 

Shielding of the exhaust system being mandatory and adequate ventilation being advisory are two examples of just how ridiculously out of touch the BSS is.

 

You are far more likely to burn yourself on the woodburner or kettle, than an exhaust, buried under the back deck, out of harm's way, yet the BSS doesn't take these risks to life and limb into account.

 

The BSS should be rewritten so that shiny capped jobsworths can't say "Actually, I think you'll find..." spouting chapter and verse about something that should be common sense, not "nanny knows best".

Edited October 26, 2010 by carlt

[Boatgypsy]

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

 

Thanks for that Richard, I now have a good idea of what you have. Do you think it would be fair to say of the "inaccessible part" that it could not be touched without removing some other part, or would it be possible, for instance if you got down in the engine hole to reach under the counter that you could touch it?

 

I ask because we were specifically told that any part of an exhaust system that could be reached, even though it might not be 'easily' accessible, would need to be lagged or shielded. More specifically on my final assessment I was examining a boat where the easily reached part of the exhaust was lagged - between the engine and where the exhaust went under the counter - but the silencer and it's connection to the hull, which could be reached if I got right down with my head and shoulders under the counter was not lagged. The senior and experienced examiner who was assessing me confirmed that this would fail.

 

As I've previously said the BSS office have expressed concern that some examiners are passing insufficiently lagged or shielded exhausts, an issue which they are trying to address.

 

I'm not in any way passing comment on what is right or wrong about the requirements, but I am clear about the way in which I have been told to interpret the BSS requirement on this.

[RLWP]

Thanks for that Richard, I now have a good idea of what you have. Do you think it would be fair to say of the "inaccessible part" that it could not be touched without removing some other part, or would it be possible, for instance if you got down in the engine hole to reach under the counter that you could touch it?

 

I ask because we were specifically told that any part of an exhaust system that could be reached, even though it might not be 'easily' accessible, would need to be lagged or shielded. More specifically on my final assessment I was examining a boat where the easily reached part of the exhaust was lagged - between the engine and where the exhaust went under the counter - but the silencer and it's connection to the hull, which could be reached if I got right down with my head and shoulders under the counter was not lagged. The senior and experienced examiner who was assessing me confirmed that this would fail.

 

As I've previously said the BSS office have expressed concern that some examiners are passing insufficiently lagged or shielded exhausts, an issue which they are trying to address.

 

I'm not in any way passing comment on what is right or wrong about the requirements, but I am clear about the way in which I have been told to interpret the BSS requirement on this.

 

From your description, your instructor's interpretation of the rule would fail our exhaust

 

Richard

[Boatgypsy]

rather like a lump of boat, perhaps?

 

 

I get the same impression about you, although you would also be wearing the shiny cap, tapping your clipboard, judgementally.

 

I engage a BSS inspector based on recommendation about how helpful they are and how they have an understanding of the huge variety of boats that the BSS fails spectacularly to cover.

 

Shielding of the exhaust system being mandatory and adequate ventilation being advisory are two examples of just how ridiculously out of touch the BSS is.

 

You are far more likely to burn yourself on the woodburner or kettle, than an exhaust, buried under the back deck, out of harm's way, yet the BSS doesn't take these risks to life and limb into account.

 

The BSS should be rewritten so that shiny capped jobsworths can't say "Actually, I think you'll find..." spouting chapter and verse about something that should be common sense, not "nanny knows best".

So, we finally have it - basically it's all about you not liking the fact that you have to abide by some safety regulations that you don't agree with. You only like boat examiners who agree with you and turn a blind eye to things. You deal out personal insults to those who take their responsibility seriously.

 

I've not claimed the BSS is perfect, in fact there's lots in it that I would like to see re-written, however, I've decided to take on a necessary job and do it to the best of my ability, working with a flawed system because there's no such thing as a perfect one. If doing my best to help make sure people don't get injured or die whilst enjoying their boats makes me a shiny capped jobsworth then I'm happy to accept that.

[mayalld]

So, we finally have it - basically it's all about you not liking the fact that you have to abide by some safety regulations that you don't agree with. You only like boat examiners who agree with you and turn a blind eye to things. You deal out personal insults to those who take their responsibility seriously.

 

OOOH, handbags!

 

The problem is that you present the BSS requirements as if they were absolutes, and assert that they are incapable of interpretation (and indeed need no interpretation).

 

In actual fact, part of what a good BSS examiner will do is look at a boat and ask "does that arrangement achieve what the BSS requires, and if not, how can it readily do so"

 

So, in the case in point, if the exhaust is sufficiently protected from accidental contact that somebody entering the engine room to perform any routine task that might be carried out, then the requirement is met.

 

There are some examiners who are helpful, who set out to pass a boat and will fail it only if it has unresolvable problems, and others that set out to fail a boat, and proceed looking for any shadow of doubt that can be used to fail a boat.

[Boatgypsy]

From your description, your instructor's interpretation of the rule would fail our exhaust

 

Richard

You see my point? If I was doing what the likes of Carl would have me do, I would be directly ignoring what I have just been trained to do.

 

There will always be grey areas in doing examinations and next time another examiner might fail your exhaust. It would then be up to you to appeal the decision to get a definitive answer from the BSS technical guy. That could go either way and it may be that a whole series of appeals would lead to a change in the wording of the requirements. But we have to work with the requirements as they are. It's very well for Carl to say that common sense should prevail, but his common sense isn't necessarily someone elses, and if it directly conflicts with the requirements, our job is to fail it on that point so that the conflict can be scrutinised.

[RLWP]

You see my point? If I was doing what the likes of Carl would have me do, I would be directly ignoring what I have just been trained to do.

 

There will always be grey areas in doing examinations and next time another examiner might fail your exhaust. It would then be up to you to appeal the decision to get a definitive answer from the BSS technical guy. That could go either way and it may be that a whole series of appeals would lead to a change in the wording of the requirements. But we have to work with the requirements as they are. It's very well for Carl to say that common sense should prevail, but his common sense isn't necessarily someone elses, and if it directly conflicts with the requirements, our job is to fail it on that point so that the conflict can be scrutinised.

 

Which is a huge pain in the arse for a boat owner as the difference lies in different instructors interpretation of "the rules"

 

Where's Rob from BSS when you need him

 

Richard

[carlt]

So, we finally have it - basically it's all about you not liking the fact that you have to abide by some safety regulations that you don't agree with. You only like boat examiners who agree with you and turn a blind eye to things. You deal out personal insults to those who take their responsibility seriously.

 

Rubbish! I have used different examiners, on different boats and never had a problem with their, or my, interpretation of the regulations.

 

No blind eye has ever been turned, or expected to be.

 

Your blinkered explanations, and over officious delivery, are what lead me to gain the impression that you are a jobsworth and your conclusion that I wish a blind eye to be turned, regarding safety matters, clearly shows that you have never read (or understood) any of my posts, on this forum.

 

My boat, which does not require a BSS certificate, meets and exceeds the requirements and would pass an inspection tomorrow.

 

You wouldn't get the job though, because it is plain that you cannot discuss safety issues sensibly, preferring to try to squeeze every situation into a little tick box system that is woefully inadequate, for the job.

 

You see my point? If I was doing what the likes of Carl would have me do, I would be directly ignoring what I have just been trained to do.

 

I have not asked you to ignore your training.

 

Qualifying to do a job should be the start of your education, you treat it like the learning is over.

[Natalie Graham]

 

This is the difference between cool male focus and scatterbrained female 'multitasking'.

 

When our manager at work decided he would make toast in the staff canteen we ended up with the fire brigade in the car park.

[Boatgypsy]

OOOH, handbags!

 

The problem is that you present the BSS requirements as if they were absolutes, and assert that they are incapable of interpretation (and indeed need no interpretation).

 

In actual fact, part of what a good BSS examiner will do is look at a boat and ask "does that arrangement achieve what the BSS requires, and if not, how can it readily do so"

 

So, in the case in point, if the exhaust is sufficiently protected from accidental contact that somebody entering the engine room to perform any routine task that might be carried out, then the requirement is met.

 

There are some examiners who are helpful, who set out to pass a boat and will fail it only if it has unresolvable problems, and others that set out to fail a boat, and proceed looking for any shadow of doubt that can be used to fail a boat.

 

I'm sure your last point is true, but where do you get the argument that only people doing routine tasks should be protected. What about people who are not familiar with boats? What about the person who falls down the engine hole by accident and grabs the unprotected silencer? What about the first time boater who has just bought your boat from you and doesn't expect that particular piece of metal to be hot?

 

I don't believe that I have presented the requirements as being absolutes - there are parts which are written so that they have to be interpreted precisely and other parts that are open to wide interpretation. If the intention of this particular requirement was intended to allow people to do what they want, it would say something like "if in the opinion of the examiner the exhaust is adequately protected", but it doesn't. It repeatedly uses the word "must".

 

Oh, and whilst I'm happy to engage in vigourous debate I draw the line at having to put up with personal insults, so until Carl learns to play nice, I won't be responding further to him.

[carlt]

What about the person who falls down the engine hole by accident and grabs the unprotected silencer?

They would probably have already lost the arm, having caught it in the unguarded pulley wheel (not covered by the BSC but far more likely to be in reach, than an exhaust shielded by the back deck) so they won't be too concerned, if they manage to get past the manifold (hotter than the exhaust but not required to be shielded), without burning their, now useless, arm and manage to reach the exhaust (though their face will probably be in contact with the pulley wheel, by this time).

 

Oh, and whilst I'm happy to engage in vigourous debate I draw the line at having to put up with personal insults, so until Carl learns to play nice, I won't be responding further to him.

So it's okay to accuse me of colluding and expecting a blind eye to be turned, yet I cannot comment on the jobsworth tone of your posts?

Edited October 26, 2010 by carlt

[jelunga]

I am going to dip my foot in the water here.

 

1) I do not have a copy of the BSS manual to hand - it is on the boat

2) I am not commenting on the interpretation of "the rules"

 

BUT

 

If the BSS says that the exhaust system .....blah blah blah.... HAS to be lagged, even when the system is in such a place that to touch it in the unlagged position would require a deliberate act and a degree of contortionism, then the BSS is an ASS. Talk about Nanny state.

 

If I want to deliberatly put my hand on a hot unlagged exhaust then I should be allowed to do it. It is like saying that the manifold and down pipe on my car should be lagged because I might lift the bonnet and touch the exhaust pipe. God forbid, I might even lift the bonnet and get my tie stuck in the fan belt.

 

It is time that Government and authority stopped trying to wrap us in cotton wool and let us make our own informed judgements. By all means, say it is recommended to be lagged, but compulsory lagging? Sound way over the top to me.

 

K

Edited October 26, 2010 by jelunga

[carlt]

 

If the BSS says that the exhaust system .....blah blah blah.... HAS to be lagged, even when the system is in such a place that to touch it in the unlagged position would require a deliberate act and a degree of contortionism, then the BSS is an ASS.

It doesn't, that is just how Boatgypsy is interpreting it.

 

If a piece of machinery is inadvertently guarded, by another piece of that machine, not specifically designed for the job, then that piece of machinery does not need to be guarded again.

 

The BSS rule allows for this by asking "2.15.2 Are exhaust system components effectively cooled, lagged or shielded?".

[RLWP]

<snip>

What about the person who falls down the engine hole by accident and grabs the unprotected silencer?

<snip>

 

That is not possible in our set up

 

Richard

[MoominPapa]

Maybe we've all got the wrong end of the stick here: it could be that the hazard being mitigated is not burns to people but fire. A silencer tucked under the back deck it not likely to come into contact with people, but it may well come into contact with cables, rubber hoses, stored cans of oil, grease and paint, blown leaves, etc etc. Unlagged, it's quite capable of starting a fire with any of those.

 

MP.

[n.b.Goldie]

Just put my five pence worth in:

 

As is have said before in similar discussions re the BSS, it, the BSS in not about keeping us stupid, dumb-headed, incompetent boaters safe from harm it is everything to do with job-creation. It is an industry concerned only with its own survival. Hope it goes the way of HIPs.

 

Gas, ventilation, electrickery and 'hot things' are just as much an issue in houses but we don't have to have them inspected periodically do we? Yet?

 

The BSS and MoT tests for road vehicles are not comparible because the MoT is concerned with keeping fast-moving vehicles as mechanically sound as reasonably possible so that collisions etc due to mechanical failure are kept to a minimum whereas the BSS does not at all concern itself with the mechanical soundness of the boat.

 

When are caravans going to get their CSS?

 

Rant over, thanks for reading it.

 

Ditchdabbler

[alan_fincher]

Maybe we've all got the wrong end of the stick here: it could be that the hazard being mitigated is not burns to people but fire. A silencer tucked under the back deck it not likely to come into contact with people, but it may well come into contact with cables, rubber hoses, stored cans of oil, grease and paint, blown leaves, etc etc. Unlagged, it's quite capable of starting a fire with any of those.

 

MP.

Excuse me, but I don't believe I have.

 

I have never assumed the primary reason was to prevent skin burns, (though I'm grateful of lagging on mine, when I have to crawl under the counter).

 

The wording that says...

 

Notes – Signs of heat damage on structures or components adjacent to exhaust systems may indicate that the exhaust lagging or shielding is not effective.

 

has always led me to believe that much of the requirement is supposed to be to do with potential fire risk.

 

The document does not say "Large red burns on your arms may indicate that the exhaust lagging or shielding is not effective".

[Timleech]

Just put my five pence worth in:

 

 

The BSS and MoT tests for road vehicles are not comparible because the MoT is concerned with keeping fast-moving vehicles as mechanically sound as reasonably possible so that collisions etc due to mechanical failure are kept to a minimum whereas the BSS does not at all concern itself with the mechanical soundness of the boat.

 

Ditchdabbler

 

I drew a comparison with the MOT test simply because they are 'checklist' tests designed for minimal discretion from the examiner. I don't think any other comparison has been drawn between them in this thread, but I can't remember what's been in every post.

 

Boatgypsy does seem to be taking the 'minimal discretion' to the extreme, but that's to be expected when he has only just finished the indoctrination course

 

 

Tim

[alan_fincher]

Gas, ventilation, electrickery and 'hot things' are just as much an issue in houses but we don't have to have them inspected periodically do we? Yet?

 

Are they really though ? I'm not convinced.

 

Who may do gas work, (and now to a very large extent electrical work), in houses is highly regulated, so there is probably less scope for a well meaning amateur to cock something up.

 

Also, slightly tongue in cheek, we do not go bashing our houses into other houses and other structures.

 

I could never defend the current BSS totally because some of the requirements are daft, and some of the emphases seem in the wrong place to me. However, I don't think the fact that it has some flaws is in itself a reason why the principle of a basic level of certification is a silly idea.

 

If I think back to some of the things going on in boats 40 years ago, including things I happily did myself, I actually consider myself quite lucky to have got away with it. I'm very happy to now have the BSS, if it means I'll not have to share locks with boats with the gas "systems" or fuel "systems" that were commonplace then!

[Dave-Shrop]

 

One would think so but there have been a lot of problems recently with supposidly RCD compliant boats not meeting BSS requirements when first examined by BSS. This is currently being addressed.

 

RCD does not require exaust to be lagged if engine compartment is covered.

 

5.1.3 Exposed parts

Unless the engine is protected by a cover or its own enclosure, exposed moving or hot parts

of the engine that could cause personal injury shall be effectively shielded.

 

David

[MoominPapa]

Excuse me, but I don't believe I have.

 

I have never assumed the primary reason was to prevent skin burns, (though I'm grateful of lagging on mine, when I have to crawl under the counter).

OK, Fincher, A is exempted from admonishment Everybody else was arguing as if the only reason for lagging was to avoid burns to people.

 

Actually, the "heat damage to structure" thing is relevant to my boat. After 20 years the veneer on the ply lining the roof immediately above the expansion box is starting to delaminate. Adding heat-resistant board in that location is on the list, pending a sufficiently large tuit surplus.

 

MP.

[RLWP]

OK, Fincher, A is exempted from admonishment Everybody else was arguing as if the only reason for lagging was to avoid burns to people.

 

Actually, the "heat damage to structure" thing is relevant to my boat. After 20 years the veneer on the ply lining the roof immediately above the expansion box is starting to delaminate. Adding heat-resistant board in that location is on the list, pending a sufficiently large tuit surplus.

 

MP.

 

Can I be excused too? I was only pointing out my exhaust has no lagging and passed, not discussing the whys and wherefores of the need for lagging. I'm merely obstreperous, not incorrect

 

Richard

[carlt]

I wish to be excused on the grounds that the fresh faced BSS inspector first mentioned burning human body parts, and I saw no reason to disagree with him.

[MoominPapa]

Can I be excused too? I was only pointing out my exhaust has no lagging and passed, not discussing the whys and wherefores of the need for lagging. I'm merely obstreperous, not incorrect

Add "I'm merely obstreperous, not incorrect." to you signature and you can be forgiven anything, I think.

 

MP.

 

I wish to be excused on the grounds that the fresh faced BSS inspector first mentioned burning human body parts, and I saw no reason to disagree with him.

One hopes that the fresh-faced one will see the error of his ways and forthwith threaten the non-compliant with a fiery fate rather than with burns to the skin.

 

MP.