Carbon Monoxide Alarm Petition

[Rob@BSSOffice]

On 02/02/2018 at 13:19, Naughty Cal said:

Now I know that some of you will not agree with this petition but some of you may be interested.

https://petition.parliament.uk/petitions/207382

Thanks P, was not aware of this....

So for private boats, priavtely managed in private use, i.e. private leisure and pleasure or owner-occupied domiciles, the the navigation authorities (via BSS Requirements) does not regulate on matters related to first party issues, carbon monoxide poisoning being the prime example. The owner/skipper has that burden of responsibility. The navigation authorities regulate on the risks that a boat presents to other people and property surrounding it (fire, explosions, pollution)

However, Examiners still have commonlaw duties of care and the the HSE advised us that we should continue to check and advise on risks such as faulty flues, appliances and under-ventilation that could lead to carbon monoxide dangers - hence the checks we call advice checks related to those issues.

The BSS is also asked to devise, produce and promote CO safety tips and advice - hence my occaisional outbust hereabouts offering the best information we can lay our hands on.

In 2016/17 the BSS Technical and Advisory committees have been tasked with the job of the 'consideration of alarms (CO & fire) on private boats'.

There are three basic scenarios

1. no change
2. introduce advice checks
3. introduce requirements with checks to meet BSS certification

In addition, these basics can be mixed and matched to certain circumstances like the hire boat checks and those relating to buildings. For example hire boats only have to have a working, suitable CO alarm on a hire boat with a solid fuel appliance. Hire boats only have to have suitable working smoke alarms when there is overnight accomodation i.e. not a day boat.

As a hypothetical thought, it could be said that only boats with petrol engines in use (generators/outboards/inboards) need CO alarms as petrol exhaust fumes have killed the last nine boat victims on pleasure craft.

However gas appliance have a record in fatal and non-lethal incidents and solid fuel stoves have also been cited in inquests as well as regularly featuring in alarm actuations we see on social media.

So it would be good to resist knee-jerk reactions either way to teh petition. In preceding posts there have been some very good and thoughtful posts made for and against the petition as written. It is those thoughts and all the shades of grey in between that need to feed into the consideration when it starts.

As such, I recommend you feed your thoughts to NABO, IWA, RYA, AWCC, TBA (the Boating Assoc) as and when asked on whatever comes out of the discussions.

I hope this helps.

Rob

[Alan de Enfield]

1 hour ago, Rob@BSSOffice said:

.......... for private boats, priavtely managed in private use, i.e. private leisure and pleasure or owner-occupied domiciles, the the navigation authorities (via BSS Requirements) does not regulate on matters related to first party issues, carbon monoxide poisoning being the prime example. The owner/skipper has that burden of responsibility. The navigation authorities regulate on the risks that a boat presents to other people and property surrounding it (fire, explosions, pollution)

It appears that a large number of boaters are unaware of this.

The question as to if the BSS should is, to my mind, a crucial one - but - it appears that many see it as an infringement of their 'rights'.

My feelings are that the BSS should focus on all safety aspects and worry less about a pump-out fitting being correctly labelled, or that boat battery supports should be able to withstand a 30 degree heel, (which, for the waters in question the risk must be a factor 10^N when compared to the possibility of running a generator on the rear deck)

The BSS has so much potential for really improving safety but it needs to 'bite the bullet'.

[TheBiscuits]

4 hours ago, Alan de Enfield said:

My feelings are that the BSS should focus on all safety aspects and worry less [...] that boat battery supports should be able to withstand a 30 degree heel, (which, for the waters in question the risk must be a factor 10^N  [...]

Whilst underway on flat water, probably.

When a pound drains overnight and a flat bottomed boat tips over sideways though that degree of heel becomes much less unlikely.

Or if someone hangs a boat on an angle in a lock, do you think the resulting electrical fire would help the crew keep calm and carry on?

 

[MtB]

On 05/02/2018 at 23:41, TheBiscuits said:

Whilst underway on flat water, probably.

When a pound drains overnight and a flat bottomed boat tips over sideways though that degree of heel becomes much less unlikely.

Or if someone hangs a boat on an angle in a lock, do you think the resulting electrical fire would help the crew keep calm and carry on?

 

 

Do crew count as third parties? (I.E. the people the BSS is claimed to exist to protect.)

Notwithstanding all this, the regulations would command more respect if they were framed as a result of actual incidents resulting in harm to third parties. 

I'd be most interested to see the stats on harm caused to third parties by batteries coming loose in boats heeling to 30 degrees. I bet there are none. 

[MtB]

I'd also like to see the stats on third parties injured or killed by missing labels on pump-out caps.

[Guest]

6 minutes ago, Mike the Boilerman said:

Notwithstanding all this, the regulations would command more respect if they were framed as a result of actual incidents resulting in harm to third parties. 

I thought the whole point of the BSS was to prevent possible and reasonably foreseeable incidents.

Not to respond to multiple incidents that already occurred.

[MtB]

On 06/02/2018 at 00:39, MJG said:

I thought the whole point of the BSS was to prevent possible and reasonably foreseeable incidents.

Not to respond to multiple incidents that already occurred.

 

Where did you get that idea from?

Rob already told us earlier in the thread it is for prevention of harm to third parties.

[Guest]

52 minutes ago, Mike the Boilerman said:

 

Where did you get that idea from?

Rob already told us earlier in the thread it is for prevention of harm to third parties.

I got the idea from the fact that preventing harm to third parties is acheviable  by anticipating how that harm could come to them.

Now you may want to go off on one of your late night word and sentence twisting excursions Mike but my meaning is pretty clear.

Edited February 6, 2018 by MJG

[MtB]

On 06/02/2018 at 01:36, MJG said:

I got the idea from the fact that preventing harm to third parties is preventable by anticipating how that harmmcould come to them.

Now you may want to go off on one of your late night word and sentence twisting excursions Mike but the meaningbis pretty clear.

 

Ah, so you made it up then.

Decent of you to admit it.

[Guest]

19 minutes ago, Mike the Boilerman said:

 

Ah, so you made it up then.

Decent of you to admit it.

As I said, late night word and sentence twisting.

[MtB]

No, you can't explain where you got that idea from and you are trying to swerve the point.. How is that me twisting what you said? YOU are the one twisting and spinning. 

[Guest]

1 minute ago, Mike the Boilerman said:

No, you can't explain where you got that idea from and you are trying to swerve the point.. How is that me twisting what you said? YOU are the one twisting and spinning. 

Keep spinning Mike, you have form and are well renowned for it.

[MtB]

On 06/02/2018 at 02:08, MJG said:

Keep spinning Mike, you have form and are well renowned for it.

 

You are SO easy to wind up!!

[Guest]

Just now, Mike the Boilerman said:

 

You are SO easy to wind up!!

4/10

[MtB]

So back to the point, where did you get the idea from? 

[Guest]

9 minutes ago, Mike the Boilerman said:

So back to the point, where did you get the idea from? 

Common sense Mike, common sense, combined with a bit of logical thinking.

[Naughty Cal]

6 hours ago, MJG said:

Common sense Mike, common sense, combined with a bit of logical thinking.

Common sense isn't quite so common as you might like to think 

[Mike Todd]

8 hours ago, Mike the Boilerman said:

 

Do crew count as third parties? (I.E. the people the BSS is claimed to exist to protect.)

Notwithstanding all this, the regulations would command more respect if they were framed as a result of actual incidents resulting in harm to third parties. 

I'd be most interested to see the stats on harm caused to third parties by batteries coming loose in boats heeling to 30 degrees. I bet there are none. 

The problem with most regulatory environments is that they are formed by successive responses to individual incidents sometimes of varying probability. As a result,  over time, they lack coherence and even can be either  self contradictory impossible to fulfil. What i call the Red Top Reaction is what drives must regulations and not as some like to suggest, an over zealous control freak in Brussels, Westminster or Milton Keynes.

[Alan de Enfield]

8 hours ago, Mike the Boilerman said:

Do crew count as third parties? (I.E. the people the BSS is claimed to exist to protect.)

 

I believe that Rob covered that in his post.

 

15 hours ago, Rob@BSSOffice said:

.....The owner/skipper has that burden of responsibility.

 

[Alan de Enfield]

9 hours ago, MJG said:

I thought the whole point of the BSS was to prevent possible and reasonably foreseeable incidents.

In a previous life, when I 'worked for payment' I was involved in the development of components for the Automotive industry, a common method of product &/or safety improvement was the use of an FMEA (Failure Mode & Effect Analysis) which basically looks at every aspect of the product and looks at how it may fail, then the occurrence (chance of failure) is estimated, then the severity (what is the impact) is estimated and the chance of detection and identification of the root cause.

Typical examples may be :

Item : Brake Pipe Clip Fails, Brake pipe hangs loose under car.

Chance of failure (on a scale of 1-10) = 2

Potential severity (on a scale of 1-10) = 5

Detection = 3

The three numbers are multiplied to give an action rating (2x5x3 = 30)

Every possible feature is considered - a similar clip could be holding the fuel line in the engine bay.

Item Fuel Line Clip Fails, fuel line drops onto exhaust manifold, melts, fuel escapes, fire, passengers killed.

Chance of failure = 2

Potential severity = 10

Detection  = 3

The three number are multiplied to give an action rating (2x10x3 = 60)

 

This can be done for every component and system on a car (boat) and would identify which have the most impact on safety and design changes, this allows a sensible prioritisation of actions, to minimise those risks.

It would be an interesting exercise to do such an analysis on an inland water ways boat.

The BSS checklist is 'almost there' in principle with the boat 'broken down into sections', the addition of a small number of extra categories and the allocation of 'risk assessment' could make it a very useable document for prioritising change.

 

Here is an example taken from an FMEA conducted by a Bank into their ATM

 

Edited February 6, 2018 by Alan de Enfield

[Rob@BSSOffice]

1 hour ago, Mike Todd said:

The problem with most regulatory environments is that they are formed by successive responses to individual incidents sometimes of varying probability.

Not in our case. Otherwise there would have been CO alarms imposed in 2004 and smoke alarms imposed in 2007 responding to some individual incidents. The committees always go back to first principles and test all points. see Alan d E process description.

[Rob@BSSOffice]

1 hour ago, Alan de Enfield said:

In a previous life, when I 'worked for payment' I was involved in the development of components for the Automotive industry, a common method of product &/or safety improvement was the use of an FMEA (Failure Mode & Effect Analysis) which basically looks at every aspect of the product and looks at how it may fail, then the occurrence (chance of failure) is estimated, then the severity (what is the impact) is estimated and the chance of detection and identification of the root cause.

Yes - just like that. Our Technical Committee chair is a NABO member and is a force to behold. In his world there is no room for sloppy thinking and heaven help us (staff) if our papers (or any others) are flawed. The committe will rip them to shreds. And that is exactly as it should be, tested thoroughly.

[Alan de Enfield]

1 minute ago, Rob@BSSOffice said:

Yes - just like that. Our Technical Committee chair is a NABO member and is a force to behold. In his world there is no room for sloppy thinking and heaven help us (staff) if our papers (or any others) are flawed. The committe will rip them to shreds. And that is exactly as it should be, tested thoroughly.

Excellent - pleased to hear it.

It is a very useful business tool.

Now that 'Fire Ratings / Approvals' of buildings are no longer conducted or issued I even used the principle for the Golf Club and Clubhouse to provide evidence of due diligence to the Insurers.

[ditchcrawler]

I think there has been an incident due to fuel being put into the wrong deck fitting

[b0atman]

4 hours ago, ditchcrawler said:

I think there has been an incident due to fuel being put into the wrong deck fitting

an incident not a disaster then ? i got pulled  up for not having a label at filler saying diesel so what else could i put in by mistake "water" What would i be doing oh yes maybe a pump out thinking its a toilet tank .