Consultation opens on proposal for BSS Requirements for CO alarms on boats

[AndrewIC]

24 minutes ago, Chewbacka said:

I have 2 CO alarms but both will need replacing as though they work, they are '-1' not the BS EN 50291-2 as l suspect many are.

 

I also see a lot of argument about placement arising as it it just not clear, for example in the consultation docs it states "wall-mounted at high level at least 150mm below the ceiling height" but later it states that for a sleeping area it should be "an additional carbon monoxide alarm must be provided, located in the “breathing zone”, i.e. near to a bed head." which in my case is going to be low level and not high level.  I can see me moving it up or down the wall for each different BSS examiner.

Also it states it should be "located between 1m and 3m (on plan view) from any stove" so for many narrow boats a second detector will be required as the other end is going to be too far away.

Again the proposed rules are not clear as to what constitutes a door - so if it has a big gap (say 1 inch) at top and bottom for ventilation is that a door for the purposes of this regulation.

 

Whilst I don't like more and more laws and guess this is really a done deal, at least get the words clear. 

We've been here before. Not all -2 certified alarms are certified for use on boats, it's an optional feature. The only way to be sure is to check the detailed certification. I have pointed out to the BSS that their guidance didn't mention this and was ignored.

 

My CO alarm is about two feet from my head when asleep, and that's where it's staying!

 

In my view anyone who doesn't have a CO alarm probably needs their head testing, but testing boaters' heads is beyond the scope of the BSS.

[rowland al]

3 hours ago, Rob@BSSOffice said:

The evidence from the MAIB investigation, other incidents and additional reasearch we are doing  - all in the past 15 months - that shows it is a thrid party party issue.  And this has coincided with evidence coming through from the health sector that CO in small densities may still be harmful.

Thanks for that Rob.

 

Any chance we couild have access to that research? It might help gain support in the proposal.  

 

Also, as most camper vans and caravans have got gas appliances, how come they aren’t subjected to the same ‘rules’? Most have an even more confined space.

 

[StephenA]

So if I'm in my boat and my gas detector goes off in the middle of the night I get up, turn off the gas and open all the windows and doors to let the gas escape and get off the boat and do what ever else is needed.

If my smoke alarm goes off I do what ever I need ( put out fire, exit the boat, call the fire bridge etc).

What do if my CO alarm goes off and I have nothing in my boat producing CO (no gas / solid fuel devices burning)  and its actually coming in from the boat behind.

 

I'm not arguing against detectors but the BSS covers several examples where the CO is coming in from an external source... what are you supposed to do about that at 2 in the morning?

 

Also how reliable are CO detectors if left on an unoccupied boat for a couple of months over winter when they'll get cold / damp?

 

Quote

Where the accommodation space is sub-divided by cabins with door(s), a CO alarm must be located within 10m of each cabin door.

 

How does this work in say a 52 foot boat with a 42 foot internal space which is divided into 3 distinct cabin areas ( living/Kitchen - Bedroom - Back Cabin) Also as the bathroom has a door is one needed in there too? If so how well do CO2 detectors stand up to large amounts of condensation?

 

Section 3.4 states:
 

Quote

 

One alarm is generally sufficient to meet the BSS minimum safety requirement. However, two or more may be required if separate accommodation spaces are separated by doors and are more than 10m from an alarm. 

 

Which implies that a 40 foot space probably needs 2 (one in the kitchen / living area and one in the middle of the sleeping spaces) (and doesn't need one in the bathroom as long as its within 10 metres of an alarm)

 

Or is this going to be another of those situations where you are at the whim of the inspector who will no doubt decide you need more detectors than you have and then offer to sell you one at an inflated price?

 

Quote

BRE made interim recommendations that petrol generators should always be used downwind of the boat, but not upwind of any adjacent boat unless there is a minimum separation of 10 metres.

 

How would you ever work this on a typical canal mooring? It seems to suggest that the right thing to do is ban petrol generators from the canal system.

Edited August 18, 2018 by StephenA

[OldGoat]

I'm suffering from a nasty attack of Deja vu -

When I fitted out our boat -

• There had to be lots of low and high level ventilation - so I cut lots of holes in the doors / hull for low level ventilation and 6 large mushroom ventilators for high level
• not required now
• BS couldn't make up it's mind abut gas pipe size - so I fitted 10? or 12mm copper pipe - just in case
• There bad to be ventilation between cabin spaces - so doors have girt big gaps for this requirement
• Everything has to be labelled - but nobody liked my nice big brass labels.
• battery isolators have to be in the negative feed  (mine seemed logical - positive feeds)
• Fire extinguishers A/B/C with different values for those generally available
• (Reasonable) restrictions on holes in the hull xx above waterline made fitting washbasins / sinks more than 'difficult' - BSS later changed the wording to allow basin height above water level instead.

All the above indicates that BSS regulations - although sensible in concept were and are drawn up by folks who haven't a clue about the environment about which  they  are 'legislating'.

My point is that now Rob@ (and his colleagues who I guess are land based) run the risk of foisting new requirements on inland boaters - where the technology doesn't really exist for the equipment that's needed.

 

I don't have a solution - and neither do they......

 

 

 

[PeterF]

3 hours ago, Chewbacka said:

I have 2 CO alarms but both will need replacing as though they work, they are '-1' not the BS EN 50291-2 as l suspect many are.

 

I also see a lot of argument about placement arising as it it just not clear, for example in the consultation docs it states "wall-mounted at high level at least 150mm below the ceiling height" but later it states that for a sleeping area it should be "an additional carbon monoxide alarm must be provided, located in the “breathing zone”, i.e. near to a bed head." which in my case is going to be low level and not high level.  I can see me moving it up or down the wall for each different BSS examiner.

Also it states it should be "located between 1m and 3m (on plan view) from any stove" so for many narrow boats a second detector will be required as the other end is going to be too far away.

Again the proposed rules are not clear as to what constitutes a door - so if it has a big gap (say 1 inch) at top and bottom for ventilation is that a door for the purposes of this regulation.

 

Whilst I don't like more and more laws and guess this is really a done deal, at least get the words clear. 

Herein one of the issues, if the CO alarm is for protection against CO generated by fuel burning appliances within the cabin, you need to locate them at high level as the hot combustion products rise, however, for CO from adjacent boats you may well need them at low level as the CO containing air may well be entering as cold air through door vents and staying low, until the incoming air is heated.

 

 

[StephenA]

1 minute ago, PeterF said:

Herein one of the issues, if the CO alarm is for protection against CO generated by fuel burning appliances within the cabin, you need to locate them at high level as the hot combustion products rise, however, for CO from adjacent boats you may well need them at low level as the CO containing air may well be entering as cold air through door vents and staying low, until the incoming air is heated.

 

 

Agreed - the whole "where detectors should be installed" is vague and woolly and open to so much interpretation that it will be open to abuse from some BSS examiners.

[StephenA]

22 minutes ago, OldGoat said:

I'm suffering from a nasty attack of Deja vu -

When I fitted out our boat -

• There had to be lots of low and high level ventilation - so I cut lots of holes in the doors / hull for low level ventilation and 6 large mushroom ventilators for high level

I don't have a solution - and neither do they......

 

Remember the fiasco over plastic and metal fuel spill rails, and fuel lines in general?

Edited August 18, 2018 by StephenA

[Chalky]

We’ve had CO alarms and optical smoke detectors on the boat for 10 years. Tend to use standard domestic ones and replace them after about 5 years. Wouldn’t be without them.

 I also have a flammable gas detector in the bilge but don’t tend to use it due to its high current draw.

[Guest]

At last.

[StephenA]

1 minute ago, Chalky said:

 I also have a flammable gas detector in the bilge but don’t tend to use it due to its high current draw.

We had a gas detector sitting mid way between the gas fridge and the cooker when we first got the boat - but it had to be taken out because the BSS inspector said that it's power feed (which was on a 500mA fuse) was "dangerously close" to  the copper gas line (it was about 2 feet away from it). 

[Guest]

7 hours ago, nicknorman said:

Yes but you are not comparing like with like. I agree that hotel boats and hire boats should have alarms, this aligns with HMOs and other rental properties. But owner-occupied houses aren’t required to have alarm no matter the number of family occupants, and thus neither should private narrowboats. It is not a matter of what is good practice, it is a matter of ensuring the BSS doesn’t exceed its remit and consider it thus has power to control our everyday lives. Creeping nanny state syndrome.

Creeping nanny syndrome?

 

It's taken donkey's years to get to this point, there is creeping and bloody snail creep creeping.

 

I doubt you will have to worry about the next sensible step, you and I will both be dead.

[MtB]

CO monitors are all rather subversive actually and I have my doubts about whether this measure will save any lives in the medium term. 

 

Like seatbelts, CO alarms engender a (possibly false) feeling of smug satisfaction amongst those who have them, they they are safe, secure and protected from all gas appliance faults. Back in the early days of CO monitors I had a number of customers express the view that a CO monitor means they no longer need to maintain their gas appliances as the monitor will save them from any faults. What measures are BSS taking to prevent this flawed line of thinking occurring?

[TheBiscuits]

2 hours ago, rowland al said:

Also, as most camper vans and caravans have got gas appliances, how come they aren’t subjected to the same ‘rules’? Most have an even more confined space.

And usually have ventilation holes in the bottom - which isn't a great idea on a boat!

 

1 hour ago, StephenA said:

What do if my CO alarm goes off and I have nothing in my boat producing CO (no gas / solid fuel devices burning)  and its actually coming in from the boat behind.

 

I'm not arguing against detectors but the BSS covers several examples where the CO is coming in from an external source... what are you supposed to do about that at 2 in the morning?

I'd recommend getting out into the fresh air PDQ.  If you don't wake up to the CO alarm, you might never wake up again.

 

If you are feeling community spirited, you could bang on the boat that is producing all the CO and wake them up too.

[Guest]

24 minutes ago, TheBiscuits said:

And usually have ventilation holes in the bottom - which isn't a great idea on a boat!

CO won't normally vent through a hole in the bottom of a caravan.

 

LPG however will, that's why caravans have vents in the floor.

[Alan de Enfield]

3 hours ago, StephenA said:

What do if my CO alarm goes off and I have nothing in my boat producing CO (no gas / solid fuel devices burning) 

Last Summer I was very glad we had a Co alarm fitted.

 

In marina, plugged into the mains, batteries on charge.

Middle of the night the Co alarm goes off its about 12" from my ear and makes a racket.

Jumped up and could not find any 'faults' (the eberspacher wasn't on, the gas cooker, hob and grill were all switched off).

Opened all of the windows, got a blanket and wafted the air around a bit until the bleeping stopped - blamed the dog's farts and went back to bed / sleep.

About an hour later, off it goes again - repeat performance - no results.

Open the windows again, waft the blanket, blame the dog, back to bed.

Whilst getting back into bed, noticed the slightest 'taste' in the air that just 'caught' in the back of the mouth (it wasn't the 'rotten-eggs' smell, it was more acidic) - not much, but not 'usual'.

Removed the stairs and was 'hit' by a rush of 'hot-smell'. It turned out one of the batteries had an internal short, Crept up to it choking, it was so hot it was untouchable. Got tools and managed to disconnect the terminals, put on both bilge blowers and cleared the engine room of 'gas'.

 

If I had not been woken and been able to disconnect the battery I don't know what would have happened but I'm pretty sure it would not have had a beneficial result.

 

Co detectors also sense Battery gas (Hydrogen ?), well worth having one.

 

Edited August 18, 2018 by Alan de Enfield

[rowland al]

13 minutes ago, Alan de Enfield said:

Last Summer I was very glad we had a Co alarm fitted.

 

In marina, plugged into the mains, batteries on charge.

Middle of the night the Co alarm goes off its about 12" from my ear and makes a racket.

Jumped up and could not find any 'faults' (the eberspacher wasn't on, the gas cooker, hob and grill were all switched off).

Opened all of the windows, got a blanket and wafted the air around a bit until the bleeping stopped - blamed the dog's farts and went back to bed / sleep.

About an hour later, off it goes again - repeat performance - no results.

Open the windows again, waft the blanket, blame the dog, back to bed.

Whilst getting back into bed, noticed the slightest 'taste' in the air that just 'caught' in the back of the mouth (it wasn't the 'rotten-eggs' smell, it was more acidic) - not much, but not 'usual'.

Removed the stairs and was 'hit' by a rush of 'hot-smell'. It turned out one of the batteries had an internal short, Crept up to it choking, it was so hot it was untouchable. Got tools and managed to disconnect the terminals, put on both bilge blowers and cleared the engine room of 'gas'.

 

If I had not been woken and been able to disconnect the battery I don't know what would have happened but I'm pretty sure it would not have had a beneficial result.

 

Co detectors also sense Battery gas (Hydrogen ?), well worth having one.

 

 

The bottom line Alan is that,  even if there is a 0.00001% risk of a dodgy battery causing a boat fire which could kill a passer by who happens to be too thick to run away from it, should we worry? 

 

Don’t forget the current mission statement doesn’t care about you. 

 

So I’m here to tell you that the dog may be a H&S issue.  :D

 

[rowland al]

The current BSS mission statement doesn’t give a shit about you as a boater.  It’s only concerned with third party litigation. 

 

Now it seems they might now care about us boaters. I’m so confused. ?

[Alan de Enfield]

28 minutes ago, rowland al said:

Don’t forget the current mission statement doesn’t care about you. 

Agreed - exactly that.

 

But - I was simply making the point that fitting one had saved me a load of trouble and strife. They don't just monitor Co.

(I appreciate that this information is tangential to the thread, but I wanted to spread the info.)

[rowland al]

Edit to say apologies Alan,  you quoted an earlier post of mine before I expanded later. 

Edited August 18, 2018 by rowland al

[LadyG]

8 hours ago, Chalky said:

We’ve had CO alarms and optical smoke detectors on the boat for 10 years. Tend to use standard domestic ones and replace them after about 5 years. Wouldn’t be without them.

 I also have a flammable gas detector in the bilge but don’t tend to use it due to its high current draw.

When I had a gas detector fitted on my boat the fitter insisted it was hard wired to a battery [salty water safety regs for commercial yachts], so it flattened the battery.

[nicknorman]

On 18/08/2018 at 09:37, Rob@BSSOffice said:

We don't run consultations to tick boxes. All opinions are sought. We look forward to all members of CWDF submissions should they choose to participate. It would be a good thing.

So when you say “all opinions are sought” does that categorically mean that if a majority of responses are against the proposal, it will be dropped? Or does it mean that, whilst all opinions are sought, you will ignore any that don’t agree with your position and/or try to twist the words used,  pick fault with, or ridicule such responses so that you can justify ignoring them. The latter of course being the way 99% of “consultations” are run.

[mrsmelly]

On 18 August 2018 at 10:20, dmr said:

Its all gets so difficult

 

BSS checklist:

 

Remove all crap from gas bottle locker and hide behind hedge so BSS man won't see it.

Borrow fire extinguishers from boat behind.

Borrow CO meter from boat behind.

Wipe all leaky fuel unions and remove dip trays from below unions (or whisky bottle if you have a Kelvin).

Remove covers from air vents.

Remove underwear that wife has wrapped round stove flue to warm up.

 

Did I forget anything?

 

..................Dave

Remove petrol and gennie with rest of stuff to behind said hedge.

[Alan de Enfield]

4 minutes ago, mrsmelly said:

Remove petrol and gennie with rest of stuff to behind said hedge.

Sorry - you lose points for repetition (post #48)

[Cheese]

The consultation seems a bit muddled.

 

The underlying rationale is that a boat might be causing a danger to third parties, i.e. occupants of other boats.  But in that case alarms should only be needed near to potential sources of CO (stoves, generators etc).  There should be no need for alarms in accommodation areas as they are only to protect the occupants.  (It may be common sense to fit them from a personal safety perspective, but they should not be needed from a BSS "third party" perspective).

[mrsmelly]

2 minutes ago, Alan de Enfield said:

Sorry - you lose points for repetition (post #48)

?