The ORC category 1 rules are a useful reference when prioritizing safety issues/equipment (the 2010-2011 update has just been released). They have been written by experienced sailors based on the combined experience of the world’s offshore racing fleet. For the most part, we have taken this hard-won advice very seriously and attempted to equip Hawk so that she is in compliance with these racing regulations. However, there are a few areas where our experience and judgment have led us to reject the recommendations. These are as follows:
3.03.1 A yacht . . . shall have been designed built, maintained, modified and repaired in accordance with the requirements of: EC Category A or . . . ABS or . . . ISO 12215 Category A
Given the frequency of broken rudders and keels, it seems clear that either the scantling standards need to be updated and strengthened or the designers/builders held to closer account to actually meeting the standards. We built the key parts of Hawk to several times ABS. This was simple and inexpensive but does add weight. To my mind this is exactly where the rule should focus its attention - on prohibiting design elements that have proven in actual fact to be fast/light but unreliable/unsafe.
3.04.4 ISO 12217-2 may be used as a guide to general suitability . . stability
Unfortunately ISO 12217 pretty much requires you hire a naval
architech to do some a number of calculations before you can determine
anything, and then you still only have a theoretical understanding based
on your vessel plans, but not an actually understanding based on your
actual vessel consrtuction and loading. In my opinion have a surveyor do
an (IMS) inclining and stability test is rather more useful and
accurate.
3.14.6 c) A taut lanyard of synthetic rope may be used to secure
lifelines provided the gap it closes does not exceed 100 mm (4 in). This
lanyard shall be replaced annually at a minimum.
We use Spectra lashings covered with rigging tape to secure our life lines. It does not need to be replaced every year, or even
every 10 years, and it essentially does not chafe nor is it exposed to
UV. I had one of these lashings pull tested in New Zealand after five
years of use and it tested at 95% of original strength. The wire appears
to need replacement more frequently than the lashings as it corrodes and/or strands where it goes through the stanchions. In addition,
our lanyards are more than 6 inches long, but I do not see that as any
problem as they are about twice the strength of the lifeline wire.
We use Spectra extensively in areas requiring strength and durability
and find it better that stainless wire, while the rules seem to reflect
‘pre-Spectra’ thinking and focus on stainless wire as the only decent
material choice.
Spectra lifelines are allowed (but not required) for the first time in the 2010 regulations.
We are told that there have been cases of spectra lashings being cut
by 'sharp weld splatter' at the attachment point on the pulpit/pushpit.
We take our lashings right around the full tubes of the pulpit/pushpit
as this is smoother, stronger, lighter and cheaper than welding on
attachment points.
A bigger question with this rule is why is it the first (and only one)
concerned with routine maintenance? Why specify lashing replacement
frequency (which does not seem to be a very major issue) and not many
more important maintenance topics, such as rigging replacement, keel bolt
torque checking, and replacement of steering cables, etc?
3.17.1 A toe rail of minimum height 25 mm (1 in) shall be
permanently installed around the foredeck from abreast the mast, except
in way of fittings and not further inboard from the edge of the working
deck than one third of the local half-beam.
3.22 Hand holds adequate hand holds shall be fitted below deck so that
crew members may move about safely at sea.
We have continuous handholds both below and above decks (e.g. you can
move from one end of the boat to the other with a good handgrip always
in reach). We also have a continuous 3” high toe rail to provide
security on a steeply heeled lee deck.
Given all the concern and other rules related to MOB issues I am puzzled
by these two very timid rules. Why not specify a
continuous toe rail which would provide much more secure footing when
moving up the lee deck, one designed to be comfortable for people hiking
out? Why specify hand holds below decks only? Why not specify continuous
handgrips along the deck (as we did on Hawk)? Further why no mention
of non-skid deck surfacing? If you
are trying to address MOB, I would focus on preventing incidents in the first
place with these sorts of things.
3.27.4 Reserve navigation lights shall be carried having the same
minimum specifications as the navigation lights above, with a separable
power source, and wiring or supply system essentially separate from that
used for the normal navigation lights
This rule does not seem practical. Dry cell powered nav
lights will either not meet required brightness or not last for any
length of time. It would be possible to fit duplicate lights,
powered off the engine start battery, but then you could well end up
with a flat engine battery (and thus probably violate 3.28.3 d).
Further I am not sure why this is an essential requirement. We
will be keeping a proper watch. If the navigation lights die
during the night, we will take avoiding action and/or communicate
our intentions by radio to any vessels in sight.
3.28.1 A securely covered inboard propulsion engine shall be
provided together with permanently installed exhaust and fuel supply
systems and fuel tank(s)
We have an engine, but it strikes me as odd that the rules of SAILING should require an engine
(for Cat 0, 1, 2 & 3 races).
Especially with the current environmental and security issues associated
with oil/internal combustion engines, should not the sailing authorities
take the lead and promote clean sailing?
3.28.2 a) A separate generator for electricity is optional. However,
when a separate generator is carried it shall be permanently installed,
securely covered, and shall have permanently installed exhaust and fuel
supply systems and fuel tank(s). A separate generator shall comply with
OSR 3.28.3 (c) and (e)
We carry a Honda 1000i portable gasoline generator which provides more
efficient battery charging than the main engine. It is not
permanently installed. I do not see any significant safety concerns with
it (that are not already widely accepted in the use of gasoline
outboards). We place it on deck when running it. We do not
do this in heavy weather. We stow our spare gasoline in a separate
partition of our sealed propane locker. You need to be extremely careful
stowing gasoline inside the vessel (and this applies to outboard motors
stowed in a lazeratte as well as gensets) because gasoline vapors can
come out an open tank vent, and being heavier than air, it will pool in
the bilge and then potentially explode if exposed to a spark. The
Honda has both a positive closing tank vent and fuel shut-off and
appears to be well designed from a safety perspective.
3.28.4 b) All rechargeable batteries on board shall be of the sealed
type from which liquid electrolyte cannot escape. Other types of battery
installed on board at January 2006 may continue in use for the remainder
of their service life though it is strongly recommended that they be
changed for sealed batteries as soon as possible. (required for catagory
0, recommended fo catagory 1,2,3)
We use wet cells, not sealed batteries. I do this for three reasons. First, from a
safety perspective I like the ability to check each individual cell with
a hydrometer, so I don’t head offshore with a weak cell (you can not do
this with sealed batteries). Second, also from a safety perspective, wet
cells are more robust and resistant to accidental high charging
voltages, and can be equalized to recover weak cells. Third, they are
half the price with more life cycles (up to twice as many) so somewhere
between 2x – 4x the value, which means we can have stronger/fresher
batteries when we go on passage.
I understand the potential for acid spills and chlorine gas generation.
However, those seem to be extremely low probability events (which can be
managed in other ways, such as installing a drip cover on the battery box)
while weak cells and accidental high voltage are much more common
problems. I prefer to address the high probability events. The two
types of batteries (wet cells and sealed) are the same weight, so there
is no competitive pressure to pick one or the other.
I therefore believe the decision should be left up to the owner.
3.29.1 The following shall be provided:n) An AIS Transponder
AIS is a nifty new tool, but . . . having that nifty screen down below will lull many crews into think the screen shows reality and it does not. (a) Many vessels don't have AIS transmitters and (b) they are broken/non-functional even on many ships that are required to have AIS transmitters, (c) are there are other hazzard out there than ships that you need to watch out for. AIS is absolutely no replacement for a good deck watch and is not as good as a radar watch. AIS is a nifty tool but there is absolutely no way that an AIS transmitter should be required equipment.
4.02.1 b) Each yacht is recommended to show at least 1 m^2 of fluorescent pink or orange or yellow colour as far as possible in a single area on the coachroof and/or deck where it can best be seen
This is not a bad recommendation except we think the color is best
at the masthead where it will be visible over waves rather than down on
deck.
4.04.1 a) ii Jackstays:- comprising stainless steel 1 x 19 wire of
minimum diameter 5 mm (3/16 in), or webbing of equivalent strength;
We use Spectra jackstays – stronger (and more UV resistant) than (nylon
or polyester) webbing and does not roll under the foot like wire.
4.07.1 a) a watertight, high-powered flashlight or spotlight, with
spare batteries and bulbs
We have mostly switched to LED flashlights, which don’t come with spare
bulbs (the bulbs last the life of most flashlights - upwards of 10,000 hours). We also have mostly switched to climbing headlamps
rather than handheld flashlights, and these climbing lights are water
resistant but not waterproof (at least I am not aware of any that have
undergone mil-spec
waterproof testing).
4.10.1 A passive Radar Reflector (that is, a Radar Reflector without
any power) shall be provided
Radar reflectors, even the Davis units, are so ineffective they should
not be required. Every quantitative test (link1,
link2) conducted has concluded
that most units provide no real improvement and the best provide only an
extremely marginal increase in target acquisition. That
ineffectiveness should be weighed against the halyard tangling, extra
holes/corrosion in the rig, and cost (which could be better invested in
other safety areas).
4.17 Yacht's name shall be on miscellaneous buoyant equipment, such
as lifejackets, cushions, lifebuoys, lifeslings, grab bags etc.
We don’t have our yacht name on these items. I suppose I could take a
‘permanent marker’ and write it on, but we have found that to fade quite
quickly (say 12 months) with UV exposure. I understand this could
potentially help a search effort, but think they will get 95% of the
necessary information from finding fresh items in the water even without
the yacht name.
4.20.2 Liferaft(s) shall be provided capable of carrying the whole
crew
The life raft is a complex topic which is discussed at length at FAQ 30
Seamanship.
I will simply add here that the apparent difficulty reaching agreement
on life raft standards and the extensive specifications in the main rule
and separate appendixes is clearly indicative of the difficulties
inherent in
creating an effective life raft.
The 2010 regulations include this warning about liferafts: "IMPORTANT
NOTICE Recent evidence has shown that packaged liferafts are vulnerable
to serious damage when dropped (eg from a boat onto a marina pontoon) or
when subjected to the weight of a crew member or heavy object (eg an
anchor). Damage can be caused internally by the weight of the heavy
steel CO2 bottle abrading or splitting neighbouring layers of
buoyancy tube material. ISAF has instituted an investigation into this
effect and as an interim measure requires that every valise-packed
liferaft shall have an annual certificate of servicing. A liferaft
should be taken for servicing if there is any sign of damage or
deterioration (including on the underside of the pack). Persons in
charge should insist on great care in handling liferafts and apply the
rules NO STEP and DO NOT DROP UNLESS LAUNCHING INTO THE SEA."
4.22.1a) The following shall be provided within reach of the
helmsman and ready for instant use: a lifebuoy with a
self-igniting light and a drogue or a Lifesling with a self-igniting
light and without a drogue.
4.22.1 b) In addition to a) above, one lifebuoy within reach of the
helmsman and ready for instant use, equipped with: (i a whistle, a
drogue, a self-igniting light and ii a pole and flag. The pole shall be
either permanently extended or be capable of being fully automatically
extended (not extendable by hand) in less than 20 seconds. It shall be
attached to the lifebuoy with 3 m (10 ft) of floating line and is to be
of a length and so ballasted that the flag will fly at least 1.8 m (6
ft) off the water. iii Each lifebuoy shall be equipped with a sachet of
fluoresceine dye
We were given an inflatable life sling and I initially installed it in
the approved fashion on the transom near the helm. But we have
since removed it, as it was vulnerable to breaking waves (I concluded
there was a good likihood it would not be there after a knock down or
breaking wave washed someone overboard), was degrading
due to salt and humidity exposure, and IMHO was unlikely to be of much
better use in a MOB situation than tying a long floating line with a big
bowline to one of our big fenders (both of which we do have in the
cockpit and which are not as vulnerable to waves/environmental
degradation).
4.23.1 Pyrotechnic signals shall be provided conforming to SOLAS LSA
Code Chapter III Visual Signals and not older than the stamped expiry
date (if any) or if no expiry date stamped , not older than 4 years.
We carry flares as required by the coast guard, but we don’t expect they
will be very helpful. The SAR helicopter pilots we have talked to
confirm our own experience when we have seen flares fired at sea: they
are hard to identify unless you are looking right at them and they go
out extremely quickly.
4.23.2 The following lights shall be provided and readily available
for the purpose of collision avoidance: a) a watertight white torch
(flashlight) with spare batteries and bulb b) a watertight, high-powered
white spotlight (searchlight) with spare batteries and bulbs
See the comments at 4.07.1 a) above. The rules do not seem to have kept
pace with the development of LED lights.
4.28.3 A yacht shall be equipped with an EPFS (e.g. GPS) capable of
immediately recording a man overboard position from each helm station
(From January 2012)
First, double-handed with autopilot, we are rarely at the helm so this
button will not be useful. Second, there are reliability issues with
putting electronic buttons out in such an exposed position (at the helm
where they are fully exposed to UV, saltwater, sunshine and breaking
waves) - all our cockpit electronics are protected under the hard
dodger. Third, we want to be pro-active rather than deal with a
MOB after the fact, so cockpit protection for the crew was high on our
list of safety design priorities, to reduce fatigue, allow better watch
keeping, keep the interior of the boat drier & shield the crew from
solid green water over the bow and side decks (not much you can do with
stern pooping).
I understand the genesis of this with the Volvo boats which are capable of sailing at 20 knots. However it seems rather less imperative for the 6-7 knot boats that most of us sail. As an aside, even with these extremely fast boats I wonder if the helm is in fact the best location for the button. The helm is very exposed in exactly the situations where waves are breaking over the deck and washing crew off the boat. Crew at the helm have been injured and wheels broken (both multiple times) in these situations. I wonder if just inside the companionway would be a better location - more protected and crew are very likely to be near (simply holding on or coming up) there after an incident.
I also think it a bit odd that the one lesson to be taken from the
Volvo/Open 60 boats is an extra MOB button. In fact in the specific
Volvo situation the boat very efficiently returned and found the MOB.
The decks of the Volvo & Open 60's have become brutal environments with solid water constantly washing over the decks
even in relatively mild weather (the maxi-cats seem to have put
marginally more priority on cockpit protection) and this was the fundamental cause of the specific MOB, and many other
injuries. I would have thought the lesson would have been to give
the crew better protection from waves breaking over the decks.
5.01.1 Each crew member shall have a lifejacket as follows: b)
fitted with crotch strap(s) c) fitted with a lifejacket light g)
clearly marked with the yacht's or wearer's name
We have the Coast Guard required life jackets and a couple inflatable pfds. However, they do not have the yacht name, do not have crotch
straps and do not have attached lights. We are very skeptical
about the effectiveness and value of life jackets. The Coast
Guard’s own data (there are links to it at FAQ #30
Seamanship), which they conveniently
ignore, shows either zero or minimal life-saving effect (this data is
shocking and should be a wake-up call for the lifejacket manufacturers).
We prefer to focus on staying on the boat.
On a related topic, we similarly believe that the US SAILING
Prescription to ISAF Offshore Special Regulation 5.02.05 ("A
harness and lifejacket shall be worn when on deck a) between the hours
of sunset and sunrise and b) when alone on deck and c) when reefed and
d) when the true wind speed is above 25 knots or above and e) when the
visibility is less than 1 nautical mile") also actually reduces overall
crew safety. It clearly does not reflect the actual practice of
most experienced seamen. This is because it unnecessarily
restricts free and fast movement on deck and thus hinders good and fast
sail handling procedures. Being able to speedily move around the
deck and quickly resolve potential problems before they become too large
will eliminate/reduce more safety difficulties than being clipped in all
the time. Recent Volvo feedback has shown that current ORC harnesses are
too clumsy for practical long duration usage, and too slow to put on
when the off-watch needs to come immediately on deck. The important,
time-tested seamanship rule is 'one hand for the boat and one hand for
yourself'. The better rule is to clip-in when you simply cannot
hold on: (a) When working with both hands, particularly when standing up
(for example at the mast or head stay), then it is good practice to
clip-in during unstable conditions because you don't have 'one hand for
yourself'. (b) If your work station is being washed with green water,
which could dislodge you even while holding on. That is the experienced
seaman's practice.
As with the lifeline lashing and the first aid certificate, IMHO this
prescription reaches into an area where experienced and knowledgeable
skippers differ in both practice and judgment. My personal feeling is that
these sorts of prescriptions should remain in the suggested/recommended
components of the rule, and the
required component should focus on areas where, without a rule,
competitive pressure would quite clearly create an incentive to do something
unsafe (such as specifying heavy but truly useful safety equipment or
proscribing aspects of yacht design that are dangerous but fast).
5.02.3 A safety line purchased in January 2001 or later shall have a
colored flag embedded in the stitching, to indicate an overload. A line
which has been overloaded shall be replaced as a matter of urgency.
We use light and easy to splice Spectra single braid which is so strong
(14,000 pound breaking strength) and chafe/UV resistant that this sort
of flag is of no value.
The 2010 regulations include a whole new section on required training. Beth & I do not have any of this training. I would immediately pick as crew someone who has sailed offshore (say to bermuda) over someone who has had this training.
6.05.2 At least two members of the crew shall hold a current Senior
First Aid Certificate or equivalent.
Beth is quite knowledgeable about first aid topics, primarily thru
treating horses in her youth, but holds no certificates. I hate the
sight of blood. I agree with suggesting that there should be first aid
knowledge on board but have a concern with requiring specific
certification. This is requiring/allowing only one way to meet an
objective when there are many other good ways to meet that same
objective. The rule seems to stem more from the European drive to
certificates & licensing for all qualifications & skills in the sport,
than from any especially
compelling need to upgrade first aid skills. As discussed below
(harnesses), I think this should be a recommendation rather than a
requirement.
An issue that the sailing authorities do not seem to have fully come to grips with is whether the racing boat is 'a work environment for paid professional sailors' or 'an amateur sporting environment where informed judgments & risks are accepted and part of the game'. The appropriate (and legal) safety rules should be quite different for those two situations. Obviously both occur and there should probably be two sets of rules, but today they are mixed together.
As I am writing this, the local Ushusia racing fleet (twelve 30-footers) is out holding a regular weekend regatta while it is blowing 35 knots sustained with gusts into the 40s. These strong, simple boats, whose owners do not have deep pockets, help put the 'real' safety priorities in quite clear perspective.