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Boiler certification in a launch

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Sam Longley 109/11/2018 09:18:50
702 forum posts
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As I understand it small boilers for hobby use are not covered by the pressure systems regs

In addition a vessel used in navigation is exempt from the pressure systems safety regs 2000.

Are there any other regs that might lead to compulsory certification of boilers in a steam powered 16 ft launch. In other words can one just go gaily ahead & build without reference to any outside inspection etc (albeit at ones own risk). Having done so can one then continue to run it without inspection ( Once again at one's own, risk)?

I ask, to assist in a dispute on a yachting forum where I stated that it would be unwise to operate such a thing without certification.& regular testing

It was pointed out that there was no legal requirement to do so.

However, I felt that any boiler would have to comply with the 2000 regs during commercial manufacture as the boiler left the factory. Regardless of final intended use. But would it, if it was for hobby use?

Thanks

fizzy09/11/2018 09:26:16
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1569 forum posts
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As a steam generatingf item of such volume it most certainly has to conform to the pressure vessel regs if commercially built. The tables and requirements are set out here - **LINK**

not done it yet09/11/2018 09:34:37
2899 forum posts
11 photos

Aside any legal requirements for testing/using such items, I would guess that a 16’ launch has some value, at least.

Operating without any certification would likely mean that insurance cover, for the launch, would not be possible. Even third party risks would not be covered, so a very dodgy situation for the owner/operator should a claim materialise!

JasonB09/11/2018 09:37:43
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Moderator
15325 forum posts
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You may want to ask on the Steam Boat Assoc forum, bit about boiler testing here

Paul Kemp09/11/2018 10:24:40
272 forum posts
9 photos

Very interesting question, the definitive answer to which is probably not available!

The link to the directive fizzy provided, according to the directive itself does not apply to equipment for 'ships' and for ship propulsion - Chapter 1, Article 1, 2.(n). However, there is probably a requirement under the seperate provisions of the Marine Equipment Directive - this is the one that underpins the 'wheel mark' in the marine sphere as opposed to the CE mark elsewhere. Whether a 16' launch can be classified as a ship is subjective. Sadly like most EU legislation the PSSR is poorly constructed for easy reference!

Without doubt as NDIY states it is highly improbable any insurer would take on the risk without any inspection and certification. However on the open sea, last time I checked there is no requirement for a vessel to carry insurance, situation on inland waterways is different though.

So, it is possible the claim no certification required, in the literal sense could be correct if the launch and its builder / operator are considered in isolation. But..... As soon as a third party is introduced such as a passenger (mate being taken for a spin, family member assisting as examples) or a bystander or another boat coming into close proximity the long standing legal principle "Duty of Care" comes into play. So any problem with the boiler leading to loss or injury where that duty has not been discharged by ensuring the boiler is safe (what better way of doing that than following established practice?) then the operator would be liable for any claim. Do you feel lucky? Like so many things the definitive answer would be influenced by legal precedent and the attitude of the judge / jury on the day!

Paul.

SillyOldDuffer09/11/2018 11:16:26
4269 forum posts
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Posted by not done it yet on 09/11/2018 09:34:37:

...

Operating without any certification would likely mean that insurance cover, for the launch, would not be possible. Even third party risks would not be covered, so a very dodgy situation for the owner/operator should a claim materialise!

That's my understanding of how Victorian Law tackled the large number of full-size boiler explosions during the 19th century. Regular deaths, manglings and scaldings, often involving by-standers.

Early on, before materials, design, build and operating methods were properly understood, even new boilers could be dangerous. After these problems were fixed there was a busy trade in second-hand boilers, most of which got more and more dangerous as they aged. As there was no certification or inspection, it was common for boilers to be life extended by patching, often badly. Industry's failure to reduce the resulting injuries and damage became a public scandal.

Rather than set technical standards in law the Victorians instead passed legislation requiring boilers to be insured, including third party cover, and nailed down liability. To get insurance, it was necessary to persuade an insurers inspector that the boiler was sound and being properly maintained. This approach worked very well, and I think is the origin of model certification today except the boiler inspector is supplied by a Club rather than the Insurance Company.

An advantage of an insurance driven approach is that it allows technical development: if an Inspector is convinced an innovation is OK, it can proceed. Generally not a good idea to embed technical limitations in the law of the land unless absolutely necessary. In theory, Club Inspectors could be wide open to new ideas, in practice it seems easier to codify 'best practice' in a rule book.

Does a 16 foot steam launch need to be insured? I don't know!

Dave

Derek Lane 209/11/2018 12:39:18
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185 forum posts
47 photos

Forgetting the legal requirements for just a second, just for peace of mind if it was mine I would have it tested. I certainly would feel better knowing that it was safe to use at whatever pressure is involved.

Could the person live with themselves if something happened.

 

I know that model boats are different scale but many clubs would not allow anyone who belonged to them sail a steam boat without a certificate

Edited By Derek Lane 2 on 09/11/2018 12:40:37

SillyOldDuffer09/11/2018 12:50:22
4269 forum posts
880 photos
Posted by SillyOldDuffer on 09/11/2018 11:16:26:
Posted by not done it yet on 09/11/2018 09:34:37:

...

Operating without any certification would likely mean that insurance cover, for the launch, would not be possible. Even third party risks would not be covered, so a very dodgy situation for the owner/operator should a claim materialise!

...

Does a 16 foot steam launch need to be insured? I don't know!

Dave

Looking the Guidance up on the gov.uk website, at least for Inland Waterways, it seems very likely: 'You’ll usually need to have ‘third party’ insurance for at least £1 million if you have a powered boat or a houseboat.' There's a £1000 fine and/or confiscation of the boat if you fail to comply which I thinks is similar to what happens when caught driving an uninsured car.

Dave

michael cole09/11/2018 13:17:29
163 forum posts

As far as I am aware there is no legal requirement but you would be restricted to running on private lakes only with the owners permission. That launch would also not be allowed to be in steam at any SBA event. You would not be able to get insurance without a boiler cert. The Steamboat Association of Great Britain ( SBA  does have its own company set up to provide boiler inspections to SBA members.

Mike

SBA member

Speedy Builder509/11/2018 13:43:47
1740 forum posts
118 photos

BSS (Boat Safety Scheme) Examination Checking Procedures – Part 2 Permanently installed fuel systems and fixed engines


Part 2 item 7 reads:-

The pressure systems of steampowered installations must have a current inspection certificate issued by a recognised competent person.

**LINK**

BobH



Sam Longley 109/11/2018 14:18:13
702 forum posts
26 photos

But the boat safety scheme is not a statutory scheme for boats on coastal waters---- or is it?

michael cole09/11/2018 14:45:51
163 forum posts

nor is it for inland waters. My steamboat is exempt from the BSS as being sold fuel and no other systems there is nothing to test.

Sam Longley 109/11/2018 15:40:58
702 forum posts
26 photos
Posted by michael cole on 09/11/2018 14:45:51:

nor is it for inland waters. My steamboat is exempt from the BSS as being sold fuel and no other systems there is nothing to test.

Thanks - no argument with that as you are a user !!!

Speedy Builder509/11/2018 16:44:03
1740 forum posts
118 photos

So Michael, You don't have a "pressurised system of steam" ? I would have thought your boat was "Steam-Powered". It is true that the BSS inspector would not be able to inspect and pass your boiler, but he/she should demand to see your "Current Inspection Certificate".

2.25 pressure system - current pressure system certificate
boiler - current pressure system insurance policy
boiler - LPG installation complies with Part 7 of these Standards
boiler - fuel system does not complies with Part 2 of these Standards

**LINK**

Ron Laden09/11/2018 16:52:03
1036 forum posts
157 photos

I know very little about steam engines and boilers etc but how anyone can operate one at any scale with an untested boiler is beyond me. I would keep looking at the boiler thinking "is it safe" maybe its just me.

Edited By Ron Laden on 09/11/2018 17:07:15

Sam Longley 109/11/2018 17:13:45
702 forum posts
26 photos
Posted by Ron Laden on 09/11/2018 16:52:03:

I know very little about steam engines and boilers etc but how anyone can operate one at any scale with an untested boiler is beyond me. I would keep looking at that boiler thinking "is it safe" maybe its just me, I dont know.

You are dead right, but it was a point dug up on a yachting forum by people with little or no knowledge of these things. Once someone said that there was no statutory requirement, I argued but have been proved totally wrong. It was accepted that one would need it for insurance purposes, but once again one is not legally obliged to hold insurance for a yacht in the Uk. Marinas etc would ask long stay visitors for confirmation third party insurance is held ( but never ask to see the policy), but there again one can moor in a bay without it, --as many do !!

However, if one takes it abroad the authorities inevitably ask for proof of 3rd party insurance, so the Op of that thread could not emigrate with the launch to some EU countries.

Edited By Sam Longley 1 on 09/11/2018 17:14:56

Sam Longley 109/11/2018 17:20:51
702 forum posts
26 photos
Posted by Speedy Builder5 on 09/11/2018 16:44:03:

So Michael, You don't have a "pressurised system of steam" ? I would have thought your boat was "Steam-Powered". It is true that the BSS inspector would not be able to inspect and pass your boiler, but he/she should demand to see your "Current Inspection Certificate".

2.25 pressure system - current pressure system certificate
boiler - current pressure system insurance policy
boiler - LPG installation complies with Part 7 of these Standards
boiler - fuel system does not complies with Part 2 of these Standards

**LINK**

Did you read the last paragraph

I read that as excluding Michael ( unless he is giving rides to kids & what kid young or old would refuse?) for the items listed. Plus the scheme is self regulation not stautory- Is it not?

All checklist items relevant to the boat's installations are mandatory passes for non-private vessels

*EXEMPTION AVAILABLE

SillyOldDuffer09/11/2018 17:47:56
4269 forum posts
880 photos
Posted by Sam Longley 1 on 09/11/2018 14:18:13:

But the boat safety scheme is not a statutory scheme for boats on coastal waters---- or is it?

Rather than worry about what's statutory in terms of boilers, it might be more helpful to consider this in terms of liability in the event someone is injured, especially if the injury is to a bystander. If you're not insured who will pay?

Second reason for avoiding home-brew legal opinion is that the Law is an octopus. You have to consider all the relevant legislation, not just cherry pick. For example, if someone died after a boiler accident, the charge would be manslaughter, not failure to produce a Boiler Certificate. Of course it would help your case considerably if you had a boiler certificate, and insurance, and could prove regular maintenance. Those facts show you took reasonable precautions and aren't negligent. On the other hand, not so helpful if the prosecution show you are an incompetent who deliberately chose to ignore a safety issue on the basis of advice given on a web forum!

Steam boat on a private lake, no problem. Steam-boat in public, different game entirely. I think the easiest way to find out is to insure the risk. As soon as you do that, the professionals get involved because they have to understand the extent of their liability.

Dave

David Jupp09/11/2018 19:03:28
668 forum posts
16 photos

Exemptions from Pressure Equipment Directive are often where other directives (or other existing legislation) apply anyway and are deemed to adequately cover the particular risk.

So for boats it might be useful to look at the Recreational Craft Directive (for example).

As others have pointed out - the regulations typically formalise what responsible owners/operators/users were doing anyway.

Paul Kemp09/11/2018 20:09:02
272 forum posts
9 photos

Posted by Ron Laden on 09/11/2018 16:52:03:

I know very little about steam engines and boilers etc but how anyone can operate one at any scale with an untested boiler is beyond me. I would keep looking at the boiler thinking "is it safe" maybe its just me.

Edited By Ron Laden on 09/11/2018 17:07:15

Ron,

Anyone operating a boiler ought to be capable of making an informed judgement if the boiler is in acceptable condition - if that is not the case then I respectfully suggest they stay well away from one! The real danger from boilers is a lack of understanding by the operator.

I regularly volunteer on a heritage railway and before anyone is allowed to light a loco up, let alone fire one they have to learn and demonstrate competence in the principles of operation and safety and carry out their own visual examination of the boiler for any signs of water leakage externally or within the firebox including stays and fusible plug(s) and the smokebox tube plate / tubes which is a daily check, to an assessor. Once in steam and before going off shed the safety valve should be observed to be operating correctly according to the pressure gauge and methods of water feed proved functional as well as a proper test of the gauge glass(s) or try cocks. Granted that is not a full trousers down inspection of the whole boiler but roughly once a month at wash out all fittings are inspected as well as an internal exam and integrity of stays checked, among other things. This is in addition to the annual formal boiler test by an independent inspector.

Things worth considering are; boilers rarely fail catastrophically without some prior indication like steam and water leaks - hence the importance of the operator having a full understanding of the implications of warning signs. A boiler inspection is a bit like an MOT, happens once a year and a lot of damage can be done to a boiler in a year by the operator running with low water, rushing into steam (unequal expansion damage), failure to wash out or in hard water areas descale so hot spots develop stressing the plates, etc etc etc!

The real risk of a miniature boiler exploding is small unless it has been made from a baked bean tin held together with chewing gum by someone with no knowledge or appreciation of the potential issues - in which case return to paragraph one! The relative level of risk is further evidenced by the low cost of insurance, if boilers were exploding left right and centre the premiums would be massive. Even the black museum of sectioned boilers parts showing quite serious weld defects and constructional issues which used to appear on various stands at exhibitions in a perverse way show the level of risk as they came from boilers that had been operated for years with those defects present before they were cut up and none of them failed catastrophically as far as I am aware?

As far as the OP question goes there is not enough information on the proposed boiler itself to make any reasonable assesment of risk - is/ was it being made to an established design? What are the materials? Builder competence? The question focused on a lack of intent to follow a formal independent inspection and certification regime because of a belief it wasn't required - that doesn't necessarily on its own make the boiler dangerous. It may be the owner is perfectly capable of making his own assesment and is confident in his abilities. It is interesting perhaps and seemingly little understood that it is the owner / operators responsibility under the regulations to appoint a competent person and be confident of his competence in so doing, to inspect a pressure system. It remains the owners liability for the safe operation unless it can be proved the person issuing the certification was negligent the owner / operator will carry the can. Having boiler certification means nothing 11 months after the test if the boiler has not been operated and monitored correctly by the operator.

Paul.

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