Twice a year, the American Boat & Yacht Council hosts the Coast Guard Risk Mitigation Series, a free online event about USCG updates, ABYC standards, risk factors associated with boatbuilding and repair, and a host of other safety topics. This past November, “Series 5: Navigating Compliance in the Age of Evolving Technology” drew approximately 250 industry professionals from around the world.
The four sessions in this two-hour event included presenters from the Coast Guard, the National Marine Manufacturers Association and ABYC, with Brian Goodwin, ABYC’s technical director, acting as emcee. Topics included factory visits and compliance, a global update on standardization and electrification, and lithium-ion battery testing.
Here, we present the highlights. To gain deeper insight into the discussions, watch the full recording for free at abycinc.org/riskmitigation.
The first roundtable includes Jeffrey Ludwig, chief of the Coast Guard’s Recreational Boating Product Assurance branch; Kevin Ferrie and Eric Johnson, engineers for the same branch; and Craig Scholten, ABYC technical vice president. This technical session covers the Coast Guard equivalency authority and what that means for “novel arrangements” such as personal watercraft; new Coast Guard policies on compliance guidance and the definition of canoes and kayaks; a quick tutorial on navigating safe afloat.com so the industry can review existing policies; an overview of an outboard center of gravity project that will affect level flotation testing; and the likelihood (spoiler alert: very likely) of global compliance labels.
Ferrie says equivalency authority is a tool that’s been used in the commercial sector for quite some time. “It’s primarily used to approve vessels or systems that don’t fit into the prescriptive words of federal regulation,” he says. In 2020, Congress passed the Coast Guard Authorization Act, which, among other things, lets the agency create alternative means to comply with the Code of Federal Regulations if there’s an equivalent level of safety. In other words, “novel arrangements” such as personal watercraft can comply with federal standards without meeting all the prescriptive requirements in the CFR.
What this means is important. With equivalency authority, if and when the Coast Guard issues a blanket policy, manufacturers will no longer need to submit individual model exemptions to comply with the CFR.
The PWC equivalency policy is in the final stages of legal review, according to Ferrie. “As the industry evolves,” he says, “we envision issuing one-off equivalencies for novel vessel designs. Working closely with industry will ensure future vessels will meet an equivalent level of safety to the intent of the federal regulations. That is our goal, and hopefully it will allow industry to continue to evolve safely without being handcuffed by out-of-date regulations.”
Next, the event moves on to “USCG Factory Visits and Compliance.” Ludwig outlines what the future of compliance looks like, including a free online-training and technician-certification course about recreational vessel compliance with federal and statutory requirements. According to Ludwig, eventually, “maybe we don’t need to have physical, in-person inspections in all cases.” He then discusses what a voluntary alternate compliance program might look like.
Scholten takes the stage next to discuss the technical files associated with product compliance, from the staff’s level of training to engineering change notices. “With the ongoing challenges of material and component availability, along with staffing issues, the chances of non-compliant product getting into the stream of commerce is very likely,” Scholten says. “This is where manufacturers’ compliance programs serve as an essential part of the operations to minimize issues.”
He also explains the need for technical files and current owners’ manuals for each vessel. Scholten describes steps to address a defect or an incident with a company’s product; the need to pay attention to global agencies and requirements; and a tutorial about the technical toolbox available on the ABYC’s website.
After that, “Electrification and Standardization: A Global Update” is the focal point. Scholten outlines where each of the various global standards entities are accepted. For instance, the ABYC is accepted in the United States, Australia, Canada and other locations, while the International Organization for Standardization provides a “presumption of conformity” for CE certification. Scholten says he works with global compliance groups to try to “standardize and harmonize those requirements” across the world. Gaps exist on all sides, and multiple groups are working to bring it together.
Last is a “Lithium-Ion Battery Testing” session presented by ABYC standards developer Maciej Rynkiewicz, who spent the majority of the past year using a Coast Guard grant to push these batteries to their limits. Rynkiewicz covers the basics of lithium-ion batteries; describes various types of failure and chemical reactions; and discusses the actual testing, in which he tried to re-create real-world scenarios with lithium-iron-phosphate batteries. In short, his testing can be summed up with one quote: “Still no fire.”
Going forward, the Coast Guard and ABYC are vetting the theme and topics for Series 6, which will be held online in May 2024.
This article was originally published in the January 2024 issue.
