Requests for Interpretation
The following Requests for Interpretation (RFIs) have been presented to the Project Technical Committee (PTC) which is responsible for that standard and the answers have been excerpted from PTC minutes when answered by the committee.
Request for Interpretation:
H-27 Seacocks, Thru-Hull Fittings, and Drain Plugs
Question: Could a boat that meets the performance requirements of level flotation as stipulated in H-8.8 qualify under the exception to H-27.5.1 and utilize other means even though that boat may be 20 feet in length or greater?
Answer: The committee voted that any boat meeting level flotation requirements may apply the exception under 27.5.1, however it is the manufacturer’s responsibility to confirm these requirements are met.
Request for Interpretation:
ABYC H-41 Reboarding Means, Ladders, Handholds, Rails, and Lifelines
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Request for Interpretation:
ABYC H-41 Reboarding Means, Ladders, Handholds, Rails, and Lifelines
Question: ABYC H-41.10.1 states "A label complying with H-41.11 and warning of propeller proximity shall be affixed in the vicinity of,
- the transom reboarding area (see Example 1), and
- the steering stations(s) (see Example 2)"
Is this requirement intended to apply to a boat where a person cannot come into contact with the propeller during the reboarding process?
Answer: The committee answered that yes this requirement applies to all boats, however as a result of this the Product Interface PTC will be examining the application of this label.
Request for Interpretation:
ABYC H-41.8.4 states "A step or rung spacing shall not be in excess of 12".
Question: If you are stepping over an obstacle in excess of 12" yet your foot surface is within 12" of each other vertically than has the requirement been met?
Answer: The Hull and Deck PTC voted and discussed this issue and determined that the requirement has not been met. Any obstacle to be negotiated that would require a step or rung per H-41 may not be in excess of 12 inches.
Request for Interpretation:
ABYC H-2 Ventilation of Boats Using Gasoline
Question: Are staterooms, heads (bathrooms), or a galley considered to be within the interior of a cabin?
Answer: The Fuel and Ventilation PTC has voted Yes to this question.
ABYC H-24 Gasoline Fuel Systems
Question: a. For the purposes of clarifying H24.13.1 and H-24.17.2, if a fuel fill is located where any overflow would run down a walkway or gunnel and out a drain, not entering the cockpit, would this arrangement be an acceptable fuel fill installation?
b. Would the same apply to diesel fills?
Answer: The Gasoline Fuel Systems PTC has voted Yes to both questions a and b.
Question: When the fuel primer bulb is located in the hull,
a. Is the termination of the fuel line connection located at the suction of the fuel primer bulb?
b. Is the termination of the fuel line connection located at the discharge of the fuel primer bulb?
Answer: The Gasoline Fuel Systems PTC has voted No to both questions a and b.
ABYC H-41 Reboarding Means, Ladders, Handholds, Rails and Lifelines 2006
Question: For the purposes of clarifying H-41.4 and H-41.5.1, if a cabin top or cutty cabin top has provisions for ground tackle or docking gear then is it exempt from the requirements of H-41.5.1?
Answer: The Hull and Deck PTC has voted no to this question
Request for Interpretation:
ABYC H-3 Windows, Windshields, Exterior Hatches, Doors, Port Lights and Glazing Materials
Question #1
Must a hatch which covers a compartment that is considered a "wet locker" and which is self draining overboard and sealed to the interior of the craft be weathertight?
Answer #1
The Hull and Deck PTC has voted "NO" to this question.
Question #2
Must a hatch which leads into a bilge space be considered watertight if the downflooding point for the craft is located below the hatch surface?
Answer #2
The H&D PTC has voted "NO" to this question.
Request for Interpretation:
ABYC H-22 Electric Bilge Pump Systems
Question #1
Is it a requirement to have the High Water bilge alarm activated at all times?
Answer #1
The Hull Piping PTC voted that yes it is required to be activated at all times.
Question #2
Is it a requirement to have the alarm located at the helm?
Answer #2
The Hull Piping PTC voted that NO the alarm is not required to be at the helm.
Request for Interpretation:
ABYC E-11 AC & DC Electrical Systems on Boats
Question: E-11.15.3.5 states: If installed in a head, galley, machinery space, or on a weather deck, the receptacle shall be protected by a Type A (nominal 5 milliamperes) Ground Fault Circuit Interrupter (GFCI). (See E-11.13.)
Does this requirement apply to receptacles that are installed for a single-purpose appliance and located that the installation of the appliance (e.g. microwave in a cabinet) blocks access to the receptacle?
Answer: The Committee agreed that this receptacle is intended to be protected by a GFCI as per 11.15.3.5.
Request for Interpretation:
ABYC E-11 "AC & DC Electrical Systems"
Q. We currently have a 5 wire connection professionally swaged onto a single ring terminal appropriately sized for the total wire capacity circular mil. It is our contention that regarding 11.16.4.1.11 of ABYC E-11. This section states, "No more than four (4) conductors shall be secured to any one terminal stud." The post in question is the negative terminal post on the battery and the section is referring to the number of ring terminals allowed onto a single connection point of a terminal strip not the number of wires to a single ring terminal itself. Is our professionally swaged assembly in compliance with E-11.16.4.1.11?
Answered by Project Technical Committee (PTC)
ABYC Electrical PTC (excerpted from February 14-15, 2005 PTC Approved Meeting Minutes)
A. The committee felt this was acceptable. The wording of E-11 will be modified during the next review cycle.
Q. Is E-11.16.4.1.9 regarding "Self Extinguishing" loom material based on UL 94 to be applied to DC wires under 50 volts? E-9 (DC under 50 volts) in its original form before combining with E-8 (AC) did not contain this requirement however E-8 (AC) did. When they were combined (E-11) was this incorporation of requiring the DC side to meet the AC requirement on wire loom intentional?
Answered by Project Technical Committee (PTC)
ABYC Electrical PTC (excerpted from February 15-16, 2005 PTC Approved Meeting Minutes)
A. The intent is to apply the DC standards to AC as well. The wording will be modified during the next review cycle.
Request for Interpretation:
ABYC S-30 "Outboard Engine & Related Equipment Weights"
Q: This letter is our request for interpretation on referencing S-30 OUTBOARD ENGINE AND RELATED EQUIPMENT WEIGHTS in ABYC standards with an effective date prior to the effective date of S-30.
ABYC recommends compliance with S-30 for all boats, associated equipment, and systems manufactured after July 31, 2004. In the July 2003 ABYC supplement #43 we received three standards that reference S-30. Each one of these standards has a different effective date.
- H-5 CAPACITY — Boats manufactured after July 31, 2003
- H-8 FLOTATION — Boats manufactured after July 31, 2000
- H-35 PONTOONS — Boats manufactured after July 31, 2004
H-35 PONTOONS is the only standard that matches the effective date of S-30.
The Hull Performance PTC and Tech Board found it necessary during the assessment of existing technology and the problems associated with achieving the goals of S-30 to make it effective on boats manufactured after July 31, 2004.
How can ABYC make a major revision to a current standard (H-5 & H-8) and not change the effective date? The increased engine weight tables have a major impact on 2004 models that are engineered, tested, and in production with marketing materials to the dealers.
With the updated reference to S-30 engine weights, is it the committee's intent that the current H-5 and H-8 be effective on boats manufactured after July 31, 2004?
Answer by Technical Board
A: Yes. (Note: The current H-5 & H-8 contain references to ABYC S-30 and no longer include individual weights, see supplement 43 issued July 2003.)
Request for Interpretation:
A-24 "Carbon Monoxide Detection Systems"
Q: Is the intent of the Gas Detector PTC to require that Carbon Monoxide detectors be certified by an independent 3rd party to meet the requirements of UL 2034 including the UL 2034 marine supplement?
Answer by Project Technical Committee (PTC)
A: Yes. The intent of the Gas Detector PTC is to require that Carbon Monoxide detectors be certified by and independent 3rd party to meet the requirements of UL 2034 including the UL 2034 marine supplement.
Request for Interpretation:
ABYC E-8, "Alternating Current (AC) Electrical Systems on Boats" (published 07/01)
Q. (ref. ABYC E-8.15.10.1 "Loom used to cover conductors shall be self extinguishing, classified V-2 or better, in accordance with UL 94, Tests for Flammability of Plastic Materials."( Should the loom itself be classified as V-2 or just the base material?)
Wire loom issue: (a PTC member) reported that he sent a questionnaire asking boat builders for input. Of 17 respondents, 13 mentioned they were using UL 94 V-2 rated loom. The others either did not use loom or are using non-rated loom.
The idea behind this requirement was to formulate loom products that would not propagate otherwise localized fires. Is this the intention of this section of the standard?
Answer by Project Technical Committee (PTC):
ABYC Electrical PTC (excerpted from July 12-13, 2001 PTC Approved Meeting Minutes)
A. The committee agreed that the base material should be classified V-2 or better and not the finished product. The paragraph of E-8 should read as follows:
ABYC E-8.15.10.1 "Loom used to cover conductors shall be manufactured from material which is self extinguishing, classified V-2 or better, in accordance with UL 94, 'Tests for Flammability of Plastic Materials'."
Request for Interpretation:
ABYC H-4, "Cockpits and Scuppers" (published 07/99)
Q. "It is my understanding that it is a common interpretation of the ABYC H-4 standard when calculating scupper size, to use only the 'fixed sill height' for the 'h' component in the formulas given, ref: ABYC H-4.5.9.2.1. With that, this is to request a confirmation on that interpretation from ABYC, for our use in assessing compliance to this standard.
However, first I would like to point out some issues I find conflicting if not confusing and feel are in need of addressing before a valid confirmation can be:
- From the definitions section we have...
Cockpit depth – The maximum depth of water that can be contained in the cockpit with the drains closed, with the boat in the static floating position.
Then, from the formulas the 'h' component itself is identified as- h = cockpit depth - ft
The traditional use of this term is from the sole to the top of the cockpit coaming, usually at the transom; this is also consistent with the ISO's interpretation. By establishing 'ft' as the value for 'h' in the formula, the expectation of using the coaming again is apparent, typically 2 ft. to 3 ft. or more, not the mere fraction of a foot a sill would be. Also, this definition does not in any way imply the use of something other than the coamings such as an entryway sill, as that would not represent the maximum depth of the cockpit as specified.
- Continuing with the formulas, the 'Vc' component is identified as- Vc = total amount of water that can be contained in cockpit with the drains closed - ft3
How would the total amount of water be accounted for if using only the height of the sill with the coaming of the cockpit extending well above?
- The term 'fixed sill height' is not even defined or identified in this standard as to what it is or it's minimum height. In the definitions section it does list...
Sill – A permanent step or coaming that prevents the entrance of water to the hull interior.
By including the word 'coaming' this just adds to the conflict and does not clarify anything. The only occurrence of this term is when describing the physical test that can be performed in lieu of the calculations to ascertain compliance to scupper size requirements:
ABYC H-4.5.9.1 When filled with water to the fixed sill height, and with weathertight hatches sealed to the height of the sill, 75% of the cockpit water volume shall drain in 90 seconds. There shall be no leakage to the hull interior during the test.
It seems clear that if you chose to perform the test, the water depth has only to reach the sill height presumably at the entryway, but if the calculations are to be relied on as the sole means to demonstrate adequate scupper size then the whole cockpit would be used."
Answer by Project Technical Committee (PTC):
ABYC Hull PTC (excerpted from April 24-25, 2002 PTC Approved Meeting Minutes)
A. The committee reviewed the wording of the published version of this document (dated 7/99) and discussed this issue, including the four-inch requirement of section ABYC H-4.5.8.2. A motion was made and passed clarifying the meaning of the formulae in ABYC H-4.5.9.2: "h" reflects the minimum height where water first flows into the interior of the boat or overboard.
Request for Interpretation:
ABYC H-5, "Boat Load Capacity" (published 07/99)
Q. "Per H-5.6.2.2.2, the number of persons shall not exceed the value determined by dividing the quantity of 32, plus the posted pounds of persons, by 141, and rounding up or down to the nearest whole number, or the number of occupant positions that are designed for occupancy while the vessel is underway, whichever is less.
During the development of this standard the word 'designated' was originally used, where the word 'designed' is now used. The PTC chose the word 'designated' to cover center console boats where the designer intends occupants to stand next to the console holding onto a grab rail, or stand behind the seat/leaning post, holding onto a handrail. As the committee discussed it more and more occupant positions that were not conventional seats came to mind.
The HP PTC must provide clarification on this point and interpret this requirement. I request that the HP PTC define a position 'designed for occupancy'."
Answer by Project Technical Committee (PTC):
ABYC Hull PTC (excerpted from April 24-25, 2002 PTC Approved Meeting Minutes)
A. The Committee reviewed the wording of the draft of H-5 dated 5/1/01, which recently passed Technical Board Ballot for Publication and is to be published in the 2002 Supplement. The wording in this draft (section 5.6.2.2.2.2) is slightly different than the wording given in the above request. The committee discussed requirements for seats, handholds, and occupant positions, both at rest and underway. It was agreed that determining "occupant positions" was the responsibility of the boat manufacturer but communicating this information to the operator is outside the scope of this standard.
A motion passed offering the following as clarification of the phrase "occupant positions that are intended for occupancy when the vessel is underway… ".
A position that is:
- a seat with a handhold, or
- a middle seat(s) in a bench seat, or
- a standing position where the person can hold on with two hands as intended by the manufacturer.
Request for Interpretation:
ABYC H-41, "Reboarding Means, Ladders, Handholds, Rail & Lifelines" (published 07/98)
ABYC H-41.8 LADDERS, STEPS, AND TREADS
ABYC H-41.8.1 A change in elevation greater than 12 inches (305mm) to a flying bridge, companionway, or walkway, shall be provided with a ladder or step(s).
EXCEPTION: Seats
Does this step spacing requirement apply only to ladders
In looking at a wide variety of boats, it appears that nearly 100% of the ladders used for the bridge, and companionway steps comply with the 12" rule. In nearly 100% of boats, the access step to side decks and fore decks exceeds 12". There are other places in many boats where the change in elevation between them will exceed 12 inches. Nearly 100% of the boats I have checked ranging between 18 and 37 feet, do not meet the 12-inch rule for steps between the swim platform and cockpit, and cockpit to side decks or cockpit to foredeck. In a boat with a cockpit, the path from the cockpit sole to the side deck may be as follows. First, you step up onto a seat 14-16" off the cockpit sole, and then step up again 14" to cross the coaming at the cockpit side. Clearly it does not make sense to permit a 16" step to get onto the seat, and require a 12" step before you reach the coaming top. I have looked at a wide variety of boats at boat shows. Where there is a step up to get to the side deck (a walkway) from the cockpit there is no consensus. They are all different, but most are 14 to 28". Where there is a 28 or 32" distance from the sole to the side deck, it is common practice to put no more than one intervening step. Lacking any evidence to the contrary, this practice should continue to be permitted.
To reflect standard industry practice, the ABYC H-41 requirement should only apply to interior spaces and companionway ladders, and ladder systems to a flying bridge.
Q. Should the standard be re-written to state the following language? "This requirement applies to companionways and ladders. It does not apply to the exterior of the boat except for a ladder to a flying bridge."
Answer by Project Technical Committee (PTC):
ABYC Hull & Deck PTC (discussed at the July 16-17, 2002 PTC Meeting)
A. No. The committee discussed this requirement and agreed that the requirement is clear as written.
If you have a "Request for Interpretation" which you would like an ABYC Project Technical Committee to address, please make sure your question is in a format requiring a "yes" or "no" response (see the ABYC Technical Board Rules relative to this in the introduction to this web page) and click on the "Submit a Comment" button. You may also contact the ABYC Technical Department at techdept@abycinc.org.
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