BSS compliance

[Chrisb62]

Help! I have an 1986 Atlanta 27 which has failed its BSS. I have sorted the two easy failures, but the problem is check 2.2.2 which requires a continuous fall in the fuel filler pipe from the filler cap to the top of the tank. Unfortunately, the route from the fuel filler cap to the tank has to go under a drainage channel round the cockpit floor which is lower than the connection to the tank (and looks like it always has been) so there can never be a continuous fall. The only solution I can think of is lowering the entrance point to the tank by relocating the connection between the hose and the tank to the side of the tank, or replacing the tank with a smaller/lower tank. Both look like major pieces of work involving welding a petrol tank - not keen on this! Has anyone any experience of dealing with the BSS people in relation to a non-compliance that looks like it pre-dates the BSS entirely, and also the non-compliance has not been identified in any previous survey of the boat.

 

[ylop]

You’ll need to read the criteria very carefully - but I don’t think you can have a filler at the bottom of the tank. The aim of the rule is that fuel is not sitting in the pipe during normal operation. Is it feasible to I’ve the filler point?

 

[Chrisb62]

Thanks for the response. I wasn't proposing to put the filler pipe at the bottom of the tank, but to move it from the top of the tank to the side of the tank at the top. In any case, I've been in contact with the BSS scheme people and there is an appeal process to review issues which we are now pursuing. What seems odd is that it looks to me like this was original design/build, and not only have all previous inspections missed it but also the original design was non-compliant (although the design and build pre-dates the start of the BSS regime.

 

[LittleSister]

. . . the problem is check 2.2.2 which requires a continuous fall in the fuel filler pipe from the filler cap to the top of the tank. Unfortunately, the route from the fuel filler cap to the tank has to go under a drainage channel round the cockpit floor which is lower than the connection to the tank . . .

1) Can the filler pipe be routed around the end of the drainage channel on a longer, more convoluted route, but one which has a continuous, if slight, fall?

2) Is the underside of the drainage channel actually above the top of the tank (rather than the fitting) plus the outside diameter of the filler pipe? In which case you could conceivably have a new (screw or bolt in) inlet fitting made for the of the tank made which would feed in at a shallow angle rather than vertically or vertically plus an elbow.

3) Is there sufficient space between the deck and the top of the tank to move the external filler point to the floor of the cockpit, directly above the tank?

4) If you are replacing the tank, I don't think there is any requirement to weld fittings mounted in the top (only) of the tank (i.e. it seems that can be bolted).

5) You could, with some minor GRP work, reduce or eliminate the drainage channel in the way of the filler pipe run. You will tend to get muck collecting in the cockpit on the upstream side of the restriction, but unlikely to be a serious problem. (Depending on layout you could probably eliminate the whole of the drainage channel 'upstream' above the without serious consequences.)

You’ll need to read the criteria very carefully - but I don’t think you can have a filler at the bottom of the tank. The aim of the rule is that fuel is not sitting in the pipe during normal operation. Is it feasible to I’ve the filler point?

I can't find anything in the BSS which prevents a filler at the bottom of the tank (though a filler at the very bottom of a tank might tank to stir up muck from the bottom of the contents). The BSS specifically says a filler pipe to the side of the tank is acceptable (with no mention of where on the side), but for petrol tanks (though not diesel) the side mounted spigot must be welded to the tank.

A side mounted spigot must also extend above the top of the tank, which in the OP's case would, I think, mean that it would have to project out and beyond the cockpit drainage channel (and hence might need to be well supported to be secure).

 

[Graham_Wright]

Why do you need a BSS cert?

 

[Chrisb62]

Why do I need a BSS cert? Insurance, boaters licence, terms of contract with marina for mooring, sensible to have one because I don't have enough experience/knowledge to check everything....

 

[Chrisb62]

1) Can the filler pipe be routed around the end of the drainage channel on a longer, more convoluted route, but one which has a continuous, if slight, fall?

2) Is the underside of the drainage channel actually above the top of the tank (rather than the fitting) plus the outside diameter of the filler pipe? In which case you could conceivably have a new (screw or bolt in) inlet fitting made for the of the tank made which would feed in at a shallow angle rather than vertically or vertically plus an elbow.

3) Is there sufficient space between the deck and the top of the tank to move the external filler point to the floor of the cockpit, directly above the tank?

4) If you are replacing the tank, I don't think there is any requirement to weld fittings mounted in the top (only) of the tank (i.e. it seems that can be bolted).

5) You could, with some minor GRP work, reduce or eliminate the drainage channel in the way of the filler pipe run. You will tend to get muck collecting in the cockpit on the upstream side of the restriction, but unlikely to be a serious problem. (Depending on layout you could probably eliminate the whole of the drainage channel 'upstream' above the without serious consequences.)



I can't find anything in the BSS which prevents a filler at the bottom of the tank (though a filler at the very bottom of a tank might tank to stir up muck from the bottom of the contents). The BSS specifically says a filler pipe to the side of the tank is acceptable (with no mention of where on the side), but for petrol tanks (though not diesel) the side mounted spigot must be welded to the tank.

A side mounted spigot must also extend above the top of the tank, which in the OP's case would, I think, mean that it would have to project out and beyond the cockpit drainage channel (and hence might need to be well supported to be secure).

1) No - the channel runs all the way round the cockpit at more or less the same level
2) The underside of the channel is just above the top of the tank, but by much less than the diameter of the pipe
3) Hmm, in theory yes but you would need a very short neck on the filler cap - don't know whether such things exist. Would not be happy fuelling inside the cockpit
4) No, I think that replacing with a smaller/shorter tank would be sufficient. But it seems a very costly solution to a problem that only really exists in the minds of the BSS people!
5) Yes that would probably work although the previous owner of the boat has put a teak deck on marine ply on top of the original fibreglass so cleaning out the channel requires removing the teak deck

I think the BSS does suggest that a filler at the bottom would not be permissible because you would then have fuel in the pipe, which is what the BSS fuel pipe checks are designed to prevent. I was thinking of side mounting as near the top of the tank as possible, but this could still end up with fuel in the pipe if you filled the tank to the brim.

In any case, the BSS have accepted that I have a case for a waiver and their surveyor is coming down in a couple of days to look at the pipes. Fingers crossed that they will agree to accept the position on a one-off basis.

 

[snowbird30ds]

Fuelling inside the cockpit it a big no-no.
How about a different bss inspector? They all work from interpretation of the rules and some use more common sense than others.

 

[LittleSister]

I think the BSS does suggest that a filler at the bottom would not be permissible because you would then have fuel in the pipe, which is what the BSS fuel pipe checks are designed to prevent. I was thinking of side mounting as near the top of the tank as possible, but this could still end up with fuel in the pipe if you filled the tank to the brim.

You can have a filler on the side of the tank, and it doesn't matter for BSS purposes whether it is at the top or the bottom of the side, but the spigot (the tubular metal bit welded onto the tank) must extend above the top of the tank. (In your case it could do this outboard of the drainage channel, but might need some bracing to provide sufficient rigidity.)

The purpose of the particular BSS fuel pipe check is to ensure that fuel always drains from the filler 'line'- in your case the flexible hose *. There is no requirement for the metal filler spigot (effectively part of the tankf itself) to drain. It is a fact of physics that wherever the metal filler is, top, side or bottom, there will always be the potential for there to be fuel in it when the tank is filled (or even over-filled a little), but it is regarded as part of the tank.

[* I think the distinction between the flexible hose and solid 'spigot' piping which is fixed to and effectively part of the tank is not immediately obvious in the checklist because the BSS checklist uses the easily conflated terms 'line' and 'pipe', but careful reading of the context; what materials are allowed for each; and finding the definitions of 'pipe' and 'hose', which are not listed alphabetically in the Glossary but unfortunately hidden under the entry for 'line'; does reveal a distinction.

In any case, the BSS have accepted that I have a case for a waiver and their surveyor is coming down in a couple of days to look at the pipes. Fingers crossed that they will agree to accept the position on a one-off basis.

i am pleased to hear that. Good luck.

 

[LittleSister]

Fuelling inside the cockpit it a big no-no.

It's not immediately clear from the checklist that this is unacceptable for the BSS.

"2.1.1
Fuel overflowing from filling points must be prevented from entering any part of the interior of the vessel.
Accordingly, fuel filling points must be positioned so that...

• the camber or configuration of the deck; or,
• a coaming; or,
• a diverter arrangement;
  
  ... prevents overflowing fuel from entering the interior of the vessel."
  
  
  Note the definition of 'interior' specifically excludes self-draining cockpits (and arguably can exclude certain non-self draining cockpits).​

 

[Sandy]

BSS

BSS?

Google gives me Bee Swarm Simulator!

I am pretty sure its not Bull Sh1t Society, so please let us uneducated into the secret of the TLA?

 

[ylop]

BSS?

Google gives me Bee Swarm Simulator!

I am pretty sure its not Bull Sh1t Society, so please let us uneducated into the secret of the TLA?

It’s Boat Safety Scheme - it’s a certification scheme required for boats kept (not just passing through) inland water. Essentially an attempt to stop Narrowboat owners from blowing themselves up, suffocated, catching fire and polluting the waterways.

 

[Sandy]

It’s Boat Safety Scheme - it’s a certification scheme required for boats kept (not just passing through) inland water. Essentially an attempt to stop Narrowboat owners from blowing themselves up, suffocated, catching fire and polluting the waterways.

Thanks @ylop

Are they really that accident prone? Oh hang on I have a pal who ran a brewery and for a week in May every year goes on a narrow boating holiday. We get lunchtime and evening review of the pubs, beer and food, and they still empty a firkin of beer between four of them.

That might explain the need for the Boat Safety Scheme.

 

[ylop]

Thanks @ylop

Are they really that accident prone? Oh hang on I have a pal who ran a brewery and for a week in May every year goes on a narrow boating holiday. We get lunchtime and evening review of the pubs, beer and food, and they still empty a firkin of beer between four of them.

That might explain the need for the Boat Safety Scheme.

A more cynical person might suggest that it is:
- a way of making money
- a way to make it easier to persuade scrap boats to leave
- a way to help inland waterways boat yards to make money
- like all rules with good intentions - a cost for the good and largely ignored by the bad
- mostly replicated in the RCD, but that would make market access easier for the rest of the EU so having extra rules is good for business!

It has nothing to do with the operation - all to do with design / integrity and perhaps a lot of dodgy diy that people think is ok because “it’s not the sea”.

 

[Tranona]

If you look at all the ancient little motor cruisers lurking around in the backwaters of our rivers and canals you will appreciate why the BSS exists. it long predated the RDC and anything built since 1998 and not messed about by owners' improvements would have no trouble passing. The OPs boat is 1986 when Standards were cars owned by lingerie salesmen.

 

[LittleSister]

. . .The OPs boat is 1986 when Standards were cars owned by lingerie salesmen.

A noble profession!

 

[Chrisb62]

You can have a filler on the side of the tank, and it doesn't matter for BSS purposes whether it is at the top or the bottom of the side, but the spigot (the tubular metal bit welded onto the tank) must extend above the top of the tank. (In your case it could do this outboard of the drainage channel, but might need some bracing to provide sufficient rigidity.)

The purpose of the particular BSS fuel pipe check is to ensure that fuel always drains from the filler 'line'- in your case the flexible hose *. There is no requirement for the metal filler spigot (effectively part of the tankf itself) to drain. It is a fact of physics that wherever the metal filler is, top, side or bottom, there will always be the potential for there to be fuel in it when the tank is filled (or even over-filled a little), but it is regarded as part of the tank.

[* I think the distinction between the flexible hose and solid 'spigot' piping which is fixed to and effectively part of the tank is not immediately obvious in the checklist because the BSS checklist uses the easily conflated terms 'line' and 'pipe', but careful reading of the context; what materials are allowed for each; and finding the definitions of 'pipe' and 'hose', which are not listed alphabetically in the Glossary but unfortunately hidden under the entry for 'line'; does reveal a distinction.




i am pleased to hear that. Good luck.

Thanks for the response - I spoke to the man from the BSS who said that there was a clear distinction that BSS use between line and pipe - but not obvious to us poor amateurs! We did discuss the potential for a metal spigot projecting below the drainage channel, which would solve the problem but would need some substantial bracing. I am awaiting a view of his report to the BSS technical committee but he did accept that the risk here was very low... Remember we are dealing with boats which tend to rock and roll, so any fuel sitting in the pipe is more than likely going to drain into the tank as long as the height difference isn't too great

 

[rogerthebodger]

A more cynical person might suggest that it is:
- a way of making money
- a way to make it easier to persuade scrap boats to leave
- a way to help inland waterways boat yards to make money
- like all rules with good intentions - a cost for the good and largely ignored by the bad
- mostly replicated in the RCD, but that would make market access easier for the rest of the EU so having extra rules is good for business!

It has nothing to do with the operation - all to do with design / integrity and perhaps a lot of dodgy diy that people think is ok because “it’s not the sea”.

I am one of those cynical people.

Is BSS law. is it compulsory.
Is the inspection free of is there a fee to be paid.
Are the inspectors appointed by a legal body.

I have no issue with complying with the law but a requirement to comply with the law must be paid for from our Taxes that we pay for the government to administer the law of the country

Some will not agree with me, but it is my personal opinion and s far as I am concerned in most free countries like EU and UK we have the right to our opinion and freedoms

If the forum rules of the Mods do not all of us to express our opinion where is our freedom doing ?

 

[Tranona]

I am one of those cynical people.

Is BSS law. is it compulsory.
Is the inspection free of is there a fee to be paid.
Are the inspectors appointed by a legal body.

I have no issue with complying with the law but a requirement to comply with the law must be paid for from our Taxes that we pay for the government to administer the law of the country

Some will not agree with me, but it is my personal opinion and s far as I am concerned in most free countries like EU and UK we have the right to our opinion and freedoms

If the forum rules of the Mods do not all of us to express our opinion where is our freedom doing ?

No need to go all high and mighty about this. The BSS is very specific to inland waterways (canals and rivers) in the UK. It was set up in response to the high level of accidents resulting from poorly designed and maintained fuel and gas and electrical systems on boats in the network. There is nothing contentious about the requirements and the EA and CRT who control the waterways are perfectly within their rights to require safety inspection as a condition for granting a licence to use the waterways. There are exemptions for temporary licences, for example for a seagoing boat to enter the controlled waterways, particularly the Thames for short periods. It is self funding as there is a charge for the inspection - so no taxpayers money involved.

The problems arise mainly for old boats which were built before there were any standards and often need complete replacements of gas and fuel systems to comply. Any modern boat built in the last 20 years or so (and many earlier) meet the requirements as originally built and the regular inspections are there to ensure they are maintained properly.

It does not apply to boats outside the system, primarily because there is no way of enforcing it plus the accident rate from these sources is tiny compared with inland waterways, at least in the waterways where it applies.

 

[rogerthebodger]

We unfortunately have legislation that required out boats both sea going and on inland water to be inspected every year and as its legislated we have no alternative. This also applied to out equivalent to your RYA.

I have lost touch with the UK consumer protection legislation but have detailed knowledge with our CPA and its restriction and what a supplier of services can and cannot do its basis is to protect the consumer from any deceptive and abusive conduct.

one issue is that our CPA protects the consumer who enter into an agreement with anyone who provided a service to the consumer cannot require the consumer to enter into an additional agreement with a third party supplier

A example of this is that if I wish to enter a yacht race, I am all my crew MUST ALL be a member of our equivalent of RYA and to agree to partake in most yacht races I must pay our RYA a fee which contravention of our CPA

I used to boat on the cannels in the UK and concentrated on the BCN around Birmingham and know about licensing to use their facility but. The right to inspection I understand but is right for the user to be charges and extra fee for that inspection.

Afterall when a police officer stops you on the road to check they you have a valid driving license, Road funs license of in your case insurance there is no fee for that check unless you are in breach of the law in which their case some fine or court attendance will be required.

Please have a look at the rights of a consumer in the UK /EU and the requirements for sailors to enter into RYA controlled events as in Word Sailing Regulation 19.

Within our CPA there are clauses the protect the consumer from certain unlaw clauses within agreement between a supplier and the consumer which most consumers are not aware of suppliers don't wish to accept.

Its all about the rights of the individual consumer and sailor which to me is being slowly eroded