[PSUBS-MAILIST] Personal_Submersibles Digest, Vol 140, Issue 5
via Personal_Submersibles
personal_submersibles at psubs.org
Mon Aug 11 17:52:10 EDT 2025
Hi Jon,
It is time to review the options. Carsten Standfuss is an inspector for
Swiss Lloyds, which have recognition for small submersibles such as ours.
Although I do not have a certified sub, I have followed a path of genuine
attempt to comply with ABS and GL limited by my budget.
The extent to which I have gone is in keeping with what I understand as
Carsten's requirements as follows:
1. Designed to comply with ABS,
2 Designed to ASME PVHO-1 2007
3. Passed FEA from Predictive Engineering for ASME / ABS approval
4. Manufactured PVHO with full inspection and pressure testing to 1.3
times Max depth, witnessed by SGS.
5. Employed consultant and specs for manufacture of fibreglass integral
craft
6. Have Lloyds approved manufacture of viewports
7. Full manufacturing drawings
8. Maintenance manual
9. Operating manual
10. Stability Calculations (to be supported by stability testing)
11. Testing regime ( To be completed)
12. Ability to meet life support for 72 / 96 hrs (ABS / GL Req.)
While it is cost prohibitive for some others to have similar claims, it may
be possible for P-subs to have an inspector to get qualified to do an
inspection similar to Carsten's position.
Could we engage with the USCG and others to demonstrate and get an approval
they are happy with. Pleasure craft are able to pursue their enjoyment as
are microlight aircraft.
Could we have a questionnaire derived from Cliff's, design/build, Kittredge
subs and some others that if signed off show responsible builds, and some
form of inspection.
Hugh
-----Original Message-----
From: Personal_Submersibles <personal_submersibles-bounces at psubs.org> On
Behalf Of via Personal_Submersibles
Sent: Tuesday, 12 August 2025 7:06 am
To: personal_submersibles at psubs.org
Subject: Personal_Submersibles Digest, Vol 140, Issue 5
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Today's Topics:
1. Re: PC2026 Announcement (Jon Wallace via Personal_Submersibles)
2. Re: USCG Marine Investigation Report and Ramifications
(via Personal_Submersibles)
3. Re: USCG Marine Investigation Report and Ramifications
(Alan James via Personal_Submersibles)
----------------------------------------------------------------------
Message: 1
Date: Fri, 8 Aug 2025 12:55:34 +0000 (UTC)
From: Jon Wallace via Personal_Submersibles
<personal_submersibles at psubs.org>
To: Personal Submersibles General Discussion
<personal_submersibles at psubs.org>
Subject: Re: [PSUBS-MAILIST] PC2026 Announcement
Message-ID: <226535686.3338020.1754657734701 at mail.yahoo.com>
Content-Type: text/plain; charset=UTF-8
IMPORTANT NOTICE - DATE CHANGE
We have changed the dates of PC2026 to Feb 11-14, 2026 to take advantage of
sea conditions.? Details will be posted later however Technical Sessions are
planned for Saturday Feb 14.??
Jon
------------------------------
Message: 2
Date: Mon, 11 Aug 2025 15:19:20 +0200
From: via Personal_Submersibles <personal_submersibles at psubs.org>
To: "'Personal Submersibles General Discussion'"
<personal_submersibles at psubs.org>
Subject: Re: [PSUBS-MAILIST] USCG Marine Investigation Report and
Ramifications
Message-ID: <00e501dc0ac2$8d2c5be0$a78513a0$@airesearch.nl>
Content-Type: text/plain; charset="UTF-8"
Thanks Jon, Will read it for sure!
Br, Emile
-----Oorspronkelijk bericht-----
Van: Personal_Submersibles <personal_submersibles-bounces at psubs.org> Namens
Jon Wallace via Personal_Submersibles
Verzonden: woensdag 6 augustus 2025 18:48
Aan: Personal Submersibles General Discussion
<personal_submersibles at psubs.org>
Onderwerp: [PSUBS-MAILIST] USCG Marine Investigation Report and
Ramifications
Psubbers,
This is a long message, but please read.
The US Coast Guard has released their Marine Investigation report of the
Titan submersible implosion at
https://media.defense.gov/2025/Aug/05/2003773004/-1/-1/0/SUBMERSIBLE%20TITAN
%20MBI%20REPORT%20(04AUG2025).PDF
Since this report is going to generate chatter throughout the submersible
industry I thought it appropriate to make a statement and start an official
discussion relative to our own organization.
Now that the Marine Boards report is public we are sure to see an uptick in
attention to the operation of our vessels and potentially some movement to
save ourselves, from ourselves, and need to be proactive in addressing this
issue rather than allowing some other agency or organization to define our
future. While we are not the largest organization in the world, we ARE the
largest organization in the world associated with private submersible
fabrication, operation, and ownership and therefore have standing to be
recognized and heard regarding any government regulation that might affect
us.
>From PSUBS beginning it has always been my position, and still is, that
private recreational use of our vessels is difficult for the government to
regulate due to the ?pursuit of happiness? founding principles of the USA.
It is my opinion, for example, that this was one reason recreational
submersibles had a specific section carved out for them in USCG NVIC 5-93
(see Chapter 1, B, 4) and were equated to pleasure surface boats.
To wit:
USCG NVIC 5-93, Chapter 1, B, 4
?Recreational vessels, as defined in 46 U.S.C. 2101(25), are vessels
manufactured or operated primarily for pleasure, or leased, rented, or
chartered to another for the latter's pleasure. Submersibles within this
category are subject to the requirements of 33 CFR Subchapter S - Boating
Safety, Parts 173-183. The guidelines in this circular generally do not
apply; however, depending on the area of operation, COTP operating
restrictions may be appropriate. This will be evaluated on a case-by-case
basis. These guidelines may be of assistance to a manufacturer or owner of a
recreational submersible.?
As optimistic as I am regarding our rights as private submersible owners,
the Titan disaster does represent a potential impact to us and we should
have a message ready to deliver to the US Coast Guard to protect our
interests. Specifically, I have concerns related to carrying passengers
(not for hire) and impacts to private submersibles participating in research
and/or acting as a non-passenger commercial operator. We enjoy quite a bit
of latitude given the language of NVIC 5-93, 1, B, 4 and it should be our
goal to preserve it as currently written.
The USCG Marine Investigation Board made 14 safety recommendations to the
USCG Commandant. While the majority of these recommendations target vessels
conducting commercial and oceanographic research operations, the following
draw my concern as potential serious impacts to our PSUBS related pursuits.
8.1.1. Recommendation #1: The USCG should establish an industry working
group to review and update NVIC 5-93. During the investigation, submersible
industry leaders indicated to the MBI that current USCG limitations on
operating parameters, including the maximum depth of 150-feet for Coast
Guard inspected passenger submersibles, was stifling submersible owners from
exploring new passenger operations in U.S. navigable waters and also
potentially incentivizing operators like OceanGate to conduct non compliant
operations. An update to the NVIC would also provide an opportunity to
clearly outline the process for certifying submersibles of novel design.
PSUBS POSITION
PSUBS *must* be included in any working group the government creates to
update NVIC 5-93 and/or create regulations that may impact us. We cannot
afford to sit idly by and allow ?industry leaders? and/or the government
itself to revise this document without our input. It is notable that the
USCG regularly attends the MTS Underwater Intervention and participates in
discussions with MUV commercial attendees; however the USCG has never
accepted an invitation to a PSUBS convention. Regrettably, we own some
responsibility for lack of communication with the USCG since we have often
taken the philosophy of ?let sleeping dogs lie? and ?out of sight, out of
mind? when considering our interaction with them; however I think we can no
longer afford to take this approach. This month I will be writing the USCG
Commandant seeking inclusion of a PSUBS representative in any working group
organized to review NVIC 5-93 and/or any other regulatory act that may
impact our organization. Addit!
ionally, I will be requesting the USCG send a representative to PC2026 to
conduct discussions with PSUBS members regarding issues and concerns
relative to our segment of the submersible industry and to start fostering
communication between us.
8.1.6. Recommendation #6: The USCG should pursue a new regulation which
requires all submersibles manufactured, owned, or operated by a U.S. entity
or any submersible operating in U.S. navigable waters carrying any occupant
other than the owner to be built to the standards of a USCG RO and
maintained under those standards.
PSUBS POSITION
Any language requiring certification for privately owned submersibles is a
serious detriment to our pursuits since from a financial perspective it
essentially is a show stopper. This recommendation goes well beyond the
current wording in NVIC 5-93 which clearly demarcates commercial, passenger
carrying, and recreational submersibles. If implemented as suggested it
would prevent us from carrying our own spouses, families, and friends as an
occupant unless the vessel was certified. It is PSUBS position that this
unreasonably restricts our right to pursue sharing our hobby with voluntary
passengers who are not for hire.
8.1.7. Recommendation #7: The USCG should pursue an update to the vessel
documentation requirements in 46 CFR ? 67.7, to require all U.S.
submersibles that conduct commercial or scientific operations to obtain a
USCG Certificate of Documentation (COD) with an Official Number assigned and
recorded in the MISLE database.
PSUBS POSITION
We currently have a number of privately owned submersibles that are used to
conduct various types of research, free of charge, for universities and
science organizations whom have a need for a deep diving vessel beyond the
range of SCUBA. This recommendation by the Marine Investigative board could
have severe impact on those missions and it is PSUBS position that this
recommendation unreasonably restricts a private submersible owner from
providing a donated service targeted for the advance of science.
WHAT YOU NEED TO DO (right now)
Minimally all PSUBS members should read the ?Recommendations? section of the
USCG Marine Investigation Board starting on page 324 and consider how this
impacts you personally or our organization and raise it as a concern if it
has not been addressed already.
Additionally, start thinking now about issues and concerns we should address
with the USCG at PC2026 in February. The more that we can speak with one
consistent message in terms of specific issues that we feel need to be
preserved or modified to our benefit, the better we will present ourselves.
Jon
_______________________________________________
Personal_Submersibles mailing list
Personal_Submersibles at psubs.org
http://www.psubs.org/mailman/listinfo.cgi/personal_submersibles
------------------------------
Message: 3
Date: Mon, 11 Aug 2025 19:05:51 +0000 (UTC)
From: Alan James via Personal_Submersibles
<personal_submersibles at psubs.org>
To: Personal Submersibles General Discussion
<personal_submersibles at psubs.org>
Subject: Re: [PSUBS-MAILIST] USCG Marine Investigation Report and
Ramifications
Message-ID: <1125630987.4293670.1754939151037 at mail.yahoo.com>
Content-Type: text/plain; charset="utf-8"
To put it in perspective, in 2024 there were 556deaths in the USA attributed
to recreational boating accidents, and 300,000 drowning deaths World
wide.?Most of those deaths could have been prevented if everyone wore life
jackets while?swimming & boating. But no one is going toagree to that.Alan
Yahoo Mail: Search, organise, conquer
On Tue, 12 Aug 2025 at 1:21 am, via
Personal_Submersibles<personal_submersibles at psubs.org> wrote: Thanks Jon,
Will read it for sure!
Br, Emilegoing?
-----Oorspronkelijk bericht-----
Van: Personal_Submersibles <personal_submersibles-bounces at psubs.org> Namens
Jon Wallace via Personal_Submersibles
Verzonden: woensdag 6 augustus 2025 18:48
Aan: Personal Submersibles Generalre? ?Discussion
<personal_submersibles at psubs.org>
Onderwerp: [PSUBS-MAILIST] USCG Marine Investigation Report and
Ramifications
Psubbers,
This is a long message, but please read.
The US Coast Guard has released their Marine Investigation report of the
Titan submersible implosion at
https://media.defense.gov/2025/Aug/05/2003773004/-1/-1/0/SUBMERSIBLE%20TITAN
%20MBI%20REPORT%20(04AUG2025).PDF
Since this report is going to generate chatter throughout the submersible
industry I thought it appropriate to make a statement and start an official
discussion relative to our own organization.
Now that the Marine Boards report is public we are sure to see an uptick in
attention to the operation of our vessels and potentially some movement to
save ourselves, from ourselves, and need to be proactive in addressing this
issue rather than allowing some other agency or organization to define our
future.? While we are not the largest organization in the world, we ARE the
largest organization in the world associated with private submersible
fabrication, operation, and ownership and therefore have standing to be
recognized and heard regarding any government regulation that might affect
us.
>From PSUBS beginning it has always been my position, and still is, that
private recreational use of our vessels is difficult for the government to
regulate due to the ?pursuit of happiness? founding principles of the USA.?
It is my opinion, for example, that this was one reason recreational
submersibles had a specific section carved out for them in USCG NVIC 5-93
(see Chapter 1, B, 4) and were equated to pleasure surface boats.
To wit:
USCG NVIC 5-93, Chapter 1, B, 4
?Recreational vessels, as defined in 46 U.S.C. 2101(25), are vessels
manufactured or operated primarily for pleasure, or leased, rented, or
chartered to another for the latter's pleasure. Submersibles within this
category are subject to the requirements of 33 CFR Subchapter S - Boating
Safety, Parts 173-183. The guidelines in this circular generally do not
apply; however, depending on the area of operation, COTP operating
restrictions may be appropriate. This will be evaluated on a case-by-case
basis. These guidelines may be of assistance to a manufacturer or owner of a
recreational submersible.?
As optimistic as I am regarding our rights as private submersible owners,
the Titan disaster does represent a potential impact to us and we should
have a message ready to deliver to the US Coast Guard to protect our
interests.? Specifically, I have concerns related to carrying passengers
(not for hire) and impacts to private submersibles participating in research
and/or acting as a non-passenger commercial operator.? We enjoy quite a bit
of latitude given the language of NVIC 5-93, 1, B, 4 and it should be our
goal to preserve it as currently written.
The USCG Marine Investigation Board made 14 safety recommendations to the
USCG Commandant.? While the majority of these recommendations target vessels
conducting commercial and oceanographic research operations, the following
draw my concern as potential serious impacts to our PSUBS related pursuits.
8.1.1. Recommendation #1: The USCG should establish an industry working
group to review and update NVIC 5-93. During the investigation, submersible
industry leaders indicated to the MBI that current USCG limitations on
operating parameters, including the maximum depth of 150-feet for Coast
Guard inspected passenger submersibles, was stifling submersible owners from
exploring new passenger operations in U.S. navigable waters and also
potentially incentivizing operators like OceanGate to conduct non compliant
operations. An update to the NVIC would also provide an opportunity to
clearly outline the process for certifying submersibles of novel design.
PSUBS POSITION
PSUBS *must* be included in any working group the government creates to
update NVIC 5-93 and/or create regulations that may impact us.? We cannot
afford to sit idly by and allow ?industry leaders? and/or the government
itself to revise this document without our input.? It is notable that the
USCG regularly attends the MTS Underwater Intervention and participates in
discussions with MUV commercial attendees; however the USCG has never
accepted an invitation to a PSUBS convention.? Regrettably, we own some
responsibility for lack of communication with the USCG since we have often
taken the philosophy of ?let sleeping dogs lie? and ?out of sight, out of
mind? when considering our interaction with them; however I think we can no
longer afford to take this approach.? This month I will be writing the USCG
Commandant seeking inclusion of a PSUBS representative in any working group
organized to review NVIC 5-93 and/or any other regulatory act that may
impact our organization.? Addit!
ionally, I will be requesting the USCG send a representative to PC2026 to
conduct discussions with PSUBS members regarding issues and concerns
relative to our segment of the submersible industry and to start fostering
communication between us.
8.1.6. Recommendation #6: The USCG should pursue a new regulation which
requires all submersibles manufactured, owned, or operated by a U.S. entity
or any submersible operating in U.S. navigable waters carrying any occupant
other than the owner to be built to the standards of a USCG RO and
maintained under those standards.
PSUBS POSITION
Any language requiring certification for privately owned submersibles is a
serious detriment to our pursuits since from a financial perspective it
essentially is a show stopper.? This recommendation goes well beyond the
current wording in NVIC 5-93 which clearly demarcates commercial, passenger
carrying, and recreational submersibles.? If implemented as suggested it
would prevent us from carrying our own spouses, families, and friends as an
occupant unless the vessel was certified.? It is PSUBS position that this
unreasonably restricts our right to pursue sharing our hobby with voluntary
passengers who are not for hire.
8.1.7. Recommendation #7: The USCG should pursue an update to the vessel
documentation requirements in 46 CFR ? 67.7, to require all U.S.
submersibles that conduct commercial or scientific operations to obtain a
USCG Certificate of Documentation (COD) with an Official Number assigned and
recorded in the MISLE database.
PSUBS POSITION
We currently have a number of privately owned submersibles that are used to
conduct various types of research, free of charge, for universities and
science organizations whom have a need for a deep diving vessel beyond the
range of SCUBA.? This recommendation by the Marine Investigative board could
have severe impact on those missions and it is PSUBS position that this
recommendation unreasonably restricts a private submersible owner from
providing a donated service targeted for the advance of science.
WHAT YOU NEED TO DO (right now)
Minimally all PSUBS members should read the ?Recommendations? section of the
USCG Marine Investigation Board starting on page 324 and consider how this
impacts you personally or our organization and raise it as a concern if it
has not been addressed already.
Additionally, start thinking now about issues and concerns we should address
with the USCG at PC2026 in February.? The more that we can speak with one
consistent message in terms of specific issues that we feel need to be
preserved or modified to our benefit, the better we will present ourselves.
Jon
_______________________________________________
Personal_Submersibles mailing list
Personal_Submersibles at psubs.org
http://www.psubs.org/mailman/listinfo.cgi/personal_submersibles
_______________________________________________
Personal_Submersibles mailing list
Personal_Submersibles at psubs.org
http://www.psubs.org/mailman/listinfo.cgi/personal_submersibles
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