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Old 07-17-2016, 06:10 AM   #41
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It is completely beyond my comprehension to think a BC, dry chem extinguisher that is sold with one type of bracket versus one sold with a clamping bracket is any different in design or use...especially if it says so right on the extinguisher it is the same IF sold with a different bracket. So safety is right off the table.

I am somewhat trained in shipboard fire fighting, have personally fought several boat fires and been involved with dozens more. If my insurance company thinks that additional large fire extinguisher which is the same exact model as the ones on the commercial boats I work on (in welded up brackets or in a bin)....that the USCG seems to have no issue with.....neither do I ....and I will bet neither will my insurance company.


So for the OP, if you have refillable fire extinguishers with inspection tags (or get tags from a fire extinguisher business) and every 30 days or so put your initials and date on them. That meets NFPA 10 for a recreational boat as far as I can tell and you are done. Or just take the extigushers to that store and have them inspect and tag them for a small fee. I have seen it done dozens of times for the commercial fleet I work for and is no different than you looking to see if they have pressure and are in reasonable condition. They used to hit them, maybe they still do, but in the link I provided it seems to be a myth that it is needed.
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Old 07-17-2016, 06:59 AM   #42
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Here is the reference to the Rules for small passenger vessels "Sub-chapter T". Note that this is applicable to inspected small passenger vessels of less than 100 GT. 46 CFR 181.120. Basically excess fire equipment is required to meet the same criteria as required equipment in regards to inspection and maintenance. My mistake on the earlier reference in that I spent most of my time on tank vessels.

Once again, it is up to the insurance company as to what they are requiring to issue their policy and not necessarily an enforceable action by USCG.
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Old 07-17-2016, 07:38 AM   #43
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Sure...the insurance company always can make their own requirements....


But 46 CFR 181.120 applies to passenger vessels and doesn't even require the extinguishers to be mounted in the bracket that is sold with them...as long as they are "secure"...so if you toss the bracket...no one has any idea whether your extinguisher meets the requirement for "selling it" or not.


The inspection tag issues was addressed.....


I really think this has become a debate over nothing.....
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Old 07-17-2016, 07:51 AM   #44
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I don't feel as though I was debating anything. I had stated that the surveyor was probably going on the fact that excess un-inspected/maintained fire extinguishers should be removed from the boat. You had asked if I had that "in writing anywhere". I provided three locations where it was written for reference purposes. One ref. was indeed for tank vessels which is where I spent most of my time and the regs. were readily available.

While recreational vessels are not subject to the requirements of inspected vessels the insurance company may require it meets NFPA and/or CG requirements for inspected vessels. I was simply providing you with the locations where those requirements are "in writing". I did not consider it a debate, simply providing the information that you had requested in writing.
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Old 07-17-2016, 07:55 AM   #45
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Old 07-17-2016, 09:27 AM   #46
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Ok....reread your first post and realized that the discussion of extra and unserviceable got a little clouded in my mind.


But none of the references mean a thing in my book...as they don't apply to rec vessels.


Only what your insurance company requires seems to matter...and after rereading my policy and my last boats (also a liveaboard)....nowhere in either policy does it mention safety gear. The only mention of it was concerning the survey and only what the surveyor recommended (whether he was right or wrong). Several items I knew the surveyors had overstepped their bounds and I discussed and got the insurance company to agree on....such as meeting current ABYC recommendations versus being an older boat. I upgraded eventually but I wasn't going to have them done prior to using the boat. This is somewhat common, but some insurance companies dig in their heels.


So I have to assume as long as I meet USCG safety requirements for a recreational vessel, I am OK, but encourage others to get in writing exactly what their insurance requires.
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Old 07-17-2016, 10:49 AM   #47
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This illustrates an inherent problem with the surveyor/insurance industry relationship that all of us need to take very seriously and address with the insurance companies. Some years ago, they gave the SAMS/NAMS umbrella groups exclusive access to the boat survey function. They also abdicated oversight of standardization within those groups. As a result, there are inspectors running around with ABYC and other "regulations" and "requirements", and wlly nlly referencing them in their reports. That leaves YOU, the boat owner, stuck with making the case that X and Y items in a survey are inappropriate. Unfortunately, when the insurance companies abdicated technical oversight, they also eliminated knowledgeable internal technical staff who can referee inconsistencies. Who gets left holding the bag ($$$)? The boat owner.

I agree with PSNEELD....talk to your insurer and be armed with regulations to back up your grievances. Make it clear that elements of the surveyor community has run amuck. Point out that surveyors should be looking at condition of the boat and weighing it against the original design that was approved when the boat was put in service. That doesn't include additional safety equipment such as the number of life preservers on board, for example. If a surveyor wishes to address fire extinguishers, they should do so off-line and not in a survey report. Insurance companies need to hear what's going on out there, and the surveyor community isn't going to do it...that much is obvious.


Further, it is incongruous that a surveyor is qualified to set a value on a boat. "Excellent, good, poor" qualifiers, maybe. But a number value, no.
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