Tier I - Policy – Accepting alternative electrical standards for small electric and hybrid vessels

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1  Policy Objective

1.1  This policy allows alternative electrical standards to be used for elements not currently covered under the current Transport Canada regulatory and standards framework, for pleasure craft less than 24 metres in length and vessels, other than pleasure craft, of not more than 24 metres, and fishing vessels of not more than 24.4 metres in length and not more than 150 gross tonnage.

2  Policy Statement

2.1  Transport Canada will accept as an alternative to the existing requirements for small vessels, as set out in the Construction Standards for Small Vessels (TP 1332) or the Ships Electrical Standards (TP 127), where the current requirements do not address specific elements for electric or hybrid systems, that an equivalent marine electrical standard, rule or test, published by a listed organization is used.

2.2  A vessel’s authorized representative must make sure that the vessel’s electrical system and related machinery, equipment and components meet all applicable requirements of the alternative standards chosen. Examples of recognized standards can be found in Annex A.

2.3  Transport Canada must be able to trace the equipment and component compliance to the applicable standards through certification marking, third-party organization approval documentation, or testing records.

2.4  By using alternative standards, a vessel’s authorized representative must make sure that the alternative standards achieve an equivalent or higher level of safety to the current TCMSS requirements.

2.5  For pleasure craft and non-pleasure craft that are subject to the Small Vessel Regulations, battery powered electrical and hybrid systems must be rated for marine use and meet the requirements of the alternative standards before being used. Manufacturers and importers of pleasure craft and non-pleasure craft subject to the Declaration of Conformity process of the Small Vessel Regulations Part 8, must state which alternative standards are being used on the vessel’s Declaration of Conformity.

2.6  For vessels that aren’t subject to the Declaration of Conformity process, the authorized representatives must:

  • apply for a Marine Technical Review Board (MTRB) equivalency, and
  • make sure that the system and components meet the requirements of the alternative standards before they go into operation
    • This includes permanent or temporary electric propulsion, including experimental or novel systems

2.7  Conditions under the Marine Technical Review Board’s decision must include:

  • the alternative standard(s) chosen, and
  • the electrical propulsion system must be installed according to the manufacturer’s instructions and according to the requirements of the chosen alternative standard

3  Scope

3.1  This policy applies to vessels that are manufactured, constructed, converted, modified, altered or imported for use in Canada that are:

  • pleasure craft less than 24 m in length, or
  • vessels, other than pleasure craft, of not more than 24 meters, or
  • fishing vessels of not more than 24.4 metres in length and not more than 150 gross tonnage

4  Authority

4.1  This policy falls under the administrative authority of the Director General of Marine Safety and Security.

4.2  The Marine Safety and Security Executive Committee has approved this policy for general use.

5  Responsibility

5.1  The Executive Director of Domestic Vessel Regulatory Oversight is responsible for developing, approving and maintaining this policy.

5.2  The Manager of National Marine Safety Program – Small and Fishing Vessels Design and Construction (AMSDS) is the OPI (Office of Primary Interest) for this policy and responsible for implementing it.

5.3  Please address your comments or questions to:

Executive Director, Domestic Vessel Regulatory Oversight (AMSD)
Transport Canada
Place de Ville, Tower C
330 Sparks St
Ottawa, ON  K1A 0N8

Phone: 613-949-3819

6  Background

6.1  The commercial vessel and pleasure craft industries are using electric and hybrid propulsion systems as a way to reduce fuel consumption and carbon pollution. Battery technologies are also quickly evolving to support the growing need.

6.2  The electrical system requirements made under the Small Vessel Regulations (SVR) are limited to systems based on lead-acid or nickel-alkaline type batteries. They don’t consider requirements for other, now common, battery types which are now common as they provide a better performance than the legacy type. Under section 709 of the Small Vessel Regulations the use of alternative recommended practices and standards are allowed due to the particular design of a system or component that would be unsafe, unsuitable or impracticable to build.

6.3  Similarly, the Ships Electrical Standards (TP 127) is limited to lead-acid and nickel-alkaline type batteries. Lithium-ion battery systems approved by other marine standards are not covered in TP 127. This led to confusion around the procedures and regulations for electric and hybrid systems.

6.4  Although marine standards exist and continue to be developed, there is no official document that gives vessel builders a list of alternative standards. This has led to confusion around which standards could be used to provide an adequate level of safety.

6.5  In order to keep up with innovation and industry pressures to convert/build electric and hybrid vessels, Transport Canada is providing an alternative to the current regulatory requirements as a temporary solution until the applicable regulations are updated.

7  Date of Application 

7.1  This policy comes into effect on October 25, 2022.

8  Date for Review or Expiry 

8.1  This policy will be reviewed 12 months after it comes into effect and then at least every 5 years after.

9  RDIMS Reference

9.1  The English version of this document is saved in RDIMS under reference number 17997955. The applied naming convention is PUBLICATION – TP 13585 – POLICY - ACCEPTANCE OF ALTERNATIVE ELECTRICAL STANDARDS FOR SMALL ELECTRIC AND HYBRID VESSELS.

9.2  La version française du présent document est dans le SGDDI et porte le numéro de référence 18997487. La règle d'affectation des noms est PUBLICATION – TP 13585 – POLITIQUE - ACCEPTATION DE NORMES ÉLECTRIQUES ALTERNATIVES POUR LES PETITS BÂTIMENTS ÉLECTRIQUES ET HYBRIDES.

9.3  This is the first approved and finalized revision of the English version of this document.

10  Keywords

  • Batteries
  • Electric propulsion
  • Hybrid propulsion
  • Electrical standards
  • Lithium-Ion
  • Small vessel
  • TP 127
  • TP 1332

11  ANNEX A – Alternative Standards List

This Annex provides a list of alternative standards that can be used to meet the requirements of this policy. This list does not include every possible alternative standard. You can use other standards if the Marine Technical Review Board accept them.

The chosen alternative standard(s) of an organization must be used in its/their entirety where applicable. Standards published by other organizations can be used when incorporated by reference. The alternative standards can be used for an entire electrical distribution system as long as it meets an equivalent level of safety.

Table 1: American Boat and Yacht Council (ABYC) Standards

Standard Number

Standard Name

Type of system

A-31

Battery Chargers and Inverters

All

C-7

Battery Switches for Use on Boats

60VDC or less

E-13

Lithium-Ion Batteries

Batteries over 600Wh

E-30

Electric Propulsion Systems

more than 300VAC but less than 1000VAC

E-30

Electric Propulsion Systems

more than 60VDC but less than 1000VDC

Table 2: Institute of Electrical and Electronics Engineers (IEEE) Standards

Standard Number

Standard Name

IEEE 45

Recommended Practice for Electric Installations on Shipboard

IEEE SA – P45.1

Recommended Practice for Electric Installations on Shipboard - Design

Table 3: International Electrotechnical Commission (IEC) Standards

Standard Number

Standard Name

IEC 60092-501

Electrical Installations in Ships – Part 501: Special features- Electric propulsion plant

IEC 60092-507

Electrical Installations in Ships – Part 507: Small vessels Not exceeding 50VDC, single phase not exceeding 250VAC, 3 phase not exceeding 250VAC

IEC 60529

Degrees of Protection Provided by Enclosures

IEC 62133-2

Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary lithium cells, and for batteries made from them, for use in portable applications

IEC 62620

Secondary cells and batteries containing alkaline or other non-acid electrolytes - Secondary lithium cells and batteries for use in industrial applications

Table 4: International Organization for Standardization (ISO) Standards

Standard Number

Standard Name

ISO 16315

Small Craft – Electric propulsion system

ISO/TS 23625

Small Craft – Lithium-ion batteries

Table 5: Underwriters Laboratories (UL) Standards

Standard Number

Standard Name

UL 1642

Lithium Batteries

12  Classification Societies

American Bureau of Shipping (ABS)

  • Guide for Use of Lithium-Ion Batteries in the Marine and Offshore Industries
  • Guide for Hybrid Electric Power Systems for Marine and Offshore Installations

Det Norske Veritas (DNV)

  • Rules for Classification Part 4 Chapter 4 Electrical installations Section 5 Storage batteries Section 14 Electrical propulsion plants
  • Rules for Classification Part 6 Chapter 2 Propulsion, power generation and auxiliary systems section 1 Electrical energy storage