Numbers Game a Hull of a Problem
What began as one BoatU.S. member’s complaint about difficulties
getting warranty service on his German-built sailboat has brought
to light a world of problems or, more accurately, a problem
of global proportions about the official hull identification
numbers (HINs) boat builders use to identify their vessels.
It all started when
the owner of a brand new 2004 Hanse 411 sloop told BoatU.S. that he was having
trouble
getting his dealer in Milford, CT, to correct some
problems that showed up at the time he took delivery. Simple, we thought. Get
in touch with the manufacturer in Greifswald, Germany, or the Hanse importer
here in the U.S. and, before we could whistle Danke Schoen , our member’s
problems would be solved.
Wrong!
When we attempted to locate
the manufacturer using the U.S. Coast Guard’s
database, there was no match for the manufacturer’s code, YZG, shown
in the boat’s hull identification number. As the story unfolded, it became
apparent that Coast Guard has some problems with marine police and marine investigators
both in the U.S. and abroad.
A word of explanation.
Federal regulations require that every boat built in the U.S. must be identified
by a unique
12-digit number. The Coast Guard assigns
each commercial boat builder a three-letter identification code, which is followed
by the boat’s serial number, the date the boat was certified to meet
manufacturing regs and its model year. [See HIN sidebar for details.] Numbers
must be placed on the starboard side of the transom and in a hidden spot inside
the boat. The HIN rules were written to enable manufacturers to identify boats
in the event of a defect recall. It is illegal to alter a boat’s HIN
once it has left the place where it was built.
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A typical hull identification number, or HIN, consists of 12 letters
and numbers, as in ABC12345D404.
Here’s what the
letters and numbers mean:
ABC: the U.S. Coast
Guard-assigned Manufacturer Identification Code. The Coast Guard’s
MIC database is online at www.uscgboating.org/recalls/mic_database.htm
12345: the hull serial
numbers assigned by the manufacturer, may be a combination of
letters and numbers; the letters “I,” “O” and “Q” are
excluded because they could be mistaken for numbers.
D: the month
of certification or manufacture. Indicates the month in which
construction began, with “A” being January
and “L” being December. In our example, “D” means
April.
4: the year of certification or manufacturer. Indicates the last
digit of the year, in this case, 2004, the boat was built.
04: the boat’s
model year. |
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Although HINs can help identify lost or stolen boats, it is difficult to track
stolen boats once they cross state lines or national borders. A U.S.-wide Vessel
Identification System similar to the decades-old National Crime Investigation
Center database for cars and heavy equipment has never been established because
each state collects different boat data and, authorities say, it would be impossible
to compile comprehensive information.
Back to the Hanse 411.
A Coast Guard spokesman told BoatU.S. that the agency had been trying to
work with the
German builder. “They have to establish
an agent in this country,” he said, so that the Coast Guard can assign
them a U.S. manufacturer’s code. It appears the German boats are coming
into the U.S. through the Hanse distributor in British Columbia. U.S. customs
agents mistakenly assume Hanse boats are Canadian-built because the manufacturer’s
identification code, YZG, starts with the letter “Y,” which the
Coast Guard assigns to boats built in Canada for importation here.
So, if you are wondering
where the YZG code came from and how a boat owner would go about locating
an overseas
manufacturer in the event of serious safety
defects, you’re on the right track. And if all of this has the whiff
of a significant security lapse, you are getting close to the heart of the
problem.
With the creation of the
European Union and with the expansion of the worldwide market for recreational
boats,
builders in about 70 countries — including
some in the U.S. — have adopted manufacturing standards developed by
the International Organization for Standardization or ISO, for short (“ISO” means “equal” in
Greek). Embedded in ISO is a HIN standard that is identical to the 12-digit
system used here in the U.S. Some builders add a two-letter country of origin
code to the HINs, for example, “US” for boats built in this country.
Apparently, this wasn’t the case with the Hanse 411 number.
“This is definitely a problem!” said a Coast Guard spokesman. “All
those EU countries are now assigning manufacturer’s codes which of course
duplicate ours. [Hanse] was assigned ‘YZG’ by the German authorities.
We are seeing boats coming in from all over the world with manufacturer identification
codes assigned by their country of origin.
“This is giving us and state law enforcement people fits,” he
said. “At first glance, they look like valid HINs, in fact, they are
valid HINs according to ISO. But when you run the manufacturer’s code,
they look suspicious. Some people have actually had their boats impounded by
the cops until it gets straightened out.”
This naturally raises the
question of why the Coast Guard doesn’t favor
expanding the HIN format, as has been urged by state marine police and insurance
investigators for over 15 years. Both the National Association of Boating Law
Administrators (NASBLA) and the International Association of Marine Investigators
(IAMI) favor adopting a 17-digit format similar to the uniform Vehicle Identification
Number (VIN) format used worldwide for automobiles. The format would include
information about the boat’s country of origin, its design and hull material,
as well as a “check digit” to prove authenticity.
“The boat manufacturers can’t get the 12-character HIN right,” we
were told by the Coast Guard spokesman. “Can you imagine if we add five
more characters? When we count violations every year, HINs are always number
one.”
"Changing over to a 17-digit number appears to be manageable, given the
right set of circumstances,” counters Dave Marlow, quality control director
for Brunswick, parent company of Sea Ray, Bayliner and a number of other builders. “It
is not a large leap for some boat makers, in fact, we are currently up to 14
digits [i.e., regular 12-digit HIN plus a two-digit country code] with the
international requirements.
He adds, “Many brands
in the Brunswick Boat Group also emboss additional information on their transoms,
such as model designations and hull ID numbers.
This is evidence that we are used to controlling a lot of information in that
area.
“One of the questions for the industry is whether existing computer
operating systems can accommodate a 17-digit HIN, along with the two additional
country code characters required by ISO,” Marlow says. “If current
computer capacity is insufficient, that could mean significant investments
to upgrade those systems."
But, if a 17-character HIN is what is required to sell boats in foreign countries,
it stands to reason that manufacturers will figure out how to comply.
"There would be a learning curve at first, but those concerns seem to
be counter to significant support for the measure being offered for the additional
identifiers by law enforcement officials and marine investigators," says
Marlow.
"A National Boating Safety Advisory Council (NBSAC) subcommittee has
been set up to discuss the suggested format, Marlow says. Members of the subcommittee
come from the Council, the National Association of Boating Law Administrators,
the International Association of Marine Investigators, the ISO group responsible
for the standard on HINs, the American Boat & Yacht Council, the Coast
Guard and the National Marine Manufacturers Association. “The main challenge
they have is how to make sure if the change is made, it is agreed upon worldwide,” Marlow
concludes.
If adopted, manufacturers would be given a date, probably several years in
advance, by which they would need to comply with the new requirements. Older
boats with different HIN formats would be grandfathered. Boat builders faced
a similar challenge in the 1970s with the passage of the Federal Boat Safety
Act, containing newly required boat building regulations. They were given several
years to comply with those the regulations.
“The HIN issue has become a nightmare because the Coast Guard will not
make a ruling on a 17-digit format,” according to Karlton Kilby, president
of IAMI and director of the BoatU.S. Seaworthy insurance program. “If
they did, ISO would follow suit.
“The EU is having
a tough time with stolen boats being remarketed or used for committing other
crimes.
The problem is so bad that ISO and the German
government have decided to implement a new numbering format, with the thought
that it would certainly be better than what is now in place. The 12-digit HIN
seems to be making things worse globally.”
His comments are echoed
by Fred Messman, Nevada boating law administrator and president of NASBLA,
who says
HIN expansion will aid in law enforcement,
identifying lost or stolen vessels and in accident reporting. In a letter to
the Coast Guard, Messman wrote, “The present 12-character HIN has been
outdated and obsolete in our global marketplace.”
The Coast Guard does not
support modifying HIN format, Messman told BoatU.S. “It
never has and, even when Congress told them to do it, it has not been a priority
to get it done.”
“The Coast Guard’s excuse that manufactures wouldn't comply is
because the current inspection system is also inadequate, which is not necessarily
their fault, due to lack of funding like everything else,” he commented. “The
old argument that manufacturers are unwilling has been rebuked.”
“Even [the Coast Guard’s] flawed cost benefit study said it would
cost less than a dollar per boat for companies to make the changes,” Messman
concludes.
Following the September
11 attacks and the transfer of the U.S. Coast Guard to the Department of
Homeland Security,
a significant portion of Coast Guard
resources has been devoted to protecting the nation’s ports, coastlines
and shipping from attack. Making it easier to identify boats by expanding the
current HIN requirements seems like a logical security measure. And, it could
also be a big help for folks who just want to protect their investments.
(c)
Copyright BoatU.S.
Magazine, July 2004 |