Will my documents be held in confidence?
The American Bureau of Shipping has always maintained a policy of complete cooperation with those involved in the administration of justice and will continue to do so in the future. However, the confidential relationship between a professional and his/her client must be protected against the unwarranted invasions of competitors and prospective suitors insofar as they are unwilling to comply with the formalities of the established body of justice. For this reason, the American Bureau of Shipping has consistently refused to disseminate unpublished information acquired by it as a representative of its clients except where a client has given his/her consent to the release of information or where disclosure is required by judicial order, governmental order or regulation, subpoena or direction of a governmental agency with subpoena power.
Who may apply for ABS Type Approval?
The ABS Policy on Approval of Equipment and Spare Parts is that ABS requires the Original Equipment Manufacturer (OEM) to demonstrate to ABS the compliance of the equipment and its parts with the ABS Rules. Any modifications of an ABS approved design must be at the approval of the OEM.
What is the ABS policy and procedure towards secondary manufacturers and relabelling?
In Type Approval we are obliged to strictly follow the entities of the designer, or OEM and secondary OEMs and product category and model identification Thus:
- The Type Approval data base is set up based on a World Wide Client Number (WCN) and that WCN must be the physical location of either the designer or the manufacturer.
- The WCN is further categorized by a specific product name, In general, the product is defined as a "thing produced by labor or effort" or the "result of an act or a process".
- The product is further categorized as a model, identified by the Manufacturer or the Designer. Several models may share the same intellectual property and be listed under the same Product.
- An assessment is made of the model against the intended use as provided by the Manufacturer or Designer, and the specific Rules, Guides or Standards associated with the Product.
- When an assessment is satisfactorily completed, the Model is assigned a serialized Design Assessment Certificate (PDA).
- The PDA is assigned to the WCN of the entity that will have control of the product and its specifications.
- If the entity that owns the PDA is also the manufacturer of the PDA, then the Manufacturing Assessment Certificate is also assigned to that WCN.
- If the entity that owns the PDA decides to subcontract the PDA, then the secondary entity must be a manufacturer. The secondary entity must apply for a Duplicated Product Design Assessment.
- As set up our Policies and Procedures do not allow for Re-Branding of PDAs.
Do my subcontractors require an ABS audit?
When ABS learns that a manufacturer will be "outsourcing" a portion of its product to a controlled supplier our concern is who will do the final manufacturing steps, inspection, packaging and shipping. If it is done at the manufacturer's facility, and the manufacturer is an ISO 9001 facility; it is not necessary for a controlled supplier to have an ABS Manufacturing Assessment conducted at its facility. Quality Management System (ISO 9001) makes the manufacturer responsible for auditing and controlling its suppliers.
Why does my design certificate have a different validity date from my Confirmation of Type Approval?
The ABS Type Approval Program is modeled after the IMO's and EU's programs. Both require a certificate for design and a certificate for manufacturing that together define the product as being "Type Approved." In the EU program, each product must be issued both certificates. When a second approval is done, an individual Design Module is required; the second product may be listed on the manufacturing Module.
Due to the expired time between the issue of the certificate of design and the first opportunity for a surveyor to witness a type test of the product, it is virtually impossible to synchronize these dates. Once a client starts to add more products the problem arises of when to conduct the audits of the individual manufacturing assessments.
In order to streamline the ABS Program, one certificate of management is valid for similar products that have a valid certificate of design. In this manner the manufacturer has the flexibility to add or remove products from its portfolio without affecting the status of the remaining products. Therefore, each individual listing will have as a minimum a Product Design Assessment. The dates of validity for these products will vary according to the date they were issued.
Is ISO 9000 required for ABS Type Approval?
Yes. The company has to be ISO certified. or have an equivalent certified management system that must be certified by an accredited third party; this will be approved by ABS on a case by case basis. If the manufacturer asks for a scheme of self inspection, then compliance with the most recent ISO9000 Standard is mandatory.
How does a product qualify to be called "ABS Type Approved Product"?
The product must have both a valid and current design approval and a valid and current Manufacturing Assessment"
Who can use the ABS Type Approved Program Logos?
When a product has received a Product Design Assessment (PDA) it is eligible
to use the Design Assessed logo.
When a manufacturer has a PDA and has completed a satisfactory Manufacturing Assessment (MA) the product is then eligible for a Confirmation of Type Approval and the Type Approved Product Logo may be used.
It must be understood that both logos are copyrighted and their use must be controlled as follows:
- Both logos are not to be used at the same time. The Type Approved Product
logo takes precedence and is to be used whenever the manufacturer has a valid
MA and PDA. In the absence of an MA only the Design Assessed logo may be used
when the manufacturer has a valid PDA.
- Any advertisement or other use of the logos is to be presented to ABS Programs
for review prior to use.
- The logos may only be used on correspondence, advertising and promotional
material and must not be used except in connection with those goods or services
defined in the scope and conditions of the Product Design Assessment certificate.
- The logos may be used only on those materials (i.e., internet site, letterhead,
marketing literature, advertising, invoice stock forms, packaging, etc.) relating
to the particular facility and process/product lines included within the Confirmation
of Type Approval.
- The logos may not, under any circumstances, be used directly on or closely
associated with products in such a way as to imply that the products themselves
are unit-certified by ABS.
- If used with other logos, ABS may ask that the manufacturer discontinue any use of other logos that are unacceptable to ABS and any form of statement that, in the opinion of ABS, might be misleading.
- Upon the termination of certification, for whatever reason, the manufacturer
must begin to immediately discontinue all use of the logos and to destroy all
stocks of material on which they appear.
- When advertising the product as ABS Type Approved the manufacturer's name, if different from the parent company, is to be used in conjunction with this logo. Any use should be specific to the process/product line covered and not represented as a blanket approval of the company.
- The logo may be scaled uniformly to any size necessary. The color of the logo shall be either black or Pantone 294 blue.
- Logos are available by email from firstname.lastname@example.org.
Does Product Type Approval replace Conformity Assessment?
In the scope of product assessment, the product either requires Unit Certification or it does not. Product Type Approval makes it a bit easier to do the shop inspections. However, one must be careful to recognize that Type Approval may be required by certain standards in order to complete Conformity Assessment.
I am ISO 9000 certified, why must I also be audited by ABS?
Both ISO 9000 and ISO 14000 concern the way an organization goes about its work, and not directly the result of this work. In other words, they both concern processes, and not products - at least, not directly. Nevertheless, the way in which the organization manages its processes is obviously going to affect its final product. The management system standards in these families state requirements for what the organization must do to manage processes influencing quality (ISO 9000) or the processes influencing the impact of the organization's activities on the environment (ISO 14000).
Therefore, if we are going to accept ISO 9000 certification it must be in conjunction with some form of product specific audit that is based on our Rules. In our Type Approval process we do not require ISO 9000. Recognized Quality System (RQS) is simply a system that has been certified to ISO 9000 or equivalent.
Just what is EU type approval?
As a point of order, EU and all other class Type Approvals require the approval of a design + the approval of the manufacturer. It is more correct to refer to the EU Module B as "A Type-Examination certificate" not as a Type Approval certificate.
When a product has the Wheelmark, and it is to be used on an EU flagged vessel, all class societies must accept it at face value.
When a Wheelmarked product is not to be used on an EU flagged vessel, the usual restriction ABS will have is for the surveyor to be contacted prior to installation in order to obtain the surveyor's acceptance for the specific application on ABS classed vessels and as allowed by the Flag of the vessel. The surveyor will also verify that the non EU Government has no specific requirements in addition to the ones used in EU approvals.
What is a limited approval?
When a Product Design Assessment Certificate expires or is superseded by a Rule or specification change, the option of maintaining the listing in the category of Product Design Assessment, Limited (PDA Ltd.) is available. There will be two categories in this PDA Ltd:
- A product that has expired is pending renewal and requires technical revalidation prior to being used. The term of validity will be one year from the date of expiration of the PDA.
- A product that will be listed as in compliance with a previous Rule and remains valid only for vessels contracted on or before the effective date of the Rule. The effective date will be included in the service restrictions of the product. The term of validity will be five years subject to continued compliance with the applicable Rule.
Does ABS approve After Market Parts?
The responsibility for compliance of an equipment design approved to ABS Rules lies with the OEM. Continued suitability for use is the responsibility of the owner. The owner is responsible for the choice of replacement parts and the suitability for use and continued warranty of the equipment with the OEM. Modifications to the equipment, such as the use of spare parts not licensed by the Original Equipment Manufacturer (OEM), may jeopardize the vessels classification and compliance with International Regulations.
What are the relations between a design review letter, a PDA and Unit Certification?
A design review letter is the approval of a material, component, product or system for a specific installation on a vessel, MODU or facility. It is typically a one time approval. Normally, a surveyor then witnesses the manufacture of the item and approves its use (Unit Certification).
A Product Design Assessment (PDA) is an assessment it is not an approval. The PDA is a generic assessment of materials, components, products or systems for a specific use in compliance with the Rules, Guides and recognized standards.
In the absence of a known vessel, MODU or facility, materials, products, components and systems cannot be fully "Approved". These particular products have generic approvals to provide clients and ABS with pre-approvals of products that will help to reduce back logs and expedite final approvals.
Final approval is given when an Engineer or Surveyor accepts the assessed item for a specific user and installation. Therefore, the PDAs are written assuming that the end user and installation of the product is unknown, and that the manufacturer may or may not apply for a Manufacturing Assessment.
What is the difference between an Approved Product and Type Approved Product?
When ABS Rules ask for an "Approved Product" it means a product that requires either a technical evaluation or a survey. Normally the technical evaluation is reported in a design review letter (DRL) and is limited to a specific application.
If a client wants a generic approval, then a Product Design Assessment (PDA) is issued.
When ABS Rules ask for "Unit Certification"; then a surveyor would use either the DRL or the PDA and conduct a manufacturing survey at the plant, and in turn issue a vendor's report.
At this time ABS Rules do not require "Product Type Approval" for any products. You will find that some societies do require Product Type Approval, and it is becoming a more frequently seen requirement in SOLAS and the MED.
What is Unit Certification?
This is defined as "where required by the Rules; after assembled to a complete assembly unit or subassembly unit, each production unit of equipment, used in the classification of a vessel, is to be tested at the manufacturer's shop in the presence of the surveyor to verify the tests required by the Rules were satisfactorily completed"
What is the limitation of a Product Design Assessment?
One of the misconceptions about ABS Type Approval is that many believe when they have Design Assessed or Type Approved products it is a carte blanche for use of the product. A Product Design Assessment (PDA) is not an approval. The PDA is a generic assessment of materials, components, products or systems for a specific use in compliance with the Rules, Guides and recognized standards. In the absence of a known vessel, MODU or facility, materials, products, components and systems cannot be fully "Approved". These particular PDAs have generic approvals to provide clients and ABS with pre-approvals of materials, components, products or systems that will help to reduce backlogs and expedite final approvals. Final approval is given when an engineer or surveyor accepts the PDA for a specific user and installation. Therefore, the PDAs are written assuming that the end user and installation of the product is unknown and the manufacturer may or may not apply for a Manufacturing Assessment.
What is ABS' definition of asbestos?
There is no definition of asbestos in SOLAS (or the ABS Rules). You may wish to be guided by the definition that refers to the six mineral names (with CAS numbers) which is consistent with the definition of asbestos as provided by OSHA, the EU and the USCG/EPA.
- Actinolite CAS 77536-66-4
- Amosite (Grunerite) CAS 12172-73-5
- Anthophyllite CAS 77536-67-5
- Chrysotile CAS 12001-29-5
- Crocidolite CAS 12001-28-4
- Asbestos Tremolite CAS 77536-68-6