Could you specify which requirements? My boat has one that has been through at least 4 surveys. My understanding, from the factory paperwork, is that it was factory installed. It is vented w/water tight stack, has leak sensors, and is in a bulk headed compartment with low-level gas ventalation. Everything about the installation looks factory, down to using exactly the same plumbing and mounting methods that were used throughout.
The manufacturer is Takagi, though the specific model is out of production. 1997.
You've been lucky or had surveyors who simply look the other way or just don't know their stuff.. Factory installed does not mean much of anything as there are many boats not built to ABYC standards and many ABYC built boats that flagrantly miss items that are required..
All that matters is what is in the survey report. If your surveyors have missed it, and you like your water heater, USE THEM AGAIN!!
To be ABYC compliant the water heater must be 100% room sealed combustion. Make up air must come from outside the vessel and combustion air must vent outside the vessel. Water heaters are classified under ABYC standards as an
unattended appliance and thus need to meet the standards for an
unattended appliance.
As of yet I don't know of any on-demand LPG heater that meets the standard, though many companies lie and purposely deceive buyers...
Some considerations from the ABYC A-26:
26.5.1 LPG and CNG fueled appliances shall not be installed in spaces containing internal combustion engines,their fuel tanks, or joints and fittings of their fuel systems.
26.5.3 Appliances shall meet the combustion requirements of ANSI Z 21.57 Recreational Vehicle Cooking Gas Appliances.
26.5.4 Printed instructions for proper installation, including air intake and exhaust systems, operation, and maintenance shall be provided with each appliance.
26.5.4.1 The instructions shall include information on the risks associated with the air consumption of the appliance, and
26.5.4.1.1 venting of combustion products from the appliance.
26.5.5 A burner system shall be capable of operation without creating a fire hazard during periods of boat pitch and roll, at angles up to 30° from horizontal in any direction, and continuous operation at angles of heel up to 30°.
26.5.6 Operating controls shall be located to be easily accessible, and to minimize possible injury from burners or elements when being used.
26.5.7 Appliance controls shall be designed to require a push-turn or other two phase operation when going from “off” to “on” position.
26.5.8 The design and installation of LPG and CNG appliances and systems shall provide for the consumption of air and the venting of exhaust products.
26.5.9 Pilot lights and other automatic ignition devices shall be permitted only in appliances with room sealed combustion systems.
26.5.10 Unattended appliances shall incorporate a room sealed combustion system.
26.5.11 Attended non-room sealed combustion system appliances shall be equipped with an oxygen depletion sensor that cuts off the fuel supply to the appliance when the room oxygen level falls below 95% of normal, and/or failure of oxygen depletion sensor.
26.5.11.1 In addition to the oxygen depletion sensor, the manufacturer of the appliance shall provide a warning label to alert the appliance operator to maintain adequate ventilation during appliance operation.
26.5.12 All appliances shall have flame failure devices on all burners, and pilot lights, that will prevent gas from flowing to the burner if flame is not present.
26.5.13 When operating at the rated capacity, the exterior surfaces of the appliance shall not exceed 180°F (82°C) when tested in an ambient temperature of 77°F (25°C), and
26.5.13.1 the appliance shall be designed so that, when installed, the temperature of the surface below, and immediately surrounding vertical combustible surfaces, shall not rise more than 150°F (65°C) above the compartment’s ambient temperature.
26.5.14 Appliances shall be mounted in accordance with the manufacturer's instructions and in accordance with this standard.
26.6.1 Exhaust products shall be ducted to the exterior of the vessel and designed to minimize water entry, back draft, and exhaust re-entry through any hull openings, ventilators, opening ports, hatches, windows.
26.6.2 Flues shall be routed and sized to ensure complete discharge of the products of combustion outside the craft, and shall not be obstructed by an accumulation of water.
26.6.2.1 The flue system shall be continuous and sealed from the appliance to its terminus outside the craft.
26.6.2.2 Flue terminus shall not be positioned within 20 inches (500mm) of a refueling fitting or fuel tank vent.
27.6.2.3 Dampers, i.e., shut-off valves, shall not be installed in flue systems.
27.6.2.4 The flue system shall be accessible for inspection.
26.6.2.5 Exposed surfaces of flues, smoke pipes, or stacks in accommodation spaces shall not have a surface temperature greater than 180°F (82°C) during operation with a compartment ambient temperature of 77°F (25°C).
26.6.3 Double or triple wall smoke stacks shall meet the requirements of UL 103 Chimneys, Factory-built, and shall be installed in accordance with the instructions of the manufacturer.
Definitions:
Unattended Appliance - appliances intended to function without frequent attention by an operator, and that may cycle on and off automatically, such as refrigerators, thermostatically controlled cabin heaters, and water heaters.
Room Sealed Combustion System - a combustion system in which incoming air, the combustion chamber, and the outgoing products of combustion are sealed from the boat interior.
Having been on the receiving end of an on demand LPG heater removal, on a customers boat, which was mandated after an insurance survey, I really do feel for the folks who buy these products from sleazy misleading companies. Sadly these companies know damn well these water heaters do not meet marine safety standards but they mislead the consumer anyway...
Course it is not just water heaters. I know I have posted this before but here it is again:
FACT: You as a private boater do NOT need to comply with the ABYC standards
Catch 22 / CAUSE FOR CONSIDERATION: Your surveyor surveys to ABYC standards and your insurance company underwrites your boat based on the surveyors report! If you happen to have one that misses deficiencies then that is likely less costly for you....
These are just a bit of the "insurance/survey" items I have had to deal with over the last few years:
*Bond a keel stepped mast to external ballast (after a strike claim this is not even a standard)
*Bond numerous boats for AC Grounding to DC Grounding
*Add over current protection where it did not exist (house banks for example)
*2 Boats for the AC inlet / breaker 10' rule
*1 Boat for an improper AC main breaker (not double pole)
*Multiple boats for GFCI outlets
*Multiple boats for lack of DC over-current protection
*Multiple boats for LPG system issues
*1 Boat for AC/DC isolation (cover for AC) behind AC/DC panel
*Multiple boats for fuel system issues (too many to list)
*1 Boat for a reverse polarity indicator
*Approx three boats for non compliant battery chargers
*2 Boats for ignition protection issues on gas boats.
*1 Boat for lack of a bilge blower
*Improper bonding of chargers and inverter/chargers
*1 Boat for a bilge pump alarm
*Multiple boats for deteriorated below waterline hoses
*Remove a non compliant on-demand water heater (Excel)
*Multiple battery system compliance issues including venting, acid containment, over current protection etc..
*Multiple unsafe termination issues (solder, wire nuts, improper lug stacking etc.)
*Steering system failures (meat hooks etc.)
There are probably more that I am just forgetting... Insurance companies and surveyors today are playing a CYA game. Surveyors are indeed getting better and have more training in ABYC, CFR and other standards than ever before.
In today's day and age it
does pay to use the available safety standards as a solid guideline for boat upgrades (see list above). The survey industry uses the standards so the closer your boat is to those guidelines (ABYC) the better chance you will have a skating through clean on an insurance survey. LPG systems are but one of the hot ticket items but electrical is getting more and more demanding I suppose because 55% of boat fires are electrical in nature...