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Old 05-25-2009, 11:01 AM
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Default Commentary on Mandatory PFD Use In Canada By Kiteboarders

In speaking with the Ontario Kiteboarding Association, it was requested that a document be prepared discussing existing and proposed regulations governing PFD use by kiteboarders in Canada. The resulting document is attached with photos in pdf format.

The text of the response appears below:

May 24, 2009
Regulatory Services and Quality Assurance (AMSX)
Transport Canada, Marine Safety
Place de Ville, Tower C
330 Sparks Street
Ottawa, Ontario
K1A 0N8
Attn.: Kevin Monahan
Project Manager

Ontario Kiteboard Association
www.kiteboardontario.com
matt@kiteboardontario.com
Attn.: Matt Aiken


RE: Proposed Changes Related
To Kiteboarding
“Small Vessel Regulations”
Canadian Gazette, Part I, Revisions
dated Ottawa, April 2, 2009, Published
on April 25, 2009

Gentlemen:

The Ontario Kiteboarding Association, requested comment upon proposed Transport Canada (TC) rule changes requiring kiteboarders to wear Transport Canada approved Personal Flotation Devices (PFDs). The writer has evaluated kiteboarding accidents for many years with the intent of reducing repetition while focusing on improving the safety and sustainability of kiteboarding. His C.V. has been attached for reference.

Based upon a review of proposed and past “Small Vessel Regulations,” C.R.C., c. 1487, kiteboarders in Canada haven’t been required to use PFDs or carry other boating safety gear prior to the proposed rule change. This may explain some of the considerable upset and concern in the Canadian kiteboarding community. Kiteboards are usually well under 2 m in length, the heretofore limiting criterion.1 1.35 to 1.5 m are more common lengths in use currently. Apparently, all restrictions based upon minimum size which made the rule not applicable from 2001 through 2008 have been removed from the proposed new rule. 2 The basis for removing this “non-applicability” status is not clear other than perhaps as a reasoned precaution as opposed to one derived from the apparent accident experience in Canada.

To the writer’s knowledge there have been no kiteboarding fatalities in Canada, including no drownings, making the motivation for the creation of this measure unclear. Swimmer and fisherman drownings have been substantial unlike the kiteboarder experience. Limited kiteboarder drownings have occurred in other countries in some instances however the most common mechanism by far of fatal kiteboarding accidents involves impact trauma often related to weather conditions.

In the interest of safety, it is important that new requirements when implemented for the public in fact heighten safety as opposed to potentially compromise it, cause general confusion or other motivations for non-compliance. Several issues and potential problems are perceived related to limited availability of TC approved PFDs suitable for kiteboarding.
Kiteboarding creates a demanding and exacting performance environment for equipment used by the kiteboarder or kiter. The kiter usually is planing above the water on his board but may become partially immersed at frequent intervals during a kiteboarding session. These immersions are typically both intentional and accidental. Kiteboarders also jump for periods of seconds frequently and impact the water at high speed accidentally on a regular basis.

The nature of the kiteboarding suggestions the following considerations:

1. Kiteboarders require unencumbered mobility to swim if needed, perform aerial “gymnastic-like” tricks and maneuvers on their kiteboards. They also engage in “body dragging” or utilizing their kite to pull them in shallow tacks upwind to regain their kiteboard after falling off. These activities require considerable body flexion with an absence of bulky, heavy, drag prone or confining garments and accessory gear. Of a necessity flotation aids, if used must be low drag (form fitting) and not interfere with other gear or normal kiteboarder function. These among other reasons are why bulky, encumbering lifejackets (SOLAS, foam filled or Small Vessel) are are unsuited to kiteboarding and may even present potential hazards to the kiter related to water impacts. The reasons why are explored below.


Photo 1: A popular “handle pass” trick requiring unimpaired movement.

2. There are limited kiteboarding parallels to water skiing and wakeboarding including fairly common water impacts sometimes at high speed and with substantial force. Kiteboarding differs in that jumps may regularly achieve 5 m to as much as 20 m above the water. The kiter as he descends to the water may be moving quite fast in some cases approaching the wind speed. Kiters hit the water fairly often at speed both gracefully burning off the speed on his board or by impacting the water with considerable force. It is important when hitting the water that nothing he is wearing has excessive drag, weight or impact loading on his body. The resulting forces from impact drag on articles and reaction impacts on the kiter’s body could lead to injury, diminishment of ability or other issues.

Photo 2: A nice jump,you want to have as little drag as possible if you land in the water badly particularly at high speed. Kiters jump substantially higher at times.

3. The bottom edge of the PFD must terminate high enough on the kiter’s torso so as to allow the comfortable use waist or seat harnesses required for kiteboarding. In some instances male kiters have worn shorter female PFDs in other countries just to be able wear their harnesses. In some cases the harness may be worn over certain PFDs subject to the limitations described herein.

Photo 3: This photo shows the limited torso area available for a PFD above a waist harness. The harnesses my slip even higher under load at times.

4. The PFD can’t bind on the harness impeding movement nor can it impair access to quick releases (usually two) that are opened in the instance of anticipated high wind emergencies. The opening of this quick releases must be rapid and extremely reliable and in no way obstructed or compromised by a PFD. Failure to open the quick release in a high wind emergency may result in serious impact trauma to the kiteboarder.

5. The PFD and components should not pose a tangle hazard for his kite flight lines and leaders through the presence of excessive buckles or other snagging points. Such tangles can be hazardous leading to loss of powered kite control and risk of impact trauma.

6. The PFD must remain secured and in place not shifting on the kiter’s torso despite substantial water impact forces. There is a tendency for ill fitting or designed PFDs to ride up excessively on the kiter diminishing function. Historically this led to neck fractures with some lifejackets in use in the early part of the last century when passengers jumped from the decks of sinking vessels. Kiters have reported problems with some inflatable PFDs twisting and tangling on routine water impact. Untoward twisting or tangling could impair proper PFD function and/or possibly cause injury to the kiter when inflated. Until inflatable PFDs are commonly known to remain in place despite routine impacts their use in kiteboarding is questionable.

7. Consider a diver vaulting off a 3 m, or worse a 10 m platform with a prospective PDF on, feet first, rotating sideward, even head first. The drag and related consequences upon impact with the water, freedom for movement during free fall become more apparently. It is unusual for kiters to make head first entries from high jumps but the mode of water entry is varied, frequently fast and uncomfortable/painful even without untoward drag of accessories. There is an important need for streamlined, low drag, unencumbering and well secured PFDs in kiteboarding.

8. Regarding other items required for use on “Small Vessels” apparently heretofore exclusive of kiteboarders. Things such as: one buoyant heaving line of not less than 15 m in length, one manual propelling device, or an anchor with not less than 15 m of rope, a watertight flashlight; or three pyrotechnic distress signals,a sound-signalling device. All though well intended and suitable for a conventional “boat,” several of these items would serve no essential justifying purpose typically for a kiteboarder. Specifically, the heaving line, anchor, propelling device (aside from hands of course). The reason being as most contemporary kiteboards such as “Twintips” possess very minimal buoyancy and will not support a kiters weight sitting still, keeping him out of the water. The board acts as a planning surface under kite power in the wind and offers negligible flotation through displacement. Often if the kiter wishes to swim, he must tow the board as it offers inadequate flotation to support his weight upon it. It offers a poor towing surface as well via the heaving line. Anchoring the lot may be of questionable value particularly considering there may be no feasible way to carry an anchor of sufficient weight safely or comfortably to serve. Carrying a whistle is a good idea and frequently recommended. Signaling flares have been carried at infrequent time such as on particularly long kiteboarding trips such as in a race between Ft. Lauderdale, Fl, USA and Bimini,
Bahamas in December 2005. Kiters are frequently encouraged to not kite further from shore and in conditions in which they can’t reliably swim in from.

Use of PFDs by kiteboarders in Canada at the present time is not common. Kiteboarders frequently have developed swimming skills, often wear exposure clothing such as wetsuits and drysuits along with kiteboarding harnesses which impart limited bouyancy. Properly selected exposure clothing can substantially extend the time a kiter can be in the water without hypothermia related diminished function. Some types of kites posses air filled battens or stiffening elements that provide considerable flotation. These kite can even be used as a raft of sorts at times or alternately can be employed as a sail on the water to drag the kiter into shore. Kiteboarding is a relatively new sport which may account for the lack of use of these aids. Another reason is the limited availability of comfortable, functional PFDs that comply with fit and performance demands of kiteboarding. PFDs have been developed for other activities and often may clash with performance demands of the sport.

Based upon questioning of Canadian kiteboarders and extensive searching of TC approved PFDs, the quantity of suitable TC approved PFDs for the demands of kiteboarding may be quite small indeed. The same might be said of USCG approved PFDs that are suitable for kiting. What few that seem to work reasonably well are frequently not approved by TC, USCG or CE. Given the considerable costs associated with obtaining such approvals through testing and the current depressed economy, it seems that expansion of the number of approved PFDs seems unlikely in the near term.

Use of appropriate PFDs for the demands of kiteboarding is recommended by the writer, who has used several vests for almost 11 years.
Some of those devices had poor performance while others worked better. The writer also uses seat harnesses which allow more torso room for an abbreviated length PFD. If he used waist harnesses as perhaps the majority of kiteboarders, his experience may have been more challenging. He believes that PDF use should be per informed rider choice and not subject to government mandate at this time, particularly given some of the problems.

Concerns exist with the creation of a rule mandating the use of articles, appropriate versions of which seem to be few, leaving more commonly available but inappropriate PFDs. These more commonly available but ill suited PFDs may actually pose a hazard to kiters on water impact. There is poor consensus among kiteboarders at present about what PFDs function the best with least constriction, loss of mobility and related considerations. It seems that manufacturers may need to play catchup to develop more purpose developed PFDs specifically for kiteboarding. Given the weak economy, it is uncertain how soon these developments may occur. It is worth noting that the performance environment for windsurfing or sailboarding PDFs differs from that appropriate for kiteboarding. Windsurfers are less sensitive to drag and bulk although neither is viewed as a desired quality. PDFs that work well for windsurfers may be inappropriate for kiteboarders.

In the interim, Transport Canada, (in descending order of projected effectiveness and desirability) might elect to:

1. Leave references to kiteboarding the same as existed in C.R.C., c. 1487 3.(2) (updated to June 9, 2008) pending more input from the kiteboarding community and manufacturers. Ideally, a consensus view about what the best and most appropriate PFDs for a given activity with unusual performance demands should exist prior to requiring their mandatory use by regulation. Promote kiteboarder education to employ suitable PFDs through manufacturers, retailers, schools and kiteboarding magazines in the interim.

2. Give consideration for the use of a full wetsuit and harness and require mandatory PDF use only beyond a certain distance from shore. The kite if it is a tube or Leading Edge Inflatable (LEI) design can also offer considerable bouyancy and even an opportunity to partially leave the water.

3. Most PFDs which may have desirable features for kiteboarding, have no governing body (Transport Canada, USCG and CE) approvals whatsoever. TC may consider waiving governing body PDF approval if that is feasible. Some kiteboarding/windsurfing specific PFDs have CE approval such as that shown below. TC may consider waiving PFD approval if feasible or substituting CE approval. Again, developing a consensus view among the kiteboarding community as to what constitutes an appropriate, serviceable PFD should ideally be developed first before mandating their use.


Photo 4: Cabrinha High Hook Vest
Should you have questions please contact the undersigned at your convenience.
Sincerely,

Rick Iossi
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Old 05-26-2009, 06:46 AM
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I see my Canandian friends are already on this.
http://www.boostkiteboarding.com/php...php?f=3&t=1153
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Old 05-26-2009, 07:41 AM
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ricki ricki is offline
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Thanks for putting this up Chris. There is a petition there that it would be good if folks could sign.

Regarding some of the points on the petition:

1. make body dragging to your board difficult
2. can interfere with the use of quick release safety
3. can result in more line entanglement
reduce mobility, so can limit a kiteboarders ability to depower kite and board

This is true of some pfds, likely many if not most Transport Canada approved PFDs. It isn't true of all pfds however, fortunately for us. Lots of kiters wear pfds routinely and don't suffer any of the above problems. Still, I believe TC needs to be better informed as to what our sport entails, what works and what doesn't before requiring equipment of kiters, if ever. In the interim, informed free choice should govern. I recommend wearing a pfd for kiting sessions, I don't feel it should become a Federal requirement though.
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