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Thread: HIN silliness

  1. #1
    Advanced Beginner bgary's Avatar
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    HIN silliness

    Went to renew my state registration number yesterday, and was told I wouldn't.

    Why? Because my HIN does not conform with a new (2012) USCG standard format.

    Yep. The number which has identified my boat since the gelcoat was sprayed into the mold in 1984... is no longer valid.

    My current HIN is ERY32604M85A.... and apparently the new format requires that positions 11-12 be the model year, where the current HIN has model year in positions 10-11.

    So, they will "assign me a new one", and I will have to permanently affix it to two places on the boat.

    (insert epithet about the absurdity of bureaucratic machinations here).

    Anyone else having to go through this?

    _/)_
    Bruce


    https://www.snohomishcountywa.gov/Do...ter/View/43323

    https://www.gpo.gov/fdsys/pkg/CFR-20...l#seqnum181.25
    "Makana" (ex-Thelonious)
    1985 Ericson 32-III #604
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  2. #2
    Senior Moderator Loren Beach's Avatar
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    Question HIN confusion

    I logged onto the Oregon Marine Board site and find no (zero, zip, nada) mention of your HIN change issue.
    I wonder how and why Washington state was impacted.
    After all, a Federal rule change would apply to all boats in all states.

    Have you spoken to anyone about this at your state level?

    Good luck,
    Loren

    ps: interesting trivia in reply 19 in this thread: https://www.planetnautique.com/vb5/f...irements/page2
    Last edited by Loren Beach; 06-30-2017 at 02:32 PM.
    1988 Olson 34 #8
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  3. #3
    Advanced Beginner bgary's Avatar
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    I have not spoken with anyone at the state level. It's.... uh... "interesting" to see this play out through the state-licensed licensing agents.

    It's a Federal standard, enacted in 2012, apparently now on the cusp of being enforced by USCG. If I'm piecing things together correctly, there's nothing actually "wrong" with the old HINs, just that they aren't in the new format.

    But apparently the state of WA, in its infinite wisdom, has decided that there are 19,000 boats in WA that do not conform AND WE MUST DO SOMETHING ABOUT IT!!!!!!

    Apparently exacerbated by the fact the new computer system WA uses flags them as invalid rather than just non-confirming.

    Everyone I've talked to says that that Washington is "doing it wrong". That no longer has the power to surprise me... and doesn't help me get my 2017-18 registration stickers.

    So, yeah, I'll go get my new HIN. and then I'll probably tuck it in my chart table for in case I ever get pulled over. Or something.

    (as an aside... I'm mildly curious what the new HIN will be. If they do it according to the Federal standard, it *should* be ERY32604G485.... three-letter manufacturer code, 5-digit serial number, letter to indicate month of manufacture (July), last digit of the year of manufacture (1984), and the last two of the model year (1985).

    The only place - theoretically - where WA has some flexibility is in how they assign a 5-digit "serial number".... but given that it is WA, I'm sure they'll screw it up. It's entirely possible that WA will create a HIN which puts the model-year in the last two places, but *doesn't* use ERY as the manufacturer code, or doesn't conform to the rest of the standard in some way....)
    "Makana" (ex-Thelonious)
    1985 Ericson 32-III #604
    Makana blog: here

  4. #4
    Senior Moderator Loren Beach's Avatar
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    Red face

    Beyond ownership records, that historic HIN is also a primary ID for all loans and insurance. This will have an odd ripple effect.
    1988 Olson 34 #8
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  5. #5
    Curator of Broken Parts toddster's Avatar
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    When WA disapproved of the lack of VIN on one of my old trailers, they assigned a new number all their own that appears to list the Washington State Patrol as the manufacturer.
    s/v arcturus E29 #134

  6. #6
    Advanced Beginner bgary's Avatar
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    Quote Originally Posted by Loren Beach View Post
    This will have an odd ripple effect.
    Yup. I now have a new HIN (and new title document) showing that, apparently, my Ericson is a homebuilt boat....

    I hadn't thought about the insurance aspect. I guess I need to call my insurer now and notify them to update their records.

    Side note - the WA licensing agent did not like it when I told her that she was effectively falsifying a federal ID number by eradicating the ERY from the record....
    "Makana" (ex-Thelonious)
    1985 Ericson 32-III #604
    Makana blog: here

  7. #7
    Contributing Partner Kenneth K's Avatar
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    Yeah, that's crazy. Maybe Pierce County is behind Snohomish, but they issued my sticker with no problems. Mariah is Federally registered, which brings up another point; the Coast Guard has tracked Mariah's title records for years under the original HIN. Wonder what their reaction to be would be to Washington's silly request?
    Ken
    '85 E32-3 "Mariah" #641
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    "Saltwater is the cure; sweat, tears, or the sea......"

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    I just renewed Cinderella's tags here in Seattle at the start of June. I went online and chose the option to have the tags mailed from a license branch. I was never prompted to change it. My paperwork says my HIN is 168, so my format is far from "correct"

    Have you jumped theough the hoops already?

    -P

  9. #9
    Advanced Beginner bgary's Avatar
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    Quote Originally Posted by p.gazibara View Post
    Have you jumped theough the hoops already?
    Yeah. My choices were get a new HIN, or not get new registration tabs.

    I firmly believe WA is screwing this up. My old HIN was perfectly valid for 30-something years, and seems to still be valid in other states, but WA has (apparently) adopted a computer system that kicks it out as non-conforming.
    "Makana" (ex-Thelonious)
    1985 Ericson 32-III #604
    Makana blog: here

  10. #10
    Senior Moderator Loren Beach's Avatar
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    Angry Actually, this seems too crazy to be Real

    The state agency is forcing a sort of "fraud" onto the boat owners, by denying that the actual boat builder built the boat.
    We are a small niche group, numbers-wise.

    I doubt that the DMV would, for one second, try this on vehicle owners.

    And if they next require everyone over 30 to have new birth certificates, hopefully you will end up younger, with wealthier parents....
    1988 Olson 34 #8
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  11. #11
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    Birth cert

    Well my wife declined to get a passport a couple of years ago when informed her original birth certificate from MT containing all the needed information including her foot prints on it were unacceptable. The reason was it didn't look like all the others and she was born in 1963. Go figure.

    Scott Wysailer

  12. #12
    Principal Partner footrope's Avatar
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    I also think Sno County screwed up

    If you decide to fight this, take it to the State or Federal level. I'd hate to bring this up to another County Auditor because they might decide to go with Snohomish County! A Sno County friend went in to the office in person to renew a 1970s boat and had no trouble. His HIN is not quite in the format for 2012, but it is closer than mine. I had no trouble three weeks ago for my 1980 and got mine from the Pierce County Auditor via the WA DOL online renewal and the US mail.

    Here are the applicable Federal regulations from your link. These are Manufacturers Requirements. I think the folks at the Snohomish County Auditors Office have interpreted the requirements incorrectly and if they checked with "somebody" they would likely be told that the rule in 181.23 only applies to HIN location and the need for a hidden duplicate number. It seems they are out of step with the rest of Washington State. This regulation does not seem to demand that anyone who is not manufacturing boats change his hull id number on already-produced hulls. If there is no hull number at all, then you make one up, is how a reasonable person would interpret this, IMHO. In any case, for documented boats, a new HIN must be coordinated with the USCG. The document on the HIN format is from 1984, which makes many of our boats prior to that format rule. If the number is unique by virtue of the ERY designation, then I see no reason to change it. My boat is documented and has been renewed by the USCG for 13 years.


     181.23
    Hull identification numbers required.
    (a) A manufacturer must identify each boat produced or imported with primary and secondary hull identification numbers permanently affixed in accordance with  181.29 of this subpart.
    (b) A person who manufactures or imports a boat for his or her own use and not for sale must obtain the required hull identification number in accordance with the requirements of the issuing authority listed in 33 CFR part 173, Appendix A for the boat's State of principal operation and permanently affix the HIN to the boat in accordance with  181.29 of this subpart.
    (c) No person may assign the same HIN to more than one boat.
    [USCG-2003-14963, 77 FR 18703, Mar. 28, 2012]

     181.25
    Hull identification number format.
    Each of the hull identification numbers required by  181.23 must consist of twelve characters, uninterrupted by slashes, hyphens, or spaces, as follows:
    (a) The first three characters must be a manufacturer identification code assigned under  181.31(a) or the importer designation assigned under  181.31(b).
    (b) Characters four through eight must be a serial number assigned by the manufacturer in letters of the English alphabet, or Arabic numerals, or both, except the letters I, O, and Q.
    (c) Characters nine and ten must indicate the month and year of certification when a date of certification is required. In all other cases characters nine and ten must indicate the date of manufacture. The date indicated can be no earlier than the date construction or assembly began and no later than the date the boat leaves the place of manufacture or assembly or is imported into the United States for the purposes of sale. Character nine must be indicated using letters of the English alphabet. The first month of the year, January, must be designated by the letter “A”, the second month, February, by the letter “B”, and so on until the last month of the year, December. Character ten must be the last digit of the year of manufacture or certification and must be an Arabic numeral.
    (d) Characters eleven and twelve must indicate the model year using Arabic numerals for the last two numbers of the model year such as “82” for 1982 and “83” for 1983.


     181.29
    Hull identification number display.
    Two identical hull identification numbers are required to be displayed on each boat hull.
    (a) The primary hull identification number must be affixed—
    (1) On boats with transoms, to the starboard outboard side of the transom within two inches of the top of the transom, gunwale, or hull/deck joint, whichever is lowest.

    (2) On boats without transoms or on boats on which it would be impractical to use the transom, to the starboard outboard side of the hull, aft, within one foot of the stern and within two inches of the top of the hull side, gunwale or hull/deck joint, whichever is lowest.
    (3) On catamarans and pontoon boats which have readily replaceable hulls, to the aft crossbeam within one foot of the starboard hull attachment.
    (4) If the hull identification number would not be visible, because of rails, fittings, or other accessories, the number must be affixed as near as possible to the location specified in paragraph (a) of this section.
    (b) The duplicate hull identification number must be affixed in an unexposed location on the interior of the boat or beneath a fitting or item of hardware.
    (c) Each hull identification number must be carved, burned, stamped, embossed, molded, bonded, or otherwise permanently affixed to the boat so that alteration, removal, or replacement would be obvious. If the number is on a separate plate, the plate must be fastened in such a manner that its removal would normally cause some scarring of or damage to the surrounding hull area. A hull identification number must not be attached to parts of the boat that are removable.
    (d) The characters of each hull identification number must be no less than one-fourth of an inch high.
    [CGD 79-013, 48 FR 40718, Sept. 19, 1983; 48 FR 53558, Nov. 28, 1983]
    Craig Davis & Ellen Le Vita

    1980 E38 "Pilot Project"
    Hull #20, Universal Diesel 5432
    Seattle, WA



    Somebody once said "It's an old boat and therefore resistant to change."

  13. #13
    Advanced Beginner bgary's Avatar
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    I don't know how hard I'm going to fight it. Might just land on "passive resistance" (not permanently affixing the new HIN to the boat....)

    The format for mine (perhaps all of ours) "mostly" conforms with the USCG standard

    -- first three are the manufacturer code (we're good)
    -- next five are the serial number (we're good)
    -- last 4 are the manufacture/certification (we're NOT good)

    ...the spec calls for a letter indicating month and a digit representing year of manufacture, and then two-digit model year
    ...mine has an "M", then the two-digit model year, then a letter indicating month.
    which means my last 4 digits should be H585 (August, manufactured 1985, model year 1985), where they are currently M85A

    So... even though it has been in fully-compliant use for decades, it is now *not* compliant, at least with the published spec.

    It appears that most other states have handled this in stride - WA seems to be in the minority of states that are declaring "non-compliant" to be "invalid", and issuing a new HIN.

    Feh.
    Last edited by bgary; 07-05-2017 at 03:39 PM.
    "Makana" (ex-Thelonious)
    1985 Ericson 32-III #604
    Makana blog: here

  14. #14
    Senior Moderator Loren Beach's Avatar
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    Lightbulb The HIN here, and there...

    I emailed my contact @ the Oregon Marine Board (OMB), for commentary and out of some curiosity as to whether this might happen in Oregon.
    She sent a detailed reply.
    Main points are that the Oregon database software was implemented in 2013, and is used by over 28 other states. Washington does not use this software.
    Here is the gist of her message:
    " The new system accepts various HINs including shorter HINs issued by manufacturers prior to 1972 when the USCG implemented a 12-digit format. The 12-digit format has been modified several times over the years and manufacturers are required to follow the current format. In Oregon if a boat is pre-1972 and has a permanent HIN that is shorter than 12 digits, it is accepted. Some sailboat manufacturers did not meet the 1972 deadline for 12-digit HINs until a few years later. The USCG has also approved that the Marine Board may issue shorter HINs that match the title number for pre-1972 boats that are verified as not having a HIN on the boat, an unknown model year or manufacturer. The Marine Board may request a photo or inspection for a HIN that does not match the format or to verify the HIN."

    My uneducated take on this computer-y stuff is that WA dropped the (digital) ball badly on what should have been a seamless transition to a newer db.
    It might be interesting to see if they have to correct their mistake if enough boaters complain.
    Last edited by Loren Beach; 07-05-2017 at 06:05 PM.
    1988 Olson 34 #8
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  15. #15
    Advanced Beginner bgary's Avatar
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    Quote Originally Posted by bgary View Post
    ...the spec calls for a letter indicating month and a digit representing year of manufacture, and then two-digit model year
    ...mine has an "M", then the two-digit model year, then a letter indicating month.
    which means my last 4 digits should be H585 (August, manufactured 1985, model year 1985), where they are currently M85
    I got around to calling the Coast Guard today, and got some information that *almost* makes sense.

    The officer I spoke to said that there have been three different standards for HIN numbers: pre-1972, 1972-1984, and then 1985 to present.

    The format for the last 4 digits of the HIN on my boat arguably should be H485 (August, manufactured 1984, model year 1985).

    The issue is that my boat was built in 1984, but is a 1985 model-year. So.... Ericson used a HIN format that was correct in 1984 when the hull was in the mold, but by calling it a 1985 it now has to conform with the HIN format in place for 1985 and on.

    So.... now I get it. And now I understand why my boat is getting caught up in this, where others (Washington and elsewhere) are not being required to get a new HIN from the state. My boat (and probably a few, but not many others) has a conflict between build-year and model-year which just happens to cross a period when the HIN-number format was being changed.

    The officer said the HIN-format cleanup has been required by law, starting in 2012, but that most states are doing a "really bad job" both of making the change and communicating the reason.

    Anyway.... thought I'd pass along what I've learned. Now all I have to do is figure out which HIN is going to get me through a border crossing more smoothly; the one molded on the back of the boat, or the one the state of Washington created out of thin air.

    Or maybe both. Since they're both listed on my registration paperwork...
    "Makana" (ex-Thelonious)
    1985 Ericson 32-III #604
    Makana blog: here

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