1. USCG Lifesaving & Fire
Safety Division
Update
Brandi Baldwin
U. S. Coast Guard
Design and Engineering Standards
Lifesaving & Fire Safety
2. 2008
Harmonization
effort began
2015
ANSI/CAN/UL
12402-5 and -9
published
2018
First approvals
issued using UL
12402
2017
MOU between the
U.S. and Canada
signed
FUTURE
Policy to partially
adopt UL 12402-5
FUTURE
Rulemaking to fully
adopt UL 12402-5
and UL 12402-4
Major Milestones
3. 2005
ASE Ergonomic
label study
2012
1st Preliminary
Review
2013
2nd Preliminary
Review
Major Milestones – Labels
2011
Label Focus
Groups
Merged back
into 12402
work ….
2010
Revitalized
by IHC
Paused to
focus on
harmonization
4. Major Milestones – Follow up
2010
USCG initiates
work on FUS
Standard
2014
1st Prelim of
UL 9595
2019
3rd Prelim of
UL 9595
2015
2nd Prelim of
UL 9595
• USCG/UL/PFDMA project to update UL’s
standardized appendix pages
• New USCG-recognized independent laboratories
Paused to
focus on
harmonization
5. FUTURE
Rulemaking to fully
adopt UL 12402-5
UL 12402-4
And UL 9595
2008
Harmonization
effort began
2015
ANSI/CAN/UL
12402-5 and -9
published
2017
TC/USCG
MOU signed
AUG 2018
USCG Policy to
partially adopt UL
12402-5
Major Milestones – All together now
2005
ASE Ergonomic
label study
2012
1st Prelim
Review
2013
2nd Prelim
Review
2011
Label Focus
Groups
2010
USCG initiates
FUS Standard
2014
1st Prelim of
UL 9595
2019
3rd Prelim of
UL 9595
2015
2nd Prelim of
UL 9595
6. FUTURE
Rulemaking to fully
adopt UL 12402-5
UL 12402-4
And UL 9595
2008
Harmonization
effort began
2015
ANSI/CAN/UL
12402-5 and -9
published
2017
TC/USCG
MOU signed
AUG 2018
USCG Policy to
partially adopt UL
12402-5
Major Milestones – You are Here
2005
ASE Ergonomic
label study
2012
1st Prelim
Review
2013
2nd Prelim
Review
2011
Label Focus
Groups
2010
USCG initiates
FUS Standard
2014
1st Prelim of
UL 9595
2019
3rd Prelim of
UL 9595
2015
2nd Prelim of
UL 9595
2012
Inflatables
Rule
2014
Type Codes
Rule
7. U.S. Statutory & Regulatory
Structure – US Code
• Title 46 US Code
• Inspected vessels. § 3306: “…The Secretary shall
prescribe necessary regulations to ensure the proper
execution of…. (b) lifesaving equipment and its use…”
• Uninspected vessels. § 4102(a): “Each uninspected
vessel propelled by machinery shall carry at least one
readily accessible life preserver or other lifesaving
device, of the type prescribed by regulation, for each
person on board.”
• Recreational vessels. § 4302(a): “The Secretary may
prescribe regulations … (2) requiring the installation
carrying, or use of associated equipment (…lifesaving
devices…) on recreational vessels….”
8. U.S. Statutory & Regulatory
Structure - Carriage requirements
• Recreational Vessels: 33 CFR 175.15
• At lease one approved wearable PFD per person.
• Used in accordance with approval label, and owners
manual (if the approval label references the manual)
• Over 16ft, one approved throwable PFD.
• Children under 13 years: Approved PFD must be worn
unless below deck or in an enclosed cabin.
9. U.S. Statutory & Regulatory
Structure - Carriage requirements
• Uninspected Commercial Vessels (UCV): 46 CFR
Subchapter C
• Wearable
• Less than 12m (40 ft) in length: At least one wearable PFD, OR
immersion suit (160.171) of suitable size for each person.
• Over 12m (40 ft) in length: At least one PFD or immersion suit
approved under 160.055, 160.155, 160.171, or 160.176, of
suitable size for each person.
• Passengers for hire (UPVs), regardless of length. At least one
PFD approved under 160.055, 160.155, or 160.176, of suitable
size for each person. *Immersion suits not permitted as subs.
• Throwable
• Greater than 26 ft: one approved lifebuoy (160.050 or 160.150)
• Over 100 GT: three approved lifebuoys
10. U.S. Statutory & Regulatory
Structure - Carriage requirements
• Inspected vessels; non-SOLAS (domestic only)
• Small passenger vessels (Subchapters T & K)
• Approval series 160.002, 160.005, or 160.055
• Offshore supply vessels (Subchapter L)
• Approval series 160.002, 160.005, 160.055, 160.077, 160.155,
160.176, or 160.177
• Towing vessels (Subchapter M)
• Approval series 160.002, 160.005, 160.055, 160.155, 160.155,
or 160.176
• Attachments & fittings: Approved retro-reflective tape,
approved lifejacket light, whistle on a cord, marked with
vessel name.
11. U.S. Statutory & Regulatory
Structure - Carriage requirements
• Inspected vessels; SOLAS (international voyages)
• All ships: One lifejacket for every person onboard, plus
sufficient for remote locations.
• Passenger ships: Must include infant and child size
lifejackets, plus an additional 5%.
• SOLAS Chapter III, Regulation 4:
• “…Life-saving appliances and arrangements required by this
chapter shall be approved by the Administration.”
• Administration: The government, or authorized representative,
of the flag the vessels is flying.
12. U.S. Statutory & Regulatory Structure
- Approval requirements
• 46 CFR Subchapter Q (Parts 159-165)
• Standards for approval
• Role & responsibilities of independent laboratories
• Approval process
• Pre-approval design review
• Prototype testing & evaluation
• Production quality control (Follow-up)
• Suspension/Withdrawal
• Approval series: Categorize equipment
• Lifesaving & fire protection
• Marine pollution, navigation, electrical, mechanical
13. FUTURE
Rulemaking to fully
adopt UL 12402-5
UL 12402-4
And UL 9595
2008
Harmonization
effort began
2015
ANSI/CAN/UL
12402-5 and -9
published
2017
TC/USCG
MOU signed
AUG 2018
USCG Policy to
partially adopt UL
12402-5
Major Milestones
2005
ASE Ergonomic
label study
2012
1st Prelim
Review
2013
2nd Prelim
Review
2011
Label Focus
Groups
2010
USCG initiates
work on FUS
Standard
2014
1st Prelim of
UL 9595
2019
3rd Prelim of
UL 9595
2015
2nd Prelim of
UL 9595
2012
Inflatables
Rule
2014
Type Codes
Rule
14. Rulemaking Process
NPRM
• Proposed rule is published in the FR
• Includes economic analysis
Public
Comment
• Usually 30 or 60 days
• Coast Guard considers all comments before publishing a final
rule
Final Rule
• Regulation is printed in the FR
• Regulation is included in the CFR
• Subject matter expert, economist, attorney, technical writer
• Robust review processDrafting
15. What is next for us ….
• Regulatory development
• Continued support of UL STP 1123
• UL 9595 (follow-up procedures)
• UL 12402-4 (lifejackets)
• Continued partnership with TC
• Reducing burden
OK so lets put them all together… and it’s a lot
Its almost 15 years of non-stop work. And its important to look at this because its easy for those of us who have been grinding away to feel like it will never end…. Admittedly it might not.
But we have come a long way. And we did it together, with a commitment to cooperation and collaboration, and a sense of common purpose.
Last year’s slide…..
Our authority to approve lifejackets starts with the U.S. Code. The Code is statutory; it is legislation, or law, written and promulgated by Congress, and gives the Coast Guard, as delegated via the DHS Secretary, authority to regulate U. S. vessels.
Approval series is a 6 digit number that we use to categorize equipment approvals. Many correspond to subparts contained in subchapter Q.
There are a total of 216 different approval series. 146 of them fall within the lifesaving and fire protection division.
Others cover marine pollution, navigation, and other shipboard electrical or mechanical equipment.
So, if we go back to the timeline…
We are now in the future.
Our current efforts are to fully adopt UL 12402 Parts 5 and 4, as well as 9595, the follow up standard, into the approval regulations. This will also have ripple effects throughout the carriage requirements to ensure that the approved PFDs are appropriate to meet carriage requirements on the applicable vessels.
Rulemaking is needed for Level 50 and youth inflatables.