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#301333 - 11/18/22 09:35 PM USCG Survival Equipment change effectiv 12/14/2022
rafowell Offline
Enthusiast

Registered: 11/29/09
Posts: 257
Loc: Southern California
From: The Federal Register 11/14/2022

{ (RAF) Here's a public bulletin from the USCG on this matter: }
USCG Marine Safety Information Bulletin 11/14/2022

{ My summary (RAF): USCG to drop USCG type approval requirements in favor of manufacturer self-certification to iso-18813-2006 for 12 types of survival craft equipment items effective 12/14/2022. Snippets below - full document at link above }

"SUMMARY:

The Coast Guard is updating the type approval requirements for certain types of equipment that survival craft are required to carry on U.S.-flagged vessels. This rule will remove Coast Guard type approval requirements for nine of these types of survival craft equipment and replace them with the requirement that the manufacturer self-certify that the equipment complies with a consensus standard."

{ (RAF) The "consensus standard" is ISO 18813-2006, a 22 page document which cost me $120 to purchase, with every page marked "no hard copy or electronic reproduction of any kind is permitted" - a bit of a barrier to public transparency. }

"The purpose of this rule is to update the type approval requirements for 12 types of survival craft equipment that survival craft are required to carry on certain, specified U.S.-flagged vessels—bilge pumps, compasses, fire extinguishers, first-aid kits, fishing kits, hatchets, jackknives, knives, signaling mirrors, provisions (food rations), emergency drinking water, and sea anchors—as well as some of the survival craft equipment required for sailing school vessels. For nine of these types of equipment, this rule will replace the Coast Guard type approval requirement with a requirement that the manufacturer self-certify that the equipment complies with a consensus standard: bilge pumps, compasses, first-aid kits, fishing kits, hatchets, jackknives, mirrors, sea anchors, and water. Type approval is the primary process for equipment and materials to receive Coast Guard approval. Updating type approval requirements for survival craft equipment will result in cost savings to equipment manufacturers, vessel owners and operators, and the Coast Guard.

The Coast Guard issued a notice of proposed rulemaking (NPRM) on October 5, 2020, and solicited public comment on the proposal during a comment period of 60 days.[1]

The comment period closed on December 4, 2020. The Coast Guard received 13 comment submissions, which are discussed later in this document."

{ (RAF) Alas, I didn't find out about this until the comment period closed, and the USCG (rightly, per their rules) refused to accept my comments.}

"Two commenters expressed concerns that removing type approval requirements could decrease the quality of survival craft equipment. We disagree."

{ (RAF) I share the commenter's concerns - I'd be happier if I knew there was a USCG enforcement process is for the new rules - what is the mechanism for detecting, reporting, and correcting violations of the new rules? }

{ (RAF) Having compared the ISO rules for signaling mirrors to the previous USCG 160.020 rules - they have a lot in common, but I'd be happier if:
  • the ISO requirement for the aiming mechanism accuracy was more quantified and testable than the single word "effective"
  • the ISO requirement for "flatness" was one that could be met by a perfectly flat surface
  • the ISO had kept the USCG salt spray requirement
}






Edited by rafowell (11/19/22 05:57 AM)
Edit Reason: Added MSIB link
_________________________
A signal mirror should backup a radio distress signal, like a 406 MHz PLB (ACR PLB) (Ocean Signal PLB)

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#301334 - 11/18/22 10:35 PM Re: USCG Survival Equipment change effectiv 12/14/2022 [Re: rafowell]
Phaedrus Offline
Carpal Tunnel

Registered: 04/28/10
Posts: 3075
Loc: Big Sky Country
Interesting! I wonder what practical impact this will have?
_________________________
“I'd rather have questions that cannot be answered than answers that can't be questioned.” —Richard Feynman

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#301345 - 12/06/22 12:58 AM Re: USCG Survival Equipment change effectiv 12/14/2022 [Re: rafowell]
Doug_Ritter Offline

Pooh-Bah

Registered: 01/28/01
Posts: 2183
ISO is all about making money and funding bureaucracies.
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#301399 - 01/13/23 01:21 AM Re: USCG Survival Equipment change effectiv 12/14/2022 [Re: rafowell]
WesleyH Offline
Member

Registered: 05/26/16
Posts: 101
Loc: Unknown
I would be more inclined to make a significant issue of the transparency failure. . Coupled with the cost of $120 per copy of the document seems more inclined to attempt raise revenue than to effect the safety of the boating public.

I would be inclined to publish the document in a publically available forum, let them try to come after you, for highlighting critical safety advisories from a government agency.

That is problematic.
_________________________
WesleyH

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