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Industry Stakeholder Meeting Report on Implementation of UL 12402 - 2018 LJA Annual Conference

  1. Government Affairs Committee: Report on Industry Stakeholder Meeting on Implementation of UL 12402 held by Webex on January 24, 2018 Jason Leggatt Slide 1
  2. Government Affairs Committee • Committee Chair: – Jason Leggatt • Members: – Susan Balistreri – Others TBD • Purpose: – Establish and strengthen collaborative relationships and processes with Government stakeholders – Advocate for strategic work plan priorities Slide 2
  3. Background on Harmonization 1. What is it? 2. What does it mean? 3. Understanding the label? 4. Can we get it done? 5. What’s next? Slide 3
  4. Government Intent 1. U.S.-Canada Regulatory Cooperation Council (RCC) - President Obama / PM Harper - Bilateral working groups - 2. Reciprocity/Mutual Recognition - Common standards - Conformity assessments (laboratory testing) - Production follow-up & oversight Slide 4
  5. The Standards Both published on December 31, 2015 Slide 5
  6. USCG Types Classification System 1. USCG Final Rule: 79 FR 56491, dtd Sep 22, 2014 – Personal Flotation Devices Labeling & Standards - Eliminated Type Codes from the regulations for carriage and labeling of PFD’s - Although Types still exist in legacy UL Standards - Intent to pave the way for introduction of the new label - Boaters must carry: - A USCG Approved PFD / TC Approved PFD for every passenger on board - Must use the PFD in accordance with any restrictions on its label Slide 6
  7. The New Labels Slide 7
  8. Agenda for January 24, 2018 Mtg Time Topic Lead 2:00 – 2:15 pm Introduction remarks / administrative Jason 2:15 – 2:45 pm Overview of the Regulatory Policy & Process - US Federal Regulations – US Coast Guard - Government of Canada Regulations – Transport Canada Marine Safety & Security Brandi Larry 2:45 – 3:00 pm Review UL STP 1123 bi-national standards work plan Maria 3:00 – 3:30 pm Recall review of USCG & TC letter re: adoption of UL 12402-5 Jason 3:30 – 3:45 pm Break Jason 3:45 – 4:00 pm Discussion on equivalency Jason 4:00 – 4:15 pm Existing standards (UL 1123, UL 1180 & CAN/CGSB-65.11) Jason 4:15 – 4:45 pm Communications regarding classification and labels Jason 4:45 – 5:00 pm Next steps / open forum Jason 5:00 pm Conclusion of event Jason Slide 8
  9. Regulatory Process • US Federal Regulations – US Coast Guard – Ms. Brandi Baldwin, Chief of the US Coast Guard Lifesaving & Fire Safety Division *Presentation content from proceedings of the 2013 PFDMAAnnual Conference • Government of Canada Regulations – Transport Canada Marine Safety & Security – Mr. Larry Spears, Transport Canada Marine Safety & Security, Marine Policy and Standards Officer Slide 9
  10. UL Standards Ms. Maria Iafano, UL Standards • STP 1123 Bi-National Standards Work Plan – Labeling (UL 12402-5 Level 50/70 Buoyancy Aids, UL 1123 Inherently Buoyant PFDs, UL 1180 Inflatable PFD’s) – UL 12402-4 Level 100 Lifejackets & -9 Test Methods – UL 1191 Component Standard – Immersion Suits new standards UL 15027-1, -2 & -3 – UL 9595 Follow-Up / Production Oversight Standard – UL 12402-3 Level 150 & -2 Level 275 Lifejackets – More (because it’s so much fun) Slide 10
  11. PRIORITIES (confirmed with STP May 2017) 1. Process any proposals submitted to address a safety concern 2. Undertake any revisions to support transition to ISO 12402 5 & 9 i. Any label proposals needed (Revisions to Part 5, 1180, 1123) Completed ii. Any absolutely necessary revisions needed to Part 5 & 9 Completed 3. Continue developing new Lifejacket & Immersion Suits Standards: i. ISO 15027-1, -2, -3 Underway ii. ISO 12402 – 2, -3, -4, -6 Underway iii. UL 1191 as a binational standard Underway 4. Continue work on other standards to be revised i. UL 1175 (Throwable PFDs) ii. UL 1517 (special purpose devices) iii. Consolidated label standard 5. Continue to develop UL 9595 Follow Up 6. Continue adoption of ISO 12402 suite 11
  12. Adoption of UL 12402-5 Standard Recall review of USCG & TC letters re: plan to transition to UL 12402-5 – Subject: Plan to transition to ANSI/CAN/UL 12402-5, dtd: April 13, 2016 – Draft Milestones for Adoption of UL 12402-5 Phase 1, 2 & 3 Slide 12
  13. Phase 1: Status Quo Slide 13 In the immediate future, nothing will change. For approval in Canada, new designs will continue to be submitted to Transport Canada (TC) recognized product certification bodies for certification to CGSB 65.11, CGSB 65.15 or UL 1180. For approval in the United States, new designs will continue to be submitted to Coast Guard (USCG) recognized laboratories for certification to UL 1123 or UL 1180. In order to move from the status quo phase to the interim phase, the STP, laboratories, TC, and USCG must complete tasks including, but not limited to: • update UL 1123 and UL 1180 to include UL 12402‐style labels (STP); • identify, and rectify, gaps between the old and new standards(USCG/TC/All); • develop and accept a file review plan to update devices certified to UL 1123 and 1180 with the new label format (Labs); • begin the file review process (Labs); • provide an operational “Safe Choice” website (USCG); • receive agreement from labs to test to UL 12402‐5 (USCG/TC); and • finalize internal processes (TC and USCG) for approving to UL 12402‐5, including mutual recognition for test laboratories (USCG/TC). Once these items have been addressed, TC and USCG will issue policy to approve PFDs that are certified to UL 12042‐5. This will NOT include Level 50 devices, youth inflatables, or Level 70 inflatables. TC and USCG will work together to align the implementation timelines in both countries.
  14. Phase 2: Interim Slide 14 After the items listed above have been addressed and the policy letters from TC and USCG have been issued: • The file review process will continue to update the labels on products that have previously been certified to UL 1123 or UL 1180. These products will start to appear on the market with the new label format. • New designs will be tested and approved to ANSI/CAN/UL 12402‐5, with the exception of Level 50 devices, youth inflatables, and Level 70 inflatables. At this point, TC and USCG will begin the process for adopting all options in UL 12402‐5 through regulation. The formal regulatory processes will be followed in both countries, including time for public comment and comment resolution. If adopted by regulation, Level 50 devices, Level 70 inflatables, and youth inflatables would be eligible for approval. TC and USCG will work together to align the timelines so the standards are fully adopted in both countries at the same time. The future phase begins when the regulations are published.
  15. Phase 3: Future Slide 15 Once ANSI/CAN/UL 12402‐5, Standard for Personal Flotation Devices – Part 5: Buoyancy Aids (Level 50) – Safety Requirements are adopted into regulation by both TC and USCG: • All new recreational devices covered under UL 12402‐5 will be approved under UL 12042‐5, and will meet applicable carriage requirements in both Canada and the US, and • Previously approved products will maintain approval in the country for which they were originally approved.
  16. Discussion on Equivalency • Policies enabling equivalency while Regulatory changes are in-process • Continued opportunity for equivalency of novel designs not covered by existing standards Slide 16
  17. Slide 17 Transport Canada Policy 1. Transport Canada Publication TP 13585 E – Acceptance of Level 70 Buoyancy Aids Certified to UL 12402-5 as Personal Flotation Devices 2. Published Jan 19, 2018 3. Accepts new standard allowing manufacturers to produce more innovative equipment that meets approval requirement for both Canada and the United States 4. Applicable as substitute for PFD’s required for Small Vessel Regulations (Pleasure Boating & Commercial) and the Fishing Vessel Safety Regulations 5. Lowers minimum buoyancy of a PFD relaying on inflation for performance from 22-lbs (100 N) to 16.5-lbs (70 N)
  18. Slide 18 • Question: When is the USCG going to issue a policy letter like that which has now been issued by TC? • Answer (USCG): The USCG intends to issue policy accepting PFD’s certified to UL 12402-5 Level 70 as equivalent to PFD’s already accepted under current regulations, including PFD’s that rely on inflation to meet minimum performance. That policy has been delayed and no definitive timeline can be provided for its completion. In the meantime, the USCG has reached out to its recognized labs to discuss the process of testing and certification of Level 70 inherently buoyant devices to UL 12402-5, on a case-by-case basis, with the intent of allowing bi-national approval under the USCG/TC MOU. USCG Policy
  19. New Labels • Question: Can manufacturers begin to switch to the new labels now? • Answer (unknown): Yes, manufacturers can begin to conduct file reviews and switch to the new labels. – If simply updating a design file based on UL 1123 or UL 1180 with USCG approval, this requires a file review with the applicable certification body – If moving an existing device from one approval under UL 1123, UL 1180, CGSB 65.11, or CGSB 65.15 to bi-national approval under UL 12402-5, a certification update project is required to assess and confirm that the candidate device meets the requirements of UL 12402-5 and the regulations in both countries including labeling requirements – If a product is certified to CGSB only in Canada, there is no mechanism currently to transition those products to the new label design unless the product is re-certified under UL 12402-5 for bi-national approval – There is no plan in Canada to change CGSB only product labels unless manufacturers choose to move to UL 12402-5. Both the UL label format and the present CGSB format might continue to exist in Canada until products are no longer being certified to the current CGSB standards. Slide 19
  20. Communication of Labels • Addressing issues of State Regulations & enforcement – Occupational Safety & Health Organizations (e.g. WorkSafeBC) that specific requirements in regulations that do not align with new standard – State Legislation / Boating Law Administrators / NASBLA – USCG Office of Boating Safety working w/ States to ensure their regulations align with new standard – Other Slide 20
  21. Next Steps / Timeline Slide 21 • 2018 – USCG policy to align with Transport Canada acceptance of UL 12402-5 Level 70 Buoyancy Aids, including Inflatable PFD’s - Level 70 Inherently Buoyant & Inflatable PFD’s accepted by equivalency - No INFANT kids product • 2018/2019 – CAN/ANSI/UL 12402-4 Personal Flotation Devices – Part 4: Lifejackets (Level 100), Safety Requirements - Standard lifejackets (aka infant Type II, Type II, Class 2 Canadian Lifejacket) • 2020/21 – Transport Canada & USCG regulatory change to enable - Level 50 PFD’s - Youth Inflatables
  22. Questions Moderator info: Jason Leggatt Chair, Government Affairs Committee Lifejacket Association Wayne Walters Chair Lifeacket Association Slide 22