Recommended
More Related Content
What's hot
What's hot(20)
Similar to USCG Lifesaving & Fire Safety Division Update
Similar to USCG Lifesaving & Fire Safety Division Update(20)
More from NASBLA
More from NASBLA(20)
Recently uploaded
Recently uploaded(20)
USCG Lifesaving & Fire Safety Division Update
- 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
Editor's Notes
- Last year’s slide…..
- 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.