Prevention starts here
U.S. Coast Guard Update:
Office of Design &
Engineering Standards
Brandi Baldwin & Jacqi Yurkovich
Lifesaving & Fire Safety Division
U.S. Coast Guard Headquarters
Office of Design & Engineering Standards
CAPT Dan Cost
Naval
Architecture
Mr. Jaideep Sirkar
Naval Architect
Mr. Bill Peters
Mr. Tom Jordan
Mr. Charles Rawson
Mr. David Karnes
LCDR Dimitrios Wiener
LT Carol Yin
Ship Structure
Committee
LCDR(s) Matt Faha
Vacant
Systems
Engineering
CDR Frank Strom
Electrical
Mr. Ray Martin
Mr. Lee Franklin
LCDR(s) Kevin Ralson
Mechanical
Mr. Thane Gilman
Mr. Wayne Lundy
Mr. Timothy Meyers
LT Catherine Paris
LT Carmine Faul
Lifesaving &
Fire Safety
Ms. Brandi Baldwin
Lifesaving
Mr. Martin Jackson
Mr. George Grills
Ms. Jacqueline Yurkovich
Ms. Stephanie Groleau
LCDR(s) Carlos Diaz-Colon
LT Chris Reimer
Fire Safety
Mr. John Miller
Mr. Sean Ramsey
Mr. Pock Utiskul
LCDR Sarah Rodino
LT Jon Taylor
Hazardous
Materials
LCDR Dan Velez
Bulk Liquids
LT Ethan Beard
Dr. Raghunath Halder
Vacant
Bulk Solids & Packaged
Hazmat
Dr. Amy Parker
Ms. Hillary Sadoff
LT Joseph Kolb
Bulk Liquefied Gases &
Vapor Control Systems
Dr. Cynthia Woodlock
Prevention Starts Here
03/22/2022
Rotation 2026
Rotation 2025
Rotation 2024
Rotation 2023
Rotation 2022
Prevention starts here
Who we are
The Office of Design and Engineering
Standards is responsible for …
developing, maintaining, and implementing
domestic and international
standards, regulations, and policy
related to the construction and outfitting of
commercial vessels and recreational boats
Prevention starts here
Who we are
The Office of Design and Engineering
Standards is responsible for …
developing, maintaining, and implementing
domestic and international
standards, regulations, and policy
related to the construction and outfitting of
commercial vessels and recreational boats
Regulations – Who and How
The Team
The Process
Proposal
Stage
Public
Notice &
Comment
Final Rule
Program Experts Set policy
Lawyers Legal authority & sufficiency
Economists Cost/benefit analysis, Small entities
Environmentalists EA, EIS
Tech Writers Consistency, formatting
Project Manager Deadlines, clearance
Regulations – External Communications
Ex parte guidelines
Public notice and comment period
Maritime Commons blog
https://mariners.coastguard.blog/
Semi-annual regulatory agenda www.reginfo.gov
Prevention starts here
Who we are
The Office of Design and Engineering
Standards is responsible for …
developing, maintaining, and implementing
domestic and international
standards, regulations, and policy
related to the construction and outfitting of
commercial vessels and recreational boats
Prevention starts here
Policy Development
Policy Type
USCG
Authority
External
Audience
Timeline
Navigation and Vessel Inspection
Circulars (NVIC)
https://www.dco.uscg.mil/Our-
Organization/NVIC/
Assistant
Comdt /
Director
Broad Enduring
Policy Letters
https://www.dco.uscg.mil/ENG/Policy/
Director /
Office
Well-
Defined
Medium
Interim
Distribution Letters
Office /
Division
Strictly
Defined
Short
Transient
Prevention starts here
Policy Development
Policy Type
USCG
Authority
External
Audience
Timeline
Navigation and Vessel Inspection
Circulars (NVIC)
https://www.dco.uscg.mil/Our-
Organization/NVIC/
Assistant Comdt /
Director Broad
Long-term
Enduring
Policy Letters
https://www.dco.uscg.mil/
ENG/Policy/
Director /
Office
Well-
Defined
Mid-term
Interim
Distribution Letters Office / Division
Strictly
Defined
Short-term
Transient
Prevention starts here
Policy Development
Policy Type USCG Authority
External
Audience
Timeline
Navigation and Vessel Inspection
Circulars (NVIC)
https://www.dco.uscg.mil/Our-
Organization/NVIC/
Assistant Comdt /
Director
Broad Enduring
Policy Letters
https://www.dco.uscg.mil/
ENG/Policy/
Director / Office
Well-
Defined
Medium
Interim
Distribution Letters Office / Division
Strictly
Defined
Short
Transient
Prevention starts here
Who we are
The Office of Design and Engineering
Standards is responsible for …
developing, maintaining, and implementing
domestic and international
standards, regulations, and policy
related to the construction and outfitting of
commercial vessels and recreational boats
Prevention starts here
Novel Equipment Approval
An item of equipment or material that does not meet all of the
requirements of this subchapter for design or performance may be
approved by the Commandant if it has equivalent performance
characteristics.
The item has equivalent performance characteristics if the
application and any approval tests prescribed by the Commandant,
in place of or in addition to the approval tests required by this
subchapter, demonstrate to the satisfaction of the Commandant
that the item is at least as effective as one that meets the
requirements of this subchapter.
46 CFR 159.005-7(c)
Three novel ideas
*These are just examples. None of these
specific devices have been submitted to the
USCG, and they have not been evaluated
by the USCG.
Equipment that is required by
regulation to meet carriage
requirements on vessels.
Provide an equivalent level of
safety to equipment that meets the
approval requirements.
Pool/beach toys, rescue devices.
What can be approved?
Three novel ideas
*These are just examples. None of these
specific devices have been submitted to the
USCG, and they have not been evaluated
by the USCG.
X
?
Steps for approval of a novel PFD
1 • Initial design review
2 • Detailed gap analysis
3 • Acceptance of a test plan
4 • Approval testing
5 • Final review and approval
6 • Consensus standards proposal
7 • Reassessment
Key Takeaways
Innovation, transparency, & collaboration
Just because we aren’t talking about a project
doesn’t mean we aren’t working on it
Every project has a team; everyone on the
team has a boss
When in doubt, ask; We are here to help
Who we are & what we do
Novel/innovative approvals
Counterfeiting
Our office frequently receives questions about what to do if your device doesn’t meet the requirements in the regulations or standards.
I’m going to talk to you now for a few minutes about how we can approve novel equipment.
I’m going to share three novel personal flotation devices. Which one do you think has the potential to be approved?
One is an inflatable bladder integrated into a rashguard.
One is an inflatable bladder worn on a wrist band.
One is an inherently buoyant dog life vest.
All of them are great ideas, but not all of these ideas can be Coast Guard approved.
The pet lifejacket cannot be approved because lifejackets for pets are not required to be carried on vessels, and therefore cannot receive type approval.
The inflatable wrist band would not provide an equivalent level of safety as a PFD meeting the requirements because there is no support to keep the users airway out of the water.
The rashguard PFD could be used to meet carriage requirements, and it might provide an equivalent level of safety as a PFD that meets all of the requirements. This needs further evaluation.
In step one, we will conduct a high level review of the design concept. This is the stage where the applicants with the inflatable wrist band and dog vest would be notified that their products are not eligible for Coast Guard approval.
In step two, a detailed analysis is conducted. All areas where the product does not meet the standard or requirements are identified. This step is completed with the recognized laboratory. The lab and Coast Guard will work together to determine any additional tests that will be required to demonstrate equivalent performance.
In step 3, the test plan is formally accepted and the applicant is notified that they may begin approval testing.
Next, the approval testing is conducted.
The test results are reviewed and, if acceptable, approval is granted.
This slide is extra and can be skipped.
This slide is extra and can be skipped.
Innovation, collaboration and teamwork, and advancing standards are a large part of our strategic business plan. We support innovation. We collaborate with stakeholders including manufacturers, labs, industry groups, standards organizations, and international partners. We will work with applicants and manufacturers to clearly communicate requirements and expectations to facilitate the evaluation of new and novel PFDs.