USCG Lifesaving & Fire Safety Division Update
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USCG Lifesaving & Fire Safety Division Update Speaker: Brandi Baldwin, U.S. Coast Guard Lifesaving & Fire Safety Division, Chief
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USCG Lifesaving & Fire Safety Division Update
- 1. 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
- 2. 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
- 3. 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
- 4. 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
- 5. 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
- 6. 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
- 7. Unified Agenda – Fall 2021
- 9. 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
- 10. 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
- 12. 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
- 14. 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
- 16. 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
- 17. 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)
- 18. 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.
- 19. 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?
- 20. 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 ?
- 21. 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
- 22. 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
Editor's Notes
- 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.