Upcoming Changes toUSCG Approval of

Wearable PFDs

Brandi BaldwinU. S. Coast Guard (CG-5214)

Lifesaving & Fire Safety Division brandi.a.baldwin@uscg.mil

Consolidated North American Standard◦ Overview (Background & Accomplishments)◦ Classification (Type Codes)◦ Labeling

Youth Inflatables◦ Background◦ Standards proposals◦ Regulatory action

Topics…

2007: Industry-led initiative to revise the current approval standards for wearable PFDs

Harmonize US/Canadian requirements Task Group: USCG, TC, UL, UL-C, CORD

Group Inc., US & Canadian mfrs Two approaches

◦ “Clean sheet of paper”◦ “ISO-based, w/ National deviations”

Consolidated North American Standard Background

ISO vs UL vs CGSB: Gap Analysis Propose changes to ISO Oct 2010: STP Formally established IHC Preliminary Review

◦ Comments only – Not a vote◦ Fall 2011: Comment period closed

IHC working to resolve comments ◦ Jan 2012: STP meeting

Recirculate or Ballot

Consolidated North American Standard Accomplishments

Type Codes (I, II, III, IV, V)◦ What do they mean?◦ Type II vs Type III?

Alternative regulatory terminology◦ “Approved under approval series…”

Inspection regulations refer to 21 different approval series for personal LSA

◦“Life Preserver”, “Buoyant Vest”, “Marine Buoyant Device”

◦“…of a type approved by the Commandant.”

Consolidated North American Standard Classification (USCG)

ISO Classification of PFDs◦ Buoyancy Aid vs Lifejacket

ISO Performance Levels ◦ Level 50 (BA)- Sheltered waters, Rescue close at

hand, Swimmers only◦ Level 100 (LJ)- Sheltered/calm water, may wait

for rescue; Some turning ability◦ Level 150 (LJ)- General, offshore, and rough water;

Strong turning ability◦ Level 275 (LJ)- Offshore, Severe weather/sea

conditions; Maximum turning ability

Consolidated North American Standard ISO Classification & Performance Levels

ISO StandardPerformance Levels

Selection

Use and Care

Certification

Reclassification and Labeling Project◦ Dec 2004: ASE Labels Study

Too wordy, Confusing, Not ‘User-Friendly’ Group relevant information (Selection, Use/Care,

Certification) Use icons where possible

◦ Overcome by the Consolidated North American Standard development efforts

◦ Looking at ISO Labels

Consolidated North American Standard Labeling

Labels Task Group◦ More “user-friendly” markings◦ Multiple languages (English, French, Spanish)◦ Pictograms

Focus Groups – Nov 2011◦ Hosted by UL and BoatUS Foundation◦ Recreational boaters, range of experience◦ Feedback strongly correlated to 2004 results

Consolidated North American Standard Labeling Task Group

Selection Panel Use/Care Panel Certification Panel

New Proposal – Panel Approach

Layout may change, but similar information will be grouped together

Greater use of icons vs words Still under development

Publish new standard: Summer 2012? Eliminate Type Codes

◦ Do your State laws reference USCG type codes?!?!?!

All labels will change ~2 year transition

◦ May see multiple labels on the market◦ USCG regulatory changes

Consolidated North American Standard Bottom Line – START NOW!!!!

We will support you by:◦ Working with your legislators to revise state laws to align

with new USCG approval framework We need you to:

◦ Engage the legislators◦ Tell us what you need!

Open the lines of communication◦ brandi.a.baldwin@uscg.mil◦ Federal Register

HUGE Public Education Effort◦ Developing “Press Kits” to standardize the message

Consolidated North American Standard Bottom Line - Partnership

PFD wear rate has been a NBSAC priority for many years

Current requirements:◦ 0-12 yrs: Mandatory wear!

◦ 16+ yrs: Inflatable PFDs are an option for users 80+ lbs

Youth Inflatable PFDsBackground

◦ 13-15 years: only inherently buoyant (foam) not required to be worn

Close the gap

Jan 2008: Proposed revisions to UL 1180◦ Users 12-15 years, 80+ lbs;◦ Automatic inflation only;◦ No secondary donning;◦ Must be worn;◦ Rearming and repacking by an adult.

Discussed by STP◦ Largely supported in principle◦ Some textual revisions

Ballot did not reach consensus◦ Waiting for ASE Study

Youth Inflatable PFDsStandards Development

Oct 2009: Refined proposal◦ Similar substantive requirements.◦ 13-15 years

Ballot failed to reach consensus◦ Broad support in principle◦ Unresolved technical issues◦ Direct conflict with regulations◦ 46 CFR 160.076-1 “Approved for use by adults only”

Youth Inflatable PFDsStandards Development

ANPRM: Nov ’93 (58 FR 59428) Final Rule: Mar ’96 (61 FR 13931)

◦ “..not now considered appropriate…”◦ “…revisited after more experience…”

Direct Final Rule: March 2011(76 FR 17561)◦ Update references to UL standards◦ Eliminate redundancies◦ Remove “Adults only” language◦ Withdrawn Sept 2011

Notice of Proposed Rulemaking: 76 FR 60405◦ Comment period closed November 28, 2011.

Youth Inflatable PFDsUSCG Rulemaking

Current rulemaking◦ Only the first step◦ Does NOT allow youth to wear inflatable PFDs◦ Removes barrier to standards development

ANSI standard◦ Revision to UL 1180◦ Adoption of the ISO 12402 series

Follow-on rulemaking◦ Any new standard MUST be incorporated into the

CFR before the USCG can approve inflatable PFDs for users under 16 years old.

Youth Inflatable PFDsWhat Happens Next

Questions?