Brandi Baldwin, P.E. U.S. Coast Guard Lifesaving and Fire Safety Division, Office of Design and Engineering Standards Changes are coming on new standards for wearable personal flotation devices (PFD), aka life jackets. These new standards will be harmonized with Canada and based on the International Standards Organization (ISO) standard currently being used in Europe. A notable impact of the move towards a more international harmonization is the elimination of the current type codes (i.e., Type I, II, III, etc). Since many states use these terms in their current laws and regulations, the Coast Guard wants start the dialog now so that the transition is less of a shock to you and your programs.

1. Brandi Baldwin
U. S. Coast Guard (CG-5214)
Lifesaving & Fire Safety Division
brandi.a.baldwin@uscg.mil

2.  Consolidated North American Standard
◦ Overview (Background & Accomplishments)
◦ Classification (Type Codes)
◦ Labeling
 Youth Inflatables
◦ Background
◦ Standards proposals
◦ Regulatory action

3.  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”

4.  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

5.  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.”

6.  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

8. Selection
Use and Care
Certification

9.  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

11.  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

12.  Selection Panel
 Use/Care Panel
 Certification Panel
 Layout may change, but similar information will
be grouped together
 Greater use of icons vs words
 Still under development

13.  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

14.  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

15.  PFD wear rate has been a NBSAC priority for
many years
 Current requirements:
◦ 0-12 yrs: Mandatory wear!
◦ 13-15 years:
 only inherently buoyant (foam)
 not required to be worn
◦ 16+ yrs: Inflatable PFDs are an option for users 80+
lbs
 Close the gap

16.  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

17.  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”

18.  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.

19.  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.