R 082000Z NOV 02 ZUI ASN-A00312000021
FM COMDT COGARD WASHINGTON DC//G-O//
TO ALCOAST
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UNCLAS //N10470//
ALCOAST 525/02
COMDTNOTE 10470
SUBJ: AUTOMATIC INFLATABLE PFDS, 18 MONTH REVIEW AND POLICY CHANGE
A. RESCUE AND SURVIVAL SYSTEMS MANUAL, COMDTINST M10470.10E
B. AUXILIARY OPERATIONS POLICY MANUAL, COMDTINST M16798.3D
1. 18 MONTHS AGO AUTOMATIC INFLATABLE PFDS WERE AUTHORIZED FOR USE
BY BOAT CREW MEMBERS, BOARDING TEAM MEMBERS AND SCHEDULED
PASSENGERS. DURING THE 18 MONTH PERIOD, NUMEROUS MISHAPS INVOLVING
MINOR INADVERTENT INFLATIONS, SERIOUS NON-INFLATIONS INDICATING
IMPROPER MAINTENANCE, AND INDICATIONS OF THE MANDATORY PERFORMANCE
QUALIFICATION STANDARD TRAINING NOT BEING COMPLETED HAVE PROMPTED A
REVIEW AND POLICY UPDATE. LUCKILY NONE OF THESE MISHAPS HAS
RESULTED IN SERIOUS INJURY. HOWEVER, THESE AVOIDABLE MISHAP FACTORS
ASSOCIATED WITH THE INFLATABLE PFDS HAVE BEEN IDENTIFIED AS A
BROKEN LINK IN THE SAFETY CHAIN OF EVENTS THAT COULD HAVE EASILY
LED TO SERIOUS INJURIES OR DEATH.
2. EFFECTIVE IMMEDIATELY, ALL AREA, DISTRICT AND GROUP
COMMANDS/UNITS SHALL TAKE ALL STEPS NECESSARY TO ENSURE THAT
SUBORDINATE LEVELS IN THE OPERATIONAL CHAIN OF COMMAND STRICTLY
COMPLY WITH THE POLICIES ASSOCIATED WITH TRAINING, PROPER USE,
MAINTENANCE AND INSPECTIONS DIRECTED BY CHAPTER 4 OF REF A. THIS
SHALL INCLUDE AN IMMEDIATE REVIEW OF ALL TRAINING RECORDS TO ENSURE
THAT THE PERSONAL QUALIFICATION STANDARD DIRECTED FOR USE BY
CHAPTER 4.D. OF REF A IS COMPLETELY SIGNED OFF AND ENTERED IN EACH
BOAT CREW MEMBERS AND BOARDING TEAM MEMBERS TRAINING RECORD. IN
ADDITION, CONDUCT AN IMMEDIATE REVIEW OF MAINTENANCE RECORDS TO
ENSURE ALL AUTOMATIC INFLATABLE PFDS ARE PROPERLY PLACED INTO
SERVICE WITH REQUIRED DOCUMENTATION AND THAT ALL SIX MONTH
INSPECTIONS HAVE BEEN COMPLETED AND RECORDED. FINALLY, IMMEDIATELY
ENSURE THAT EACH INFLATABLE PFD IS CORRECTLY CONFIGURED WITH THE
CARBON DIOXIDE CYLINDER INSTALLED IN ACCORDANCE WITH THE
APPROPRIATE MAINTENANCE PROCEDURE CARD.
3. EFFECTIVE IMMEDIATELY, AUTOMATICALLY INFLATING PFDS SHALL NOT BE
USED ON COAST GUARD BOATS WITH ENCLOSED SPACES, SUCH AS BUT NOT
LIMITED TO, COCKPITS, CABINS, ENGINE ROOMS OR SURVIVORS
COMPARTMENTS. THE REASON FOR THIS SIGNIFICANT POLICY CHANGE IS DUE
TO THE HIGH BUOYANCY RATINGS OF INFLATABLE PFDS. IF A CREW MEMBER
WERE CAUGHT INSIDE A FLOODED ENCLOSED SPACE OF A VESSEL AND THE PFD
INFLATED, THE 33 TO 38 POUNDS OF BUOYANCY WOULD PIN THE CREW MEMBER
TO THE HIGHEST POINT IN THAT ENCLOSED SPACE AND WOULD PREVENT
EGRESS FROM THE FLOODED COMPARTMENT. ADD THE FOLLOWING PEN AND INK
CHANGE AS A WARNING TO PAGE 4-31 OF REF A: "WARNING, AUTOMATICALLY
INFLATING PFDS SHALL NOT BE USED ON COAST GUARD BOATS WITH ENCLOSED
SPACES, SUCH AS BUT NOT LIMITED TO, COCKPITS, CABINS, ENGINE ROOMS
OR SURVIVORS COMPARTMENTS."
4. A BOAT CREW/BOARDING TEAM TRAINING PLAN IS BEING CONSIDERED FOR
BOAT EGRESS PROCEDURES AND THE USE OF MANUALLY INFLATING PFDS ON
BOATS WITH ENCLOSED SPACES. THIS TYPE OF TRAINING IS EXTENSIVE AND
WOULD REQUIRE EACH BOAT CREWMEMBER/BOARDING TEAM MEMBER TO QUALIFY
TO USE AUTOMATIC INFLATING PFDS ON BOATS WITH ENCLOSED SPACES.
5. A COPY OF THIS ALCOAST SHALL BE RETAINED IN THE FRONT OF REF A
PENDING PROMULGATION OF CHANGE 1.
6. COAST GUARD AUXILIARY BOAT CREWMEMBERS SHALL COMPLY WITH
PARAGRAPH 3 ABOVE. AUXILIARY MEMBERS SHALL MAKE THE FOLLOWING PEN
AND INK CHANGE TO REF B, CHAPTER 4 PARAGRAPH 11. CHANGE THE SECOND
SENTENCE TO READ: "ALL AUXILIARISTS, ON PATROL SHALL WEAR THE
APPROPRIATE COAST GUARD APPROVED TYPE I, II OR III PERSONAL
FLOTATION DEVICE (PFD) WHICH INCLUDES COAST GUARD APPROVED
AUTOMATIC INFLATABLE TYPE I, II OR III PFD FOR AUXILIARY MEMBERS,
EXCEPT ON BOATS WITH ENCLOSED SPACES, SUCH AS BUT NOT LIMITED TO,
COCKPITS, CABINS, ENGINE ROOMS OR SURVIVOR CABINS."
7. QUESTIONS MAY BE DIRECTED TO CWO KIRK NEPRUD AT KNEPRUD(AT)
COMDT.USCG.MIL OR (202) 267-1585.
8. INTERNET RELEASE AUTHORIZED.
9. RELEASED BY RADM DAVID S. BELZ, ASSISTANT COMMANDANT FOR
OPERATIONS.
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