Personal Flotation Devices & Lights
: Vessel operators
are required to carry USCG Approved PFDs, but
unapproved PFDs may be carried and used as additional equipment on
recreational boats (and some commercial vessels). Therefore,
unapproved flotation devices may be sold and used unless prohibited on
your class of inspected vessel.
APPROVAL GUIDANCE FOR
COMMERCIAL PFDs / LIFEJACKETS:
160.002, 160.003, 160.004, 160.005, 160.053, 160.055, 160.077, 160.155
(SOLAS), 160.176 (SOLAS)
GUIDANCE & INFORMATION:
All PFDs are approved by the Coast Guard, but some require little or no
direct USCG review prior to approval. All PFDs must be tested by
the USCGs Recognized Laboratory, which is Underwriters Laboratories,
Inc. The Coast Guard will do a pre-approval review of any new
concept prior to submitting it for testing to the Recognized
Laboratory. Commercial PFDs / lifejackets require the most USCG
involvement and the USCG should be notified whenever a design is
submitted to the laboratory for approval to minimize the chance of a
characteristic being identified that would prevent approval after
considerable time and money has been spent on testing.
Production Sampling, Tests, and
After type-approval all production of approved PFDs is overseen the
recognized laboratory, as follows:
References: Once a device is approved, the
independent laboratory will conduct inspections and tests of the PFDs
in addition to the manufacturer's quality control as specified in the
Guide for Independent Organization Inspection of Type I and V PFDs or
the Guide for Independent Organization Inspection of Type IV PFDs, as
Manufacturer's Quality Control
Program: Manufacturers of U.S.
Coast Guard approved PFDs must maintain a quality control program to
include control of inventory and processing of all materials,
performance of required production tests and inspections, and
maintenance of records detailing the results of those tests and
inspections. This is to ensure compliance with the applicable
specification subpart and approval conditions, and to maintain
traceability of all components used back to their source.
When a lot of PFDs is presented
for production inspection, the manufacturer must have previously taken
all ordinary precautions to ensure that the PFDs are in full compliance
with the requirements of the applicable specification subpart and
NOTE: The independent laboratory inspections and tests are not
intended to replace or be a substitute for any inspections and tests
normally employed by the manufacturer to maintain the quality of the
Type I Inspection Marking: Once the required number of sample
PFDs have been tested as prescribed by the applicable PFD specification
subpart and Guide, and the independent laboratory inspector is
satisfied that each PFD in the lot being tested is:
(1) of the type officially approved, and
(2) in compliance with the requirements of the applicable specification
subpart and approval conditions, then each PFD shall be plainly marked
in waterproof ink with the words, "Inspected and Passed, (date),
(identification of independent laboratory)."
submit the follow information:
Cover letter - requesting approval of the PFD.
Drawings - Detailed engineering drawings that include:
* Tolerances for all dimensions.
* Thickness (diameter) & other dimensions of all
* The construction of "T" tabs on free strap ends.
* Size of box-x stitch and/or bar tack (including
number of stitches and width).
* Note whether foam dimensions are before or after
dipping/coating, if used.
* Identify number of parts when not shown.
* Location of all straps, belt loops, and hardware.
* Seam details including allowances.
* Pocket sizes and locations, if any.
* Marking/Labeling: Text, Layout.
Bill of Materials - A parts list
which is keyed to the drawing ("Find
Numbers") and gives each item's descriptive name, the manufacturer,
manufacturer's unique part (trade) name, whether the component is
standard or non-standard, and basis for acceptability (i.e., (1)
compliance with applicable section of USCG specification subparts (by
specific paragraph) or applicable federal or military specifications
with type, style, class, etc., as applicable, or equivalent, based on
UL Recognition with applicable "Use Code").
Construction Description - Notes on the drawings or a separate
construction description should cover all construction details which
differ from the subpart, and particularly the following points:
* The design buoyancy (and distribution) of the
device and the production tolerance which
will be maintained.
* Details of stitching, size, and type.
* Thickness and method of applying standard vinyl
dip coating (2.5 mm (10 mils) minimum) or
other coating, if used.
* References to applicable sections/paragraphs of
* The length, adjustment, rigging, and tolerances on
the various straps.
* Ring buoy: weight, density, and respective
* The method of construction of all structural and
Quality Control - A brief description
of the quality control (sampling,
inspection, test, and records) which will be used in the production of
the device. This description should be equivalent to that which is
required by the appropriate USCG subpart (and MIL-L-17653B for 160.053
approvals) and 46 CFR 159.007. If a device is to be UL listed, the UL
Procedure will usually cover all the necessary quality control. In some
cases the USCG Independent Laboratory Guidelines may be referenced.
Affidavits - Standard component affidavits must be provided for all
component materials that are not UL recognized. In production, if you
substitute alternate components for those in the initially approved
bill of materials, you must first provide the USCG with affidavits
(with local copies on file) or the Use Codes for a UL recognized
components. The substitute components must be from the approved Bill of
Materials, or else you must submit a new bill of materials for
approval. Affidavits must:
* Be current (within the last year).
* Identify the component by a unique style number,
model number, weight, size, class, denier, etc.
* Reference the correct/applicable USCG
specification subpart and the specific paragraph of
the subpart with
which the component complies.
* Show the type, class, size, etc. of the federal or
military specification referenced
* Certify to the Standard under which the device is
to be approved.
* Be accurate/truthful (e.g., synthetic materials
cannot meet cotton specifications).
Please send the Submittal Package and other related information to the
U.S. Coast Guard
2703 Martin Luther King Ave SE
Washington, DC 20593-0001
Once the equipment has been tested by
the Recognized Laboratory and
reviewed by this office and found to be in compliance, it will received
Coast Guard Type Approval and a Certificate of Approval (COA).
The COA will be issued for 5 years and will remain valid during that
time period if the product continues to meet the approval and the
Quality Control Program requirements.