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NOTE:  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 & 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 USCG’s 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.  (See discussion in “Note” below)  Unless it is a new concept, most recreational PFDs may be submitted directly to the laboratory for approval.

U.S. Coast Guard approval of PFDs manufactured in accordance with any one of the PFD specification subparts must be handled through a Recognized Laboratory. Each of these specification subparts listed below briefly describes the steps involved in obtaining Coast Guard approval.  The corresponding UL standard for each PFD type contains detailed test procedures to be employed to determine compliance with the regulation requirements.

Pre-approval Review: A proposed PFD design (drawing, pictures, sample, etc.) may be sent to the Coast Guard for review of its suitability for approval prior to the PFD being submitted to the laboratory for testing.

Note: A positive Coast Guard evaluation is no guarantee of approval since testing cannot be performed by the Coast Guard. The purpose of the Coast Guard's preliminary review is to identify serious and obvious design problems before the manufacturer starts incurring laboratory test expenses and to determine if any special testing or coordination with the lab may be required. To increase the chances of successful and timely completion of testing at the laboratory, manufacturers should perform all required testing on their own before submitting a device for approval.

In response to the initial inquiry made by the PFD manufacturer, the recognized laboratory will determine a cost estimate for the work. Accompanying the cost estimate will be an application and additional information for the PFD manufacturer.

The manufacturer then submits samples of each model and each size to be tested to the laboratory. Where alternate constructions and/or materials are proposed to be used, samples must be the weakest possible combinations. After receipt of the samples to be tested, along with a signed application, the recognized laboratory will evaluate and test the design against the requirements in the applicable Coast Guard specification subpart and UL Standard(s). A test report and Follow-Up Inspection Procedure will be drafted by the laboratory and sent to the Commandant (G-MSE-4) for review. In most cases, the Procedure is issued to the applicant to start production at the same time it is sent to the Coast Guard. For reports requiring Coast Guard review prior to issuance, the Coast Guard will notify the laboratory whether or not U.S. Coast Guard approval will be granted. The laboratory will, in turn, notify the applicant.

* Release of Labels: After the laboratory has completed approval testing and, if required, verbal approval has been given by the U.S. Coast Guard, the laboratory will release labels (assign an "issue number" which must be included on the PFDs label) to the manufacturer so that production can begin.

* Frequency of Inspection: Laboratory follow-up inspections are based upon a sampling plan. Visits are made based on the number of devices produced and the extent of controls exercised by the production facility. Approximately 1 visit per 6000 to 24,000 units produced can be expected. Inspection frequency is increased when inadequacies are indicated by test failures, incomplete or inadequate records, consumer complaints, or any other indication of production or quality control problems. The recognized 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 product.

* Annual Testing at the Recognized Laboratory: In addition to the tests conducted during normal production visits, samples of wearable recreational PFDs are sent to the recognized laboratory's testing facilities once a year for examination and testing.

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