Liferafts.....revisited

[corrirod]

O.k, I was alarmed to find out from Dean Fleck and one of the CG representatives at the liferaft demo that even recreational boaters must have liferafts repacked and certified. This surprised me.

I realize that it is necessary to make sure you have a working device but to get a ticket for having an expired raft, that wasn't mandatory equipment to begin with seems out of order to me. I had a similar event happen when receiving a safety inspection back when I had the Trophy, in which I was "warned but could've been ticketed" for having spare flares/signals that had expired. I was told if they were onboard they had to be "good" or I was in violation, regardless of whether or not I had good ones onboard at the same time. Now, while looking into the liferaft issue, I noticed that apparently it IS o.k. now to have both onboard as long as you have enough good ones to meet the requirements. Why would this be any different on the liferaft issue?

As I said above, I understand that everyone should keep their gear up-to-date, and with the new gear you don't have to do it as often, however I see no need to penalize someone for having expired gear if it's gear that IS NOT REQUIRED TO BE ON THE BOAT TO BEGIN WITH.

I've said it before, I think ANY safety item is better than none. Perhaps more small boaters would consider basic liferafts if they didn't have to spend $500 every 2-3 years getting them repacked? For someone who had trouble affording a $12,000 boat, spending $2000 on a raft and then $500+ on repackings may not be affordable so they'll just go without. I'd rather see an expired raft on their boat than none at all.

Any thoughts?

[Billfisher]

Agreed. Unfortunately, the only other opinion I have heard on the matter came from a stakeholder in the 're-packing' business. At the time, the question was around 'expired' survival suits. On that issue as this one, I'd rather have out of date or less than perfect commercial grade stuff, IN ADDITION to what is required, if that is all I can afford.

On the other hand, I saw with my own eyes how lousy expired flares performed, so I'm adjusting my position in the flare department.

[little doc]

In principle I agree, but to play devil's advocate,

Take the scenario where someone has an expired safety device that may be less reliable and subsequently uses the false security that the expired device affords to then go where they would not normally venture. The expired device then puts them in a more dangerous position than they would have been in without it.

I think an expired device is better than no device, but no one ever said boating was an affordable hobby. If we cannot get the appropriate gear to do it safely, maybe we should rethink our position on going that far offshore.

[corrirod]

little doc, I understand however I don't see the need to get fined for having "extra" gear that is not "required" to begin with. If it were required then I could understand.

If we cannot get the appropriate gear to do it safely, maybe we should rethink our position on going that far offshore.

"That far offshore" only need be 100 yds off the tips of the jetty here off the Oregon coast. Whether its 100yds or 100 miles, both are about the same in our frigid waters.

If I found a 5 year old EPIRB at a garage sale and didn't have the $350 to put a new battery in it, but I threw it in my boat anyway, do I deserve a ticket for something that "might" actually still work even though I'm not "required" to carry it?

Sorry, just seems counterproductive to me.

[Something Good]

Sounds silly to me Rod. Ticket for equipment that you're not even required to have. Silly laws are why I held off on getting radar so long. Try to be safe to the best of your ability and get punished for it. There comes a point when you can take safety so far as to not make things fun anymore. The safest thing to do would be to stay home but what fun would that be.

I'm adding an EPIRB or PLB to my ditch bag this year but I don't think I'll go as far as getting a life raft.

[VICTORY]

OK, I hear you guys on this one, and here is what my book says.....hope it helps.

46CFR28.140(B):
Each item of lifesaving equipment, including unapproved equipment, must be maintained and inspected with:
(1) Table 28.140 in this section;
(2) The servicing procedure under the subpart of this chapter applicable to the items approval; and
(3) The manufactures guidelines.
(c) An inflatable liferaft or inflatable buoyant apparatus must be serviced no latter than the month and year on its servicing sticker affixed under 46CFR160.151-1579(n), and whenever the container is damaged or the container straps or seal is broken. It must be serviced at a facility specifically approved by the Commandant for the particular brand.


BUT here is where I am going to throw the wrench in the gears and kick this up to D13 Legal as well, 46CFR's apply to Commercial Fishing vessels, but table 28.120(b) under 46CFR28.120 says "Survival Craft for Undocumented Vessels with not more than 16 people on board, beyond 20 miles of coastline requires a Inflatable buoyant apparatus." It does not clearly state, "engaged in a commercial industry" so this could blanket rec. boats.


So what I SEE is that a recreational vsl is not required a inflatable life raft, but if you look at just a the term "liferaft" and carry one it is required to be serviced. This rule seems to apply to Commercial only, Documented and Undocumented, but nothing about recreational boating. So I COULD read this as you would not be required to service your raft???? The rule is stated 46CFR28.140(B) having unapproved gear serviced would not apply if a 46CFR apllies to the commercial industry and not the recreational boater.

Please do not take this as the word of the land yet, let me put someones name behind this who makes a little more money than me! haha
I will post up info ASAP.

Hope this helps???
Mike

[Tower Todd]

Victory,

Thanks for the info. I have a question for you that hopefully you can shed some light on for me.

Recently I attended the Seattle Boat Show and looked at the Winslow Brand of liferafts. Winslows are highly regarded life rafts and many people feel they are the best. I asked the rep if they were Coast Guard approved the rep smiled for a moment and said let me explain. She told me that the Coast Guard has not approved their rafts, but that the Coast Guard uses thier rafts! Something about some older rules or specs that thier rafts don't meet. Can you shed any light on this? I was scratching my head on this one.

Thank You,
TT

[Chromaflage]

VICTORY,

Thank you for the post. Here's another kicker:

"Survival Craft for Undocumented Vessels with not more than 16 people on board, beyond 20 miles of coastline requires a Inflatable buoyant apparatus."

Unless "inflatable bouyant apparatus" is specifically defined some where, I might interpret this as anything that is bouyant and inflatable. For instance, an air matress, that may not be required to be inspected.

CrF

[VICTORY]

Tower Todd
I would have to see if I can find anything on that brand.

Chromaflage
You could interpert the IBA rule that way, but one kicker, there is not a USCG Approval number on your air matress, sorry. There is another CFR that defines what an IBA is.

[corrirod]

Thanks for checking Mike. I'll be interested to hear what the legal department says about this because I looked all over the regs and came up with the same thing you did, as far as the regs being directed towards commercials but were lacking definition in the recreational regulations.

I was looking into rafts and the company that sells the rafts was under the impression that recreational boats were not required to service them, however they "recommended" they be serviced.

With the new rafts being certified every three years though, if you get the "offshore" rafts, with flare kits, the flares will need replacement every three years anyway. Because of this though the repacks will be more expensive. Figure $125 an hour for the repack then depending on how elaborate your flare kit is, assuming you have SOLAS rated flares, you could spend $200-$300 just for that. Your looking at $400-$500 a pack. But, if you look at the annual cost of $150-175 per year, it's good insurance to make sure your family gets to see you again on shore.

Thanks again Mike for all your help and thanks to all the CG men and women for risking everything to keep us safe.

[fishtales]

I could be proved wrong here but I am under the impression that once the first grace period runs out (most are two years I think), you are then required to repak EVERY YEAR after that.
Please prove me wrong on this.
Dick
FT

[corrirod]

fishtales,

I don't know if the information is correct or not but I was told by the dealer that the new ones only require servicing every 3 years, and that is new this year. Again, I'm only telling you what I was told and I'm not sure what the "reality" is yet.

[fishtales]

Rod,
The water is still pretty muddy around this topic. I got my information from Dean Fleck at Englund's however things do change.
I know there is a State Marine Borad meeting on the 15th or the 16th that I plan to attend. One topic will be should they adopt a rule to accept sat phones in place of single side bands. There are other saftey issues on the agenda also but I do not know what they are at this time. Many of the rule clarifications may change slightly after that meeting?????
Dick

[corrirod]

Dick,

I hear you. Dean told me he was going to check on the 3 year deal now that the new rafts were coming out. I had another vendor tell me the new rafts had 3 year intervals and they do repacks also so hopefully they are right.

[tomictime]

great post, another reason to "frequent" ifish:

so is it three years from date of sale? and if so, how much sense does that make?

TT: I am looking at Winslow also, 6 man. PM if you have found a deal.

JD

[VICTORY]

On your raft servicing question it has always been two years on a new raft, then a annual re-pack after that. This three year option may be brand specific and has to be USCG approved. I would assume you are going to pay more for a raft that comes with a three year intial re-pack over a comparable two year then re-pack. You never get extra for free.

What I am trying to dig up for you guys is, If a rec boat is not even required to carry a liferaft, then would a re-pack even been required. Back to my 33CFR versus 46CFR. 46CFR says any gear, even if not required, if on board and availiable will be serviced, but that to me reads on a commercial vessel. 33CFR for an Undocumented, (does not secifiy recreational, which a state registered boat is undocumented but do they mean undocumented fishing commercialy) carrying 16 POB or less would only require an IBA beyond 20NM.

Like I mentioned I must consult the pros who wrtie this stuff up for specific clearification if this applies to recreation fishing or commercial operations. In black and white as it reads everyone who fishes the Chicken Ranch off YB is required an IBA, but I know thats not the case.

Also remember, from a USCG standpoint when it comes to enforcment our main purpose is education. Anyone taking extra steps to ensure safety will always be more welcomed then the ones obviously in denial. If you are trying to carry extra gear and there is an issue, we will always look more favorable on the person attempting to be safer and seek a corrective action over an enforcement action.

[Gloucester]

I'll sound off and go with this applies to Commercial guys only. Like Mike said, fishing the ranch would require at least an IBA. That's not happening.

There was a big stink awhile back, rec boats running out past 20, 50 NM, collecting Tuna and coming back to the dock and selling. Here's the kicker to that one, once you buy the commercial license to sell tuna off the docks, your vessel now becomes commercial if you are fishing for TUNA and or have TUNA onboard. You must now comply with commercial rules vice rec rules. Ie, liferaft, flares, radio, etc. everything a commercial guy would have to do.

I'll be watching and interested in hearing what Mike finds out....

Also, like Mike said, one who carries more than what is required will most likely be thanked, not ticket for having something that is expired and not required.....it's much easier to just tell you to take it off the boat

Now, if Mike comes back with something else and you could be ticketed for having extra gear onboard that is expired......blame him! Darn Yaquina Bay Coast Guard guys. Sorry Mike, couldn't resist

CS

[blubeast]

CS & Mike... thanks for trying to clear this up.

Sincerely appeciate you guys trying to get us good info and all of the other things you do to keep us safe.

[jacksalmon]

Help me out here boys, please. In one of the posts above, someone said that an undocumented vessel beyond 20 nautical miles with less than 16 on board must have an inflatable bouyant apparatus (IBA) on board. Are our recreational boats 'undocumented vessels"? If so, are we supposed to have liferafts on board if we go beyond 20? I sure hope we are not undocumented vessels. Thanks.

[corrirod]

Jacksalmon,

We are undocumented vessels but the issue Mike(Victory) is clarifying is if the CFR regs are for commercials only or if they carry over to recreational boaters as well. If they do then we'll all be needing IBA's.

[Nalu]

A 6-Pack charter such as myself running a vessel that is state registered (not documented) is an example of a vessel required to carry an IBA or greater when operating 20 miles or more offshore. (I actually carry a SOLAS raft).

Requirements for EPIRBS, liferafts, pyrotechnics (in addition to basic requirements), and communications apply to vessels that are engaged in some sort of commercial activity, whether it is fishing or the carrying of passengers for hire.

[Aqua-Holic]

If I read the posts of Victory: "In black and white as it reads everyone who fishes the Chicken Ranch off YB is required an IBA, but I know thats not the case." and USCG Depoe Bay "Like Mike said, fishing the ranch would require at least an IBA. That's not happening." correctly, I'm content on leaving the status quo.
As a rec boat operater, a $3000 to $6000 investment in a liferaft recommended for use beyond 20nm should be an individual decision.
I would however be interested in the definition of an IBA.

[Gaffer]

We are all thinking inflatable!
What about the large ridged foam flotation rings that are approx 4'x6'.
I think I have seen these with a floor. Would they work in our waters?
No inflation, no service and always ready. Just add your ditch bag.

[FisherJack]

Aqua-Holic, I believe that IBA refers to inflatable buoyant apparatus. FYI, Dean, the applicable CFR sets forth the following hierachy of survival craft in descending order: "lifeboat, inflatable liferaft with SOLAS A pack, inflatable liferaft with SOLAS B pack, inflatable liferaft with coastal service pack, inflatable buoyant apparatus, life float, buoyant apparatus." 46 CFR 28,Table 28.120(a), Note 2.

While I certainly am not an expert in the CFRs governing ocean-going craft, I have dealt with the interpretation of administrative rules at the state level for more than two decades as an Administrative Law Judge for the State of Oregon. My preliminary examination of the CRFs lead me believe that there is no requirement for sports fishing Salty Dogs going out on big blue to carry liferafts under any circumstance. I will do some further research to confirm this and will post my results.

[Aqua-Holic]

Thanks for the reply Jack. My point is, that this thread appears to be calling for a new and different interpretation of an existing regulation.
That being the case, not only would we be required to carry a liferaft beyond 20nm but also one that is CG approved and recommended for such use by the manufacturer, thus putting that unit in the price range stated above.
As to an "IBA", does anyone have an example of one, other than a "liferaft", which would be CG approved and recommened by the manufacturer for use beyond 20nm?

[USCGBoating]

The CFR’s do not specifically identify inflatable rafts under the Recreational Boating Regulations in 33 CFR or inthe general regulations in 46 CFR. Because of that I would defer to the manufacturers recommended inspection interval which is more than likely what the Coast Guard requires for commercial vessels.

My experience with rafts is that if you are going to spend the money on one and want to rely on it to work you should have it inspected periodically to insure its ability to perform.

This may be an issue that the States could look into some form of regulation on inspection.

Dan

[USCGBoating]

Originally Posted by Tower Todd

Victory,

Thanks for the info. I have a question for you that hopefully you can shed some light on for me.

Recently I attended the Seattle Boat Show and looked at the Winslow Brand of liferafts. Winslows are highly regarded life rafts and many people feel they are the best. I asked the rep if they were Coast Guard approved the rep smiled for a moment and said let me explain. She told me that the Coast Guard has not approved their rafts, but that the Coast Guard uses thier rafts! Something about some older rules or specs that thier rafts don't meet. Can you shed any light on this? I was scratching my head on this one.

Thank You,
TT

Tower Tod

This was obviously a person who know very little about the regulations and Coast Guard requirements for survival equipment. Obviously she was attempting to make a sale. We are required to have our rafts inspected and they are all, by Coast Guard Regulations, Coast Guard approved rafts.

Dan

[VICTORY]

Originally Posted by USCGBoating

Tower Tod

This was obviously a person who know very little about the regulations and Coast Guard requirements for survival equipment. Obviously she was attempting to make a sale. We are required to have our rafts inspected and they are all, by Coast Guard Regulations, Coast Guard approved rafts.

Dan

Yes I second that, I was the Resuce and Survival Petty Officer here at YB for two years, and the new one works for me, every year our raft goes to Englund Marine to be service, beware of the hype to make a sale!!

And we put a raft on the only Motor Life Boat that has never rolled in the history of that hull since 1956!

[Herring Problem]

Here's a four man raft kit for example.



Offshore Ocean


The Offshore Ocean comes complete with double buoyancy tubes for protection against accidental puncture and provides additional freeboard. The inflatable arch tube with furlable canopy and an inflatable double-floor provides protection from inclement weather and hypothermia. Retro-reflective tape and a light on the canopy increases visibility for night vision rescues. For enhanced stability the Offshore Ocean contains four oversized ballast pockets one at each corner. For enhanced stability the Offshore Ocean contains four oversized weighted ballast pockets, one at each corner. For boarding ease, the ladder is weighted.

Revere Survival Products offers a 12-Year limited warranty for the Offshore Ocean (if inspected in accordance with the owner's manual.)
Here is a 4 man raft for $2000.00 bucks. Samll case and stowable. Emergency Pack Contents

• 3 Red SOLAS Hand Flares
• 2 Red SOLAS Parachute Flares
• Bailer
• Repair kit
• 2 Sponges
• Floating anchor
• First-Aid-Kit
• Whistle
• Seasick tablets
• 2 paddles
• Floating knife
• Survival manual
• Rescue quoit



Add an ERIB $800.00 more and every one is gonna have to fork out around $3000 bucks to fish.
After checking all of the USCG rules I can get hold of, these two items are "RECOMMENDATIONS" for small recreational offshore boaters and are not rule. We do not fit in the commercial criterias. Therefore , we do not have to carry.
But, as far as saftey goes, I wish I had the money to buy and carry. But that's why we go out with buddy boats to fish.
Thanks to the USCG guys for checking into this, I think it is very important we clarify and keep everyone safe.

[USCGBoating]

Originally Posted by Aqua-Holic

Thanks for the reply Jack. My point is, that this thread appears to be calling for a new and different interpretation of an existing regulation.
That being the case, not only would we be required to carry a liferaft beyond 20nm but also one that is CG approved and recommended for such use by the manufacturer, thus putting that unit in the price range stated above.
As to an "IBA", does anyone have an example of one, other than a "liferaft", which would be CG approved and recommened by the manufacturer for use beyond 20nm?

An IBA is a Inflatable Buoyant Device. This the same type of raft you see on airlines. They are a raft without a cover, looks just like a kids inflatable pool.

Dan