Frequently Asked Questions


In order to best serve our customers, we have compiled a list of answers to frequently asked questions. The guidance in these FAQs are not a substitute for applicable legal requirements and are not intended to impose legally-binding requirements on any party. If you want to discuss any topic with the Lifesaving and Fire Safety Division (CG-ENG-4), you may contact us at


 What is the general approval process for lifesaving appliances?
The first step in every approval (or modification to an existing approval) is the pre-approval design review. Several of the accepted independent labs have the authority to perform this review on our behalf, with pre-approval from our office. If you chose this option, we will work with you and the selected lab to ensure that everyone agrees to the correct process before you begin.

Once the design review is complete and we have accepted the results, prototype testing is typically scheduled with the nearest Coast Guard inspection office in coordination with our office. All prototype testing must be witnessed by a USCG inspector with very limited exceptions. We require prototype testing even if you have made the same model previously for other Administrations. We may also require a new prototype test for modifications to a USCG approved product if we determine that the proposed modifications warrant repeating the test. For example, an increase in safe working load, change in materials for load-bearing parts, etc, would typically require repeated prototype testing.

After satisfactory prototype testing, you must submit the completed test forms, and any other remaining items from the design review phase, to our office for final approval. At this point we will provide an approval certificate.

All production testing for subsequent units must be witnessed by an independent lab. You must identify this lab in advance, and the lab you select will be listed on the approval certificate. Please note that when you search for an independent lab at, you must include the 'approval series' in your search. For example, the approval series for winches is '160.115'.

The lab may have additional requirements before agreeing to take on production testing for your winches. For example, they may want to do plan review to their own (or IACS) standards, attend prototype testing and/or issue their own approvals. We recommend that you discuss this with the lab you select before proceeding with the approval process.
 What does the validity period mean on an equivalency letter issued under the USCG/NMD agreement?
The product has been determined to be equivalent to current USCG requirements and is accepted for installation during the validity period listed on the acceptance letter issued by CG-ENG-4.
 Is the "propeller stamp" required on the permanent marking plate for lifesaving equipment?
No. The "propeller stamp" also known as the Coast Guard symbol is only required for certain inspection activities under 46 CFR Subchapter F: boilers, safety valves, etc.. See 46§50.10-25.
 Facts about Certificates of Approval (COAs)

Certificates of Approval are regulated under: 46 CFR 2.75 and 159

Purpose of the COA:

  • The COA indicates the Coast Guard has performed its regulatory role to ensure certain equipment has met the minimum design and performance requirements to be carried on US vessels; AND
  • Allows a manufacturer to fabricate a product for a specified time period under the conditions stipulated by the COA for the purposes of producing it as USCG approved.

COAs are issued to:

An original equipment manufacturer (OEM).  Unlike a vessel’s Certificate of Inspection, the COA is not issued for a single specific piece of equipment, but covers products being fabricated under the conditions of the COA, which could be thousands of the same product. This is an important distinction when considering the validity period of the COA with respect to the equipment on board.

COAs are ONLY issued to products where there is a specific regulatory requirement for a vessel to carry such products.  Many people develop products that might offer capabilities to the vessel and its crew similar to required equipment. If the product does not meet the defined requirements for a product that must be carried on board, it will not receive a COA.  This does not preclude these innovative products from being carried, but it cannot replace a product that must be carried.

COAs are currently only issued by:

Certain CGHQ units identified in the regulations currently issue COAs, e.g., Commandant CG‑ENG‑3, CG-ENG-4 and the Marine Safety Center.

Period of validity:

Typically 5 years, unless canceled or suspended by proper authority (e.g. the HQ office that issued the COA) or otherwise specifically stated in the certificate. Only in very few cases will a COA be issued for more or less than 5 years.

The COA Number:

  • Each COA has an approval number in the format: approval series/sequential number/mod number. 
  • In most cases, this number is to be permanently affixed to the approved product and/or packaging.
  • For products that are re-issued subsequent COAs after the initial 5-year validity, the approval number may not change, unless there has been an increment to the mod number.
  • Unfortunately, CGMIX does not display earlier versions of a COA, only the most recent. This is the current version for valid COAs or the last version for COAs that are expired, former-may-use, or former do-not use (see below Categories, for these definitions).
  • It is important to note that owners of approved equipment should have a copy of the COA that was issued during the validity period encompassing the production date of their equipment and this might be a different version of the equipment’s COA than what is found on CGMIX.

Equipment approvals covered by a Mutual Recognition Agreement:

  • Certain equipment may be approved by another party under a Mutual Recognition Agreement (“MRA”) and still meet carriage requirements. See NVIC 02-19.
  • The majority of these are approved under the US/EC MRA and marked with a USCG approval number by the “Notified Body” (see NVIC 02-19), but are still not issued a COA. The format of the approval number is slightly different than a USCG issued one. It will be in form: approval series/Notified Body number/unique identifying number for that product.
  • Equipment with a USCG approval issued by a European Notified Body (NB) under the EC/US MRA can be found on and visiting the MARED database. Note: CGMIX does not presently have information on USCG approvals issued by a NB under the US/EC MRA.
  • CGMIX however does currently have information on equipment approved by the USCG eligible for reciprocal approval under the EC/US MRA. These products will have the “wheel mark” shown in CGMIX and on their COA.

Other parties involved in the USCG approval process:

Independent labs are authorized to conduct a variety of functions defined in applicable regulations on behalf of the USCG, but not authorized to issue the COA. See 46 CFR 159 regarding independent laboratories and

If the COA expires and it is not renewed:

  • the Manufacturer of record listed on the COA may no longer produce, mark, and sell the equipment as USCG approved; however-
  • Equipment sold or produced during the validity period remains acceptable for service to meet carriage requirements as long as it is in good and serviceable condition and current regulations applicable to the vessel do not require something different or require equipment meeting a new standard.

Categories of COAs you will see in CGMIX (

Approved: The COA is valid and the product meets current requirements and is approved for production and sale under the conditions outlined on the COA.

Expired: The validity period of the COA has ended and the manufacturer of record must stop producing the equipment and marketing newly produced items as Coast Guard approved. This status should be resolved by the OEM either by informing the Coast Guard that they desire to have the COA extended for another 5 years, or inform the Coast Guard that the equipment is no longer intended to be produced and sold as USCG approved.

Former may use: the equipment or product is no longer approved for production but equipment purchased and installed, or products that were produced during the validity period of a previously approved COA, may remain in service as long as it remains in good and serviceable condition even though the COA under which it was manufactured is no longer valid.  

This category may also be used for listing certain equipment that is manufacturer certified, but not formally approved with an issued COA. 

Former may not use: the equipment is no longer approved for production and previously produced items may not be used or remain in service. This status is used for products which are: obsolete (the regulations governing their design and performance have changed) or may present a safety hazard if they are used or remain in service.


 Why can't I get my product approved by the Coast Guard?

We approve products ONLY where there is a specific regulatory requirement for a vessel to carry such products. For example, when a small passenger vessel certificated under Subchapter T is required to carry a ring life buoy, that product must meet the design requirements and be approved under series 160.050 (see 46 CFR Subpart 180.70). 

Many people develop products that might offer capabilities to the vessel and its crew similar to required equipment. If the product does not meet the defined requirements for a product that must be carried on board, it will not receive Coast Guard approval.  This does not preclude these innovative products from being carried, but it cannot replace a product that must be carried.

The Coast Guard does not endorse any products, whether they are approved or not.


 What are the maintenance/repair/replacement requirements for immersion suits?
There is a wide variation of manufacturer recommendations on how and when to inspect, service and replace immersion suits. There is also a wide range of immersion suit conditions found in the field due to the numerous different materials and exposure factors that are largely unknown to the Coast Guard inspector when looking at a suit.

The bottom line is suits must be "in good working order." The governing guidance in NVIC 01-08, SHIPBOARD INSPECTION AND TESTING OF IMMERSION SUITS, helps in identifying critical factors in the verification and inspection of immersion suits for that operational readiness.

Similar to a lifejacket, immersion suits should be physically examined by the inspector to gain an initial evaluation of whether they seem to be "in good working order." If there is some indication during that examination to question the condition and integrity of the suit, the inspector should request to see additional evidence of inspection/test documentation per the NVIC and/or manufacturer's guidelines. If none is available, the operator should have the suit tested/inspected, or otherwise demonstrate the suit's acceptability. Actually having it donned can verify a number of user/device fit and operability issues.

Consider the inspection and servicing requirements in 46 CFR 28.140(h) whereby immersion suits "must be maintained and inspected in accordance with: (1) Table 28.140 (2) ...immersion suits. - Annually "Inspect, clean and repair as necessary"; (2) "The servicing procedure under the subpart of this chapter applicable to the item's approval;" and (3) The manufacturer's guidelines. The highest priority item is (1) , and means the owner/user should personally examine the suit out of the storage bag and exercise the zipper, straps, components, and fittings (in accordance with the manufacturer's instructions for inspection).

Since the Coast Guard does not formally certify servicing facilities for immersion suits, sending the suit back to the manufacturer, or to a manufacturer certified facility would be ideal. Otherwise, a facility that services wetsuits for example might be acceptable and the OCMI should consider this option if presented. In either case, documentation of the tests and procedures to manufacturer recommendations would provide a basis for acceptance.

The manufacturers' typical recommended intervals for servicing vary from every 2-5 years from the date of manufacture; then get further apart after 5 years to either annual or 2 year servicing; to annual servicing after 10 years. It should be expected that the suit condition can be expected to be less than ideal after 10 years. That is the basis of justification for an annual servicing for old suits. Potentially a suit that is 15-20 years or older in service, may very likely need replacement. While we have no authority to reject a suit solely on the basis of age, we advise that suits can lose buoyancy and strength over time such that a suit of advanced age is likely not to be effective when needed most.

For testing and servicing, NVIC 01-08 is guidance (i.e., non-regulatory), but provides additional means for gauging immersion suit servicing intervals. Further, the manufacturer may make recommendations, but that does not automatically create a requirement for the Coast Guard to require or enforce under 46 CFR 28.140(b)(3). Unless a specific problem is identified that indicates servicing by a qualified facility, those recommendations could be considered excessive. Hence the records of the owner and the USCG inspector's evaluation of the complete picture becomes a critical part of the determination that the suit is "in good working order."

Per the recommendation in the NVIC for suits 10 years old or older, an air test may be warranted at an interval less than 3 years with consideration of the manufacturer's recommended interval and with an inspection per enclosure (1). If the inspection yields some suspect areas, an air test would be indicated per enclosure (2) to confirm the integrity of the suit. The low pressure air test may be performed by a wetsuit servicing place, or the vessel's crew if they have sufficient skill, plugs, LP gage, and tools (more likely on a larger vessel). If a problem is confirmed, then the suit should be removed from service until it is repaired by a "suitable repair station" and recertified "in good working order."
 Frequently asked questions about IMO Resolution MSC.402(96) and NVIC 03-19


Q1: What is the significance of MSC Resolutions 402(96) and 404(96), and NVIC 03-19?

A1: Resolution MSC.404(96) amended SOLAS Chapter III to incorporate requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear, adopted by the Maritime Safety Committee by resolution MSC.402(96). NVIC 03-19 was published to provide the U.S. Coast Guard’s recommendations with complying with the amendments to SOLAS III and resolution MSC.402(96). These resolutions apply to vessels subject to SOLAS, including those vessels enrolled in the Alternate Compliance Program (ACP) and/or the Maritime Security Program. For those vessels that are not subject to the requirements of SOLAS, the United States Coast Guard (USCG) recommends they also follow the guidance in NVIC 03-19 when servicing their lifesaving equipment. (See paragraph 5 of NVIC 03-19).

Q2: What do these Resolutions and NVIC update or replace?

A2: MSC.402(96) replaces MSC.1/Circ.1206/Rev.1 and MSC.1/Circ.1277. NVIC 03-19 cancels and replaces NVIC 04-07.

Q3: Who is the intended audience of NVIC 03-19?

A3: US Flag Vessel owners and operators, USCG marine inspectors, class societies authorized under USCG’s ACP, lifesaving equipment manufacturers, servicing and repair facilities, and associated personnel.

Q4: Do these Requirements apply to fixed or floating platforms?

A4: MSC.402(96) and NVIC 03-19 are not required for fixed/floating platforms, however, the USCG recommends that all vessels and platforms that have equipment holding approval under series 160.115, 160.132, 160.133, 160.135, 160.156, and 160.170 conduct the maintenance outlined in MSC.402(96) according to the guidance in NVIC 03-19.

Q5: How does the USCG define “make” and “type”?

A5: The USCG definitions of make and type are outlined in Enclosure 3 of NVIC 03-19. The USCG considers the “make” to refer to the equipment manufacturer. The USCG considers the “type” to refer to the US Coast Guard approval series for the equipment, e.g., 160.135. An Authorized Service Provider (ASP) authorized to work on a type of LSA is therefore authorized to work on any equipment under that approval series. See also Q&A in the section below on “AUTHORIZED SERVICE PROVIDERS”.

Q6: How do I provide feedback to USCG about their implementation?

A6: In order to provide supporting documentation for future discussions concerning the application of IMO Resolution MSC.402(96), you are encouraged to inform the Commandant (CG-ENG-4) of any practical problems encountered in the implementation of its provisions, particularly with regard to availability of Authorized Service Providers. (see paragraph 6.f. of NVIC 03-19). This feedback should be submitted to


Q7: How do I find an Authorized Service Provider for my vessel?

A7: According to paragraph 6.c(5) of NVIC 03-19, Authorized Class Societies (ACS) should maintain a list of authorized service providers that is available to vessel owners and operators. You will need to individually check the class society websites for these lists. The USCG maintains a list of ACS on the Flag State Control Division website at

Q8: I am a US Flag vessel owner/operator and cannot find a USCG ASP in my area for my required maintenance/servicing/overhaul. How do I remain compliant?

A8: Issues involving the unavailability of an equipment manufacturer or ASP will be handled on a caseby-case basis. If the original equipment manufacturer is unavailable and there is no ASP available to conduct the required servicing or testing, the vessel owner or operator should contact Commandant (CG-ENG-4), Lifesaving and Fire Safety Division at (see also paragraph 6.e(3)(c) of NVIC 03-19).

Q9: The Original Equipment Manufacturer (OEM) of my equipment is no longer in business or providing technical support for my equipment. How will I find an ASP?

A9: The ACS may authorize service providers for USCG equipment on the basis of prior authorization for the equipment and/or long-term experience and demonstrated expertise as an authorized service provider.


Q10: Who can be an ASP?

A10: “Authorized service provider means an entity authorized by the Administration in accordance with section 3 and section 7” (MSC.402(96)). Per NVIC 03-19, this function is performed by Authorized Class Societies (ACS) according to 46 CFR 8.420. MSC.402(96) Section 7.1 outlines everything that IMO requires must be taken into account for authorizing service providers. A service provider may be either an original equipment manufacturer or a third party service provider. Components of lifeboat and launching systems are generally of common and conventional designs for which service and repair do not necessarily require manufacturer-specific expertise.

Q11: Do third party servicers need to be authorized by the OEM to work on their particular equipment?

A11: Unlike with USCG-approved liferaft servicing facilities that require both authorization by the original equipment manufacturer (OEM) and the OCMI, service providers for the LSA in the referenced SOLAS amendments are authorized entirely by Administrations; in the US, that is the USCG.

Q12: I am a third party service provider. I have been authorized by RO #1, RO #2, and RO #3 in accordance with IMO Res. MSC 402(96). However, RO #4 is requiring me to be certified by the OEM. May I service USCG approved equipment on US flag ships?

A12: If any of the ROs (#1, #2, or #3) are ACS according to 46 CFR 8.420, or have otherwise been permitted to authorize service providers for USCG approved LSA, then you are an authorized service provider for USCG approved LSA, and may service any USCG approved LSA within the scope of your authorization. It is not necessary to be authorized by multiple ACS recognized by the USCG.

Q13: What if my customers are classed by a different ACS than the ACS that authorized me as an ASP?

A13: The US Coast Guard has no control over the requirements that a class society invokes as a condition of class. However, authorization of LSA service providers is a function of the Administration. While the function is performed by an ACS, who also happens to be a classification society, there is no regulatory requirement for a US flag vessel to have their LSA serviced by a service provider authorized by the same ACS that serves as that vessel’s class society.

Q14: ISO PAS 23678, Parts 1-4 have been published. Are authorized service providers required to comply with this ISO PAS series?

A14: ISO/PAS 23678 (series) is an international voluntary consensus specification that ASPs may use to train and certify personnel while working towards compliance with the Requirements. While ACSs and ASPs may find it useful in ensuring that servicing technicians achieve the necessary competencies, it is not mandatory.

Q15: I don’t agree with a decision the ACS made when evaluating me as an ASP. How do I appeal this?

A15: The USCG appeals process is outlined in 46 CFR 1.03. Note that requests for appeals must be made within 30 days after the ACS decision is rendered or the action is taken. (46 CFR 1.03-15).


Q16: What are the ACS looking for in order to authorize service providers? A16: At a minimum, an ASP training program recognized by national, international or industry standard; competent individuals trained and experienced as ASP to service the particular manufacturer’s release mechanisms and lifeboats; access to latest maintenance manuals, service bulletins and alerts; necessary tools to service; and a certified quality system. The ASP should be able to perform the required service in Resolution MSC.402(96) to maintain the equipment in its as-approved condition.


Q17: I am an OEM and think that my equipment is so unique that our individual approved models require specific competencies above and beyond those being verified by USCG ACS. How do I communicate this to the USCG?

A17: Where a lifesaving appliance manufacturer believes that a particular model requires certified servicing personnel to have additional competencies, those competencies should be identified during the equipment approval process and will be listed on the USCG Certificate of Approval for that model. (see paragraph 6.d(4) of NVIC 03-19). OEMs must submit their reasoning and data including engineering designs and manuals so that CG-ENG-4 can make a determination of whether or not to modify the COA. To demonstrate special characteristics, the OEM’s reasoning should include a comparison between the model under consideration and the other USCG approved models manufactured by the OEM. Submissions should be sent to

Survival Craft FAQs

 What is the phase-out period for Life Floats and Rigid Buoyant Apparatus?
There have been many recent changes regarding the approval of rigid buoyant apparatus and life floats. In accordance with the Coast Guard Authorization Act of 2015 (P.L. 114-120), the Coast Guard will continue to approve rigid buoyant apparatus and life floats. For more information, see our letter dated February 12, 2016.

SOLAS Lifeboats and Rescue Boat FAQ's

 Are running lights, (a.k.a. navigation lights or red and green side lights) required on SOLAS lifeboats and rescue boats?
Yes. There is no specific exemption for motorized survival craft in the COLREGS or SOLAS. Modern USCG approved lifeboats and rescue boats are power-driven vessels capable of getting underway as transportation on the water, therefore they must meet the requirements of the COLREGS.

The International part of Regulation 23 states, "a power-driven vessel of less than 7 meters in length whose maximum speed does not exceed 7 knots may in lieu of the lights prescribed in paragraph (a) of this Rule exhibit an all-round white light and shall, if practicable, also exhibit sidelights."

Therefore, only lifeboats and rescue boats that are under 7 meters in length and operating at speeds less than 7 knots may display an all-around white light. Otherwise, the red and green side lights are required.
 Can my lifeboat be approved for more than one release mechanism?
Yes. CG-ENG-4, when practicable, will list all approved release mechanisms (approval series 160.133 and/or 160.170) on the lifeboat or rescue boat’s approval certificate.
 Can my lifeboat be approved for more than one seating plan and/or occupancy weight?
Yes. CG-ENG-4, when practicable, will list all seating/occupancy weight combinations on the approval certificate. Ideally, the manufacturer will submit all seating plan/occupant weight variations at the time of initial approval. Seating plans/occupant weights can also be requested for modification after approval has been issued. OEMs and/or operators should submit a request to CG-ENG-4 will discuss with the submitter any required testing. If the seating/occupant weight is modified, it will be amended on the approval certificate.
 Can USCG approved SOLAS lifeboats and rescue boats be any color other than international orange?
No. We require vivid reddish orange color number 12197 of FED–STD–595C, or a durable fluorescent color of a similar hue.
 Do I have to use fire-retardant laminates for the entire lifeboat/rescue boat?
Our requirements for fire-retardant resin and laminate apply only to the “hull, canopy, hatches, rigid covers, and enclosures for the engine transmission, and engine accessories”. For other components (primarily the hull liners and canopy linings, seats, etc.) we have no specific requirements. No particular Coast Guard acceptance is required for the materials used for those parts other than evaluation for structural suitability if necessary, and a resin accepted/approved by other bodies would be acceptable.
 How can I waive the fire test for tanker lifeboats?
To waive the test the following must be provided:
  1. 1. Complete report(s) for the boat(s) which was/were tested already;
  2. 2. Details to the construction and materials for the boat(s) tested to demonstrate adequate similarity to the boat for which a waiver is requested. For example: is equivalent water coverage achieved over like materials? Is the boat’s form/shape essentially the same as what was already tested?;
  3. 3. Relationship of the builders of the tested boats to the present company requesting approval, and if appropriate, release of any independent companies to use their data;
  4. 4. Details of the independent person(s) and organization(s) which witnessed the test(s) and signature(s) indicating they witnessed the tests; and
  5. 5. The test report(s) should cover all the points required by the IMO test form (MSC980).
 What are the standards for acceptance of compressed gas cylinders used in lifeboats and rescue boats?
Our regulations for air bottles in USCG approved SOLAS lifeboats is in 46 CFR 160.135-7(b). This site references 46 CFR 147.60. This is the same for any bottles in USCG approved SOLAS rescue boats, for example for self-righting systems.

Ҥ147.60 Compressed gases.
(a) Cylinder requirements. Cylinders used for containing hazardous ships' stores that are compressed gases must be—
     (1) Authorized for the proper shipping name of the gas in accordance with 49 CFR 172.101 and 49 CFR part 173;
     (2) Constructed in accordance with subpart C of 49 CFR part 178 or exempted under 49 CFR part 107;
     (3) Filled, marked, and inspected in accordance with 49 CFR 173.301 through 173.308; and
     (4) Except as provided in 46 CFR 147.65, 147.66, and 147.67, maintained and retested in accordance with 49 CFR 180.
(b) Stowage and care of cylinders.
     (1) Cylinders must always be secured and, when not in use, they must be stowed in a rack in an upright position, with the valve protection cap in place.
     (2) Lockers or housings must be vented to the open air near the top and bottom for positive circulation of vapors.
     (3) Cylinders must be protected from all sources of heat which may cause the cylinders to be heated to a temperature higher than 130 °F.”

See also 49 CFR 180.209 “Requirements for requalification of specification cylinders”, table 1. This will give you the requalification period and minimum test pressure. See also 49 CFR §180.207 Requirements for requalification of UN pressure receptacles, table 1. The U.S. DOT allows UN composite cylinders meeting certain standards for use domestically, therefore they are an option for use in USCG approved lifeboats and rescue boats.
 Do you type approve engines for lifeboats and rescue boats?

No. The USCG does not type approve engines for use in USCG approved lifeboats and rescue boats. Rather, they must be shown to meet the requirements in 46 CFR 160.135-7(b) for lifeboats or 160.156-7(b) for rescue boats.

We maintain a list of accepted engines, available publicly on our website here: However, if you wish to install an engine that is not currently on the list, you should follow the guidance below. 

Regardless of whether an engine is on our current list or not, it is essential that Commandant (CG-ENG-4) has evaluated the engine for compliance with the applicable regulations and documented the result. Engines installed on a USCG approved lifeboat or rescue boat are typically documented on the boat’s Certificate of Approval, or otherwise identified as a modification in a letter from us.  Owners of USCG approved lifeboats and rescue boats should ensure any new engine they wish to install in their boat is approved for the model and approval number of their boat, otherwise it may invalidate the boat’s USCG approval.

The requirements in 46 CFR 160.135-7(b) and §§160.156-7(b) state that any spark ignition engine fitted to an approved rescue boat must meet the U.S. Environmental Protection Agency (EPA) emission requirements in 40 CFR part 91 or part 1045, as applicable, and compression ignition engines in an approved rescue boat or approved lifeboat must meet the requirements in the EPA's 40 CFR part 89, part 94, or part 1042, as applicable.

Both engine types (spark or compression) must also have been shown to pass the tests in IMO Resolution MSC.81(70) Part 1.  We accept reports of these tests containing the same information as shown on the IMO MSC Circ. 980 forms.  The tests must be witnessed by a U.S. Coast Guard inspector or an independent laboratory, and the test forms signed legibly by the attending authority.

The testing should be done with an engine that has met the required EPA requirements, and have all components installed that are needed to pass the IMO tests. The test forms should document this. If not, we may not accept the testing.

If such testing has already occurred and you have the test forms signed by a representative of one of the current accepted independent labs for rescue boats or lifeboats, you may submit those test reports along with the necessary information to demonstrate compliance with US EPA air emission requirements and the engine operations and maintenance manual to

We also ask for plans, specifications or documents describing the components, if any, that must be supplied with, or installed on, the engine to comply with IMO or US EPA requirements.  Those parts must also have been installed during testing as mentioned above.  Any parts or components that are necessary to pass the IMO tests should be documented in the test report.

Alternatively, if testing has not occurred, you many arrange for the USCG to attend testing of the engines to the requirements in MSC.81(70) Part 1.

If you have any further questions you may contact us. See our Contact page.

Fire Protection FAQs

 FTP Code 15-year rule

IMO’s International Code for Application of Fire Test Procedures, 2010 (2010 FTP Code) specifies that a type approval can be renewed by the Administration without retesting provided that the test report is not more than 15 years old.  This applies to approvals issued under the previous version of the FTP Code and the 2010 version.  All retesting is conducted using the test procedures in effect at the time of retesting. 


The intent of the requirement is that an approval should be able to be renewed twice, giving an approval lifetime of 15 years.  This takes into consideration that most test reports are roughly one year old when the approval is issued.


The U.S. Coast Guard bases the age of the test report on the original date of the oldest test report at the expiration of the certificate of approval.  Age is calculated in the same manner as age for voting and buying alcohol and tobacco.  Requests for early renewals to circumvent the 15-year rule will not be honored.


When choosing an independent laboratory for approval tests, applicants should consider the life-cycle cost of the approval testing with the expected 15 years of follow-up service.


Responsibility for identifying the need to retest to avoid a lapse in the approval belongs to the approval holder.  Any advance notification by us is a courtesy.  If in doubt, please contact us.

 Fire Detection FAQs

What are the corresponding US terms for those used in the IMO Fire Safety System Code?

US term

FSS Code Chapter 9


1.2.1    Section means a group of fire detectors and manually operated call points as reported in the indicating unit(s).


Zone system

1.2.2    Section identification capability means a system with the capability of identifying the section in which a detector or manually operated call point has activateda


Addressable system

1.2.3    Individually identifiable means a system with the capability to identify the exact location and type of detector or manually activated call point which has activated, and which can differentiate the signal of that device from all others.




Notes: a – Sometimes referred to as a conventional system, but conventional can also mean using non-analogue devices. There is no definition of conventional device or system in NFPA 72.



What is the difference between a required fire detection system and excess fire detection equipment?

Fire detection systems that are required by regulations to be installed are required.  Fire detection systems that are installed, but not required by regulations to be installed, are excess equipment.  Any initiating device, notification appliances, or other components that are in excess of the regulations, but connected to a required system must meet the requirements for components of a required system.  In other words, if any part of the system is required, the whole system is to be treated as required.  This is to ensure the integrity of the system and to avoid issues in servicing, repairs, and future modifications.

While certain subchapters of the U.S. Code of Federal Regulation (CFR) may require excess fire detection equipment to be approved, NVIC 7-80 permits the use of control panels, devices, and appliances listed for fire service by a national recognized testing laboratory. 

Excess fire detection systems are subject to the plan review, electrical requirements, and configuration requirements as required systems unless specifically exempted by regulation.

For uninspected vessels regulated under 46 CFR Subchapter C, the above applies only to towing vessels and commercial fishing vessels.  There is no discussion of fire detection equipment for the other uninspected vessels such as recreational vessels.  Any fire detection equipment on those vessels is excess equipment and there are no USCG requirements on that equipment.


What are the approval requirements for initiating devices of supervisory signals?

46 CFR 76.27-10(i) permits signals from other safety systems to be sent to the fire detection system.  These can be from such items as a flow alarm from the sprinkler system or water main. 


What about single-station smoke alarms?

These are smoke detectors not intended to be connected to a fire detection control panel. Regardless if required equipment or excess equipment, these detectors must be listed as meeting UL 217, which is the standard for house-hold smoke detectors. There is a more severe RV category under UL 217 for Recreational Vehicles (RV) which includes testing for resistance to high humidity, temperature extremes, and salt-spray.   These detectors will be labeled “Single Station Smoke Detector—Also suitable for use in Recreational Vehicles.”  Detectors for commercial fishing vessels and small passenger vessels regulated under Subchapter T of 46 CFR must include the RV label.  The regulations for towing vessels only require the detectors to be meet UL 217 without the additional RV endorsement. 


How do I get type approval for the detection system installed on my vessel?

Type approval requires the items to be subject to destructive testing which renders them useless thereafter.  It is not cost-effective to get type approval of an installed system unless the manufacturer of the system is willing to seek type approval.  Perhaps the discussion on excess equipment will resolve your issue.