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 typeapproval@uscg.mil.
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 http://cgmix.uscg.mil/EQLabs/, 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.
The product meets current requirements and is approved for production under Coast Guard approval. Please see the definitions page of CGMIX.
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.
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.
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."

Survival Craft FAQ's

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

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.
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.
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 typeapproval@uscg.mil. 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.
No. We require vivid reddish orange color number 12197 of FED–STD–595C, or a durable fluorescent color of a similar hue.
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.
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).
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.

Structural Fire Protection

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.

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