160.002, 160.003, 160.004, 160.005, 160.053, 160.055, 160.077, 160.155 (SOLAS), 160.176 (SOLAS)
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 a USCG Recognized Laboratory. 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 Inspection.
After type-approval all production of approved PFDs is overseen by the recognized laboratory, as follows:
Follow-up Inspection 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 applicable.
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.
Manufacturer's Responsibility: 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 approval documents.
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 product.
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)."
Please 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 foam parts.
* 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 USCG subparts.
* The length, adjustment, rigging, and tolerances on the various straps.
* Ring buoy: weight, density, and respective tolerances.
* The method of construction of all structural and useful parts.
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).