Cancellation of CVC Policy Letter 15-05: Requirements for Out-of-Water Survival Craft

On February 8, 2016, the President signed H.R. Bill 4188, the “Coast Guard Authorization Act of 2015” into law. In it, section 301 amended the out-of-water survival craft requirements in Title 46 United States Code (U.S.C.) §3104, limiting its applicability. This Marine Safety Information Bulletin (MSIB) notifies the public of these changes and hereby cancels the now obsolete CVC Policy Letter 15-05, which concerned previous out-of-water survival craft requirements.

Section 301 of the 2015 Coast Guard Authorization Act (CGAA) had two significant effects on the applicability of out-of-water survival craft. First, it amended 46 U.S.C. §3104, paragraph (a), requiring that only “passenger vessels” that operate in cold waters and are built or undergo a major conversion after January 1, 2016 shall be equipped with out-of-water survival craft. "Passenger vessel" is defined in 46 U.S.C. §2101(22) as a vessel of at least 100 gross tons (among other criteria). Currently, Title 46 Code of Federal Regulations (CFR), Subchapter H - Passenger Vessels and 46 CFR, Subchapter W - Lifesaving Appliances and Arrangements dictates the survival craft requirements for passenger vessels of at least 100 gross tons. The lowest category of survival craft authorized in Subchapter W is the Inflatable Buoyant Apparatus (IBAs), with which, no part of an individual is immersed in water. Therefore, passenger vessels properly in compliance with Subchapters H and W already meet the out-of-water survival craft requirements directed in the amended 46 U.S.C. §3104.

Second, the 2015 CGAA removed the language in the previous amendment of 46 U.S.C. §3104 that restricted the Coast Guard from approving any in-water survival craft (e.g., life floats and buoyant apparatus) for the purposes of all of Part B of Title 46 U.S.C. Therefore, because the other inspected vessels (small passenger vessels, offshore supply vessels, sailing school vessels, and cargo vessels as mentioned in the CVC Policy Letter 15-05) were not specifically named in the 2015 CGAA, they may continue to use their existing in-water survival craft beyond February 26, 2016. Furthermore, all fixed manned offshore platforms may continue to use in-water survival craft beyond February 26, 2016, as well. The Coast Guard will be issuing separate correspondence to survival craft manufactures re-authorizing or extending their type approval certificates for in-water survival craft. Lastly, a separate information bulletin will be issued explaining the survival craft requirements specifically for uninspected commercial fishing vessels.

Again, as a result of the 2015 CGAA, CVC Policy Letter 15-05 is rendered obsolete and the Coast Guard is cancelling it effective immediately. The Coast Guard stands ready to answer the questions of vessel and offshore platform owners and operators regarding their specific survival craft requirements.

Questions concerning this matter may be directed to the Office of Commercial Vessel Compliance, Commandant (CG-CVC) at 202-372-1220, or at This email address is being protected from spambots. You need JavaScript enabled to view it.. Questions specifically concerning survival craft type approvals should be directed to the Office of Design and Engineering Standards, Commandant (CG-ENG) at This email address is being protected from spambots. You need JavaScript enabled to view it..

 

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