Update on Life Jacket Standards and Test Laboratory Recognition US COAST GUARD Office of Design and Engineering Standards Lifesaving and Fire Safety Division (CG-5214) Marty Jackson

Topics Resolution Number 2009-83-01 Laboratory Recognition Update Youth Inflatable PFD Update

Resolution Number 2009-83-01 requested the Coast Guard – 1. Establish a Workgroup to: a. Transition to a new consolidated NA Standard. b. Separate the standards development from test labs. c. Create a new process for certification and testing to ensure the continued safety of life jackets while providing enhanced opportunities for innovation, affordability, wearability, and use by May 30, 2010.

Resolution Number 2009-83-01 2. Flexibility in Recognized Lab Qualification a. More choices for initial and follow-up Testing. b. Facilitation of innovative products through testing to market and enable competitive pricing for product lifecycle by May 30, 2011.

Resolution Number 2009-83-01 3. Modernize compliance and quality control processes to be more cost-effective and efficient by May 30, 2012. The Coast Guard should also consider the used of industry certification or ISO 9000 as an accepted quality control process.

Consolidated North American Standard Drafting Group for Canadian/US Standard 5 members (USCG, labs, mfrs) Adopt ISO 12402 Std for PFDs Includes National Deviations document Incorporates Risk-index performance assessment Permit reduced buoyancy for Type III PFDs with equivalent performance. March 2012 target on track

Current UL Standards UL-ANSI accredited collaborative standards development considered fully independent from UL testing and certification. UL 1123 Standards Technical Panel (STP)– 22 members representing the industry, public, government (both federal and state) and includes Transport Canada. UL has only one vote on the STP as a recognized lab. Coast Guard has 2 votes Members vote independently on revisions to standards, with opportunity for comments and modifications on line. NBSAC may participate directly in STP- contact Chairperson, Ms. Sarah Brooks for information, Email:_Sarah.A.Brooks@us.ul.com Phone: 919-549-1894  

- USCG and UL cooperate to test innovative products. 1c. Create a new process for certification and testing to ensure the continued safety of life jackets while providing enhanced opportunities for innovation, affordability, wearability, and use by May 30, 2010. - USCG and UL cooperate to test innovative products. - UL's “New and Unusual Testing Program” - All recognized test labs would be expected to consider innovative products similarly. - Risk-based standards may be more flexible to consider alternative designs.

USCG Letter of Intent December 8, 2009 USCG letter to PFDMA Recognizes mutual goals and efforts of PFDMA, UL and ABYC to: Continue transition to Consolidated North American Standard with ISO 12402 base Re-evaluate Classification and Labeling Use Risk-based compliance model for PFDs

Alternative Standards The Coast Guard will support industry efforts to consider alternative standards development provided that results include ANSI-accredited process Industry consensus standards for PFDs Any change in the SDO must be done in accordance with established ANSI guidelines SDO is capable of quickly responding to issues with an STP like process that includes appropriate stakeholders.

New Recognized Labs We are considering 2 test labs –     We are considering 2 test labs – While test procedures have been verified, detailed listing/labeling, and follow-up programs must be demonstrated and documented Possible for late 2010 addition  

Modernize 3. Modernize compliance and quality control processes to be more cost-effective and efficient by May 30, 2012. The Coast Guard should also consider the use of industry certification or ISO 9000 as an accepted quality control process.

Modernize Revised Fabric Flammability Test requirements Removed the Annual PFD Swim Test Currently reviewing standard manufacturing Q/A follow-up procedures reaffirm what tests are absolutely required eliminate unnecessary tests with little value in the process and few processes systematic review process.

Modernize PFDMA-led working group consisting of: - PFD Mfr - Component Mfr - UL - USCG First phase: Review/revise UL's current follow-up appendix pages - Improve efficiency - Minimize unnecessary testing - Incorporate in-line testing where possible/appropriate

Modernize Next phase: Develop a 'quality-based' procedure Considering a 'tiered' approach in which - Manufacturers would be classified by history of compliance - Test/inspection/audit requirements would vary by classification This program will take much more work to complete and validate Independent follow-up is a requirement for USCG approval

Youth Inflatables Progress Study by ASE completed Nov 2009 Endorsed 12 yr old + Adult non-swimmer use Considering regulatory change options to address “use by adults only” in CFR UL 1180 Standards Changes Accepted Changes to labels and instructions for repacking and rearming Initial approvals based on existing designs

Questions Marty Jackson Lifesaving and Fire Safety Division (CG-5214) Phone: 202-372-1391 Email: Martin.L.Jackson@uscg.mil

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STP 1123 Roster Covers UL Stds: 1123, 1175, 1177, 1180, 1185, 1191, 1197, 1517 Name Company Interest Category SUSAN BALISTRERI BALISTRERI CONSULTING INC Producer C BROOKS SURVIVAL SYSTEMS LTD Non voting member Sarah A. Brooks Underwriters Laboratories Inc. Chair DENNIS CAMPBELL KENT SPORTING GOODS CO INC Producer W COURTNEY WATER SAFETY & SURVIVAL General SAM FOWLKES AMERICAN CANOE ASSOCIATION General CHUCK HAWLEY WEST MARINE INC Supply Chain GORDON HICKS HALKEY-ROBERTS CORP Producer MARTIN JACKSON U S COAST GUARD Government Christopher James Underwriters Laboratories Inc. Testing & Stds Org L LARSON USA WATER SKI General R MARKLE MARKLE MARINE SAFETY SERVICES General Betty C. Mckay Underwriters Laboratories Inc. Project Manager LARRY MEDDOCK WATER SPORTS INDUSTRY ASSOC.General LOUIS NOVAK U S COAST GUARD Government KENNETH PLOURDE INTER-PAC INC Producer ROBERT POPE Consumer FRED (SLIM) RAY General ROBERT RIPPY THE COLEMAN COMPANY INC Producer T ROGERS CITY OF CHARLOTTE Commercial-Ind. User RAVI SHANKAR TRANSPORT CANADA Government DOROTHY TAKASHINA TAKASHINA LIFE PRESERVERS CO LTD, DBA JAPAN Producer SARAH TAYLOR BROWN VIRGINIA TECH & EDDIE BAUER General David Toshack Underwriters Laboratories Inc. (Canada) Non voting Member SAMUEL WEHR MUSTANG SURVIVAL Producer