Development of Harmonized “North American” Life Jacket Standards Brandi Baldwin Lifesaving & Fire Safety Divison Office of Design & Engineering Standards

Resolution 2009-83-1 Regulatory Progress Standards Development Progress Provisional Timelines PFD Label Reform Questions

Regulatory Process Notice of Proposed Rulemaking (NPRM) What we want to do What impact we think it will have Public comment period Resolution of comments Final Rule (FR) Must address all comments Logical outgrowth/sufficient notice

Regulatory Progress Aug/2013: NPRM to remove Type Codes Next steps: Comment deadline: 15-Oct Final Rule “imminent” Next steps: NPRM to adopt new and revised industry standards…Public comment period…Final rule Standards must be published first 2-5 years from publication of new standards to final rule

Standards Process The Consensus Process Proposal development – TG or individual Preliminary Review (comments only) Resolution of Comments Balloting for consensus 50% votes returned, 2/3 of those positive Resolution of Comments & “No” votes Recirculation Consensus is slow and iterative

Standards Under Development Harmonized standard (UL 12402) Reorganization of Task Group Withdraw previous proposal New Prelim anticipated after PFDMA Tentative publication – early 2015 Label Reform (UL 1123, 1180, 12402) 1123 (inherent) proposal gained consensus 1180 (inflatable) comments under review 12402 (harmonized) proposal review by TG

Standards Under Development Think Safe Reform Merge with Wise Choice  “Safe Choice” Magic decoder for new label format Proposal stage – Prelim after PFDMA Follow-Up standards (UL 9595) Resolving comments from Prelim Entering ballot after PFDMA Throwables TG proposal stage

Standards Development Bi-National Standards CAN/ANSI/UL 12402 CAN/ANSI/UL 9595 CAN/ANSI/UL 1180 Task Groups formed/expanded Canadian stakeholders More non-industry voices TGs meeting at PFDMA (June 11)

Provisional Timeline Spring 2015? Mid-late 2015 Standards get published USCG initiates regulatory action USCG can approve any PFDs that are currently approvable, using the new standard. Labels will change on all new product Mid-late 2015 PFDs with new labels available on the market

Provisional Timeline (cont’d) “2018ish” USCG can approve “new” PFDs Youth inflatables (age 16 and over) Level 50 inherent (15 lb minimum buoyancy) Level 50&70 inflatables (33 lb minimum buoyancy) 2025…or later PFD with old labels become non-serviceable

Where can I use it? The icons denote the area where the lifejacket is appropriate. The numbers are the tie to the ISO (international) standard. Do they add confusion? Enough confusion to sacrifice this element of harmonization with European (CE marked) devices? Calm water, rescue close at hand Near shore Off-shore

How much does it float? Do the numbers printed below the arrows add clarity or confusion?   What about device which are not currently available? (eg Level 275) Uninflated performance for hybrids & inflatables Different devices have a different amount of buoyancy. The expanding arrows are intended to demonstrate the relative comparison from one device to the next. Do the numbers printed below the arrows add clarity or confusion?   In the early phases of this transition, only certain Levels will be available. Is there a concern about having the other arrows represented? In the long term, we will likely have all of them represented.

Does it Turn? Which graphic do you prefer? Are the words helpful or confusing?

Activities PWCs & Towed Sports The approval for PWCs and towed sports will always come together (either all yes or all no). Should we use both, or develop a single icon that denotes all activities?   Which devices should have the icon? Only where PWC/tow is prohibited, Only where PWC/tow is allowed, All should indicate if PWC/tow is allowed or prohibited.

Activities – Other Inflatables: not approved for ‘whitewater paddling’ Develop an icon? Which ones get marked? Allowed, Not Allowed, or All?   Intended uses Perception of legality vs appropriateness Optional labels/icons Should they be ‘standardized?’ Who develops/maintains them? Enforcement implications? The only other place where USCG (or TC) regulations, and the associated standards, include specific limitations on activities is the prohibition to use inflatables for ‘whitewater paddling.’ Would you recommend that we adopt an icon (which would be on all inflatables) to denote this?   In early iterations, we discussed using icons for all ‘intended uses.’ However, this created the perception that there creates an implication of legality, rather than appropriateness. As an alternative, the standard allows any additional labels that do not conflict with the required markings. Would you support a ‘standardized’ set of icons for optional markings? How would you envision educating boaters and enforcement that those icons do not indicate legality?

Anything else? This is pretty much “last call” Once the standard is approved, manufacturers will start redesigning existing labels. We do not want to make this transition more than once. Volunteers are welcome on all TGs