Lifesaving Requirements for Charter Boats: What's New?
New regulations taking effect March 11, 2001.

The new 46 CFR Subchapter K and revised Subchapter T were published January 10, 1996.

  • Effective date for new vessels in domestic service was March 11, 1996
    • New vessels are generally those whose construction began after March 11, 1996.
  • Existing vessels must comply with the new survival craft requirements by the later of:
    • March 11, 2001 or
    • 10 years after the vessel's keel was laid.

The old regulations were based exclusively on buoyant apparatus and life floats as primary lifesaving equipment.

  • Full rated capacity of persons are in the water
  • Most of rated capacity hangs on outside edge

The new regulations require inflatable survival craft in those applications posing the greatest risk of hypothermia, taking into account:

  • Water temperature
  • Vessel construction (wood vs non-wood)
  • Vessel stability (subdivided vs not)
  • Vessel route
  • Overnight accommodations or not

Life Float to IBA Comparison

  • Full rated capacity of persons are in the water
  • Most of rated capacity hangs on outside edge
  • Full rated capacity +50% can be out of water in ?calm? conditions
  • Additional persons can hang on outside edge

Relative risks were assessed based on statistics from Coast Guard and NTSB casualty investigations.

By addressing the relevant risks individually, the new regulations provide a good deal of flexibility in managing those risks--for example, by allowing subdivision to substitute for inflatable survival craft.

Vessels in Ocean Service

  • Old Sub. T
    • 100% LF
  • New Sub. K
    • Cold water
      • 100% ILR
    • Warm water
      • 67% IBA
      • 100% IBA*
  • New Sub. T
    • Cold water
      • 100% IBA
      • 100% LF**
  • Warm water
    • 67% IBA or 100% LF

* vessels with overnight accommodations
** vessels with subdivision

It is not necessary to continually monitor water temperature to know when the "Cold Water" requirements apply. Navigation and Vessel Inspection Circular (NVIC) 7-91 provides monthly maps of cold water areas based on historic NOAA data.

Vessels in Coastwise Service

  • Old Sub. T
    • 100% LF or 100% BA
  • New Sub. K
    • Cold water
      • 67% IBA
      • 100% IBA*
    • Warm water
      • 100% LF
      • 100% IBA*
  • New Sub. T
    • Wood vessels in cold water
      • 67% IBA
      • 100% LF**
    • Warm water, all non-wood
      • 100% LF

* vessels with overnight accommodations
** vessels with subdivision

The new regulations add an additional category of vessels not included in the old regulations--vessels operating within three miles of shore.

For Coastwise and Limited Coastwise service, this replaces the provision in old Subchapter T which allowed reductions, at the OCMI's discretion, for vessels operating not more than 1 mile from land.

Vessels in Coastwise Service (and within 3 miles of shore)

  • Old Sub. T
    • N/A
  • New Sub. K
    • 50% LF*
  • New Sub. T
      • 100% LF
      • 50% LF**

* vessels with overnight accommodations
** vessels with subdivision

Vessels in Limited Coastwise Service (20 miles from safe refuge)

  • Old Sub. T
    • 50% LF or 50% BA
  • New Sub. K
    • Cold water
      • 67% IBA
      • 100% IBA*
    • Warm water
      • 50% LF
      • 100% IBA*
  • New Sub. T
    • Cold water
      • 67% IBA
      • 100% LF**
    • Warm water
      • 50% LF

* vessels with overnight accommodations
** vessels with subdivision

Vessels in Limited Coastwise Service (and within 3 miles of shore)

  • Old Sub. T
    • N/A
  • New Sub. K
    • Cold water
      • 50% LF*
    • Warm water
      • None*
  • New Sub. T
    • Cold water
      • 100% LF*
      • 50% LF**
    • Warm water, all non-wood
      • 50% LF*
      • None**

* vessels with overnight accommodations
** vessels with subdivision

Vessels in Great Lakes Service

Requirements for vessels in Great Lakes service under Subchapters K and T are the same as for vessels in Limited Coastwise Service, except that a vessel certificated to operate within one mile of land is not required to carry survival craft if the OCMI determines that it is safe not to do so.

Vessels in Lakes, Bays , and Sound Service

  • Old Sub. T
    • 30% LF or
    • 30% BA (except within one mile of shore)
  • New Sub. K
    • Cold water
      • 100% LF
      • 67% IBA*
    • Warm water
      • 50% LF
      • 67% IBA*
  • New Sub. T
    • Cold water
      • 100% LF
      • 50% LF**
    • Warm water
      • None

* vessels with overnight accommodations
** vessels with subdivision

Vessels in Lakes, Bays, and Sounds service under either Subchapter K or T, operating within one mile of shore, are not required to carry survival craft.

Vessels in River Service

  • Old Sub. T
    • 10% LF or
    • 10% BA (except within one mile of shore)
  • New Sub. K
    • Cold water
      • 50% LF
    • Warm water
      • None
  • New Sub. T
    • Cold water
      • 50% LF*
    • Warm water
      • None

* vessels with subdivision

Vessels in Rivers service under either Subchapter K or T, operating within one mile of shore, are not required to carry survival craft.

For vessels in Lakes, Bays, and Sounds or Rivers service under either Subchapter K or T, survival craft requirements may be waived or reduced, at the discretion of the OCMI, if:

  • the vessel operates in shallow water where the vessel cannot sink deep enough to submerge the topmost deck, or?passengers can wade ashore, or
  • the vessel operates on a set schedule on a specific route with regular communications, or participates in a VTS.

Survival Craft Stowage and Embarkation

  • A launching appliance or a marine evacuation system must be provided for inflatable survival craft when:
    • the embarkation station is more than 4.5 meters (15 feet) above the waterline or
    • the appliance will be boarded prior to being placed in the water.
  • An embarkation ladder must be at each embarkation station if the distance from the embarkation deck to the waterline is more than 3050 mm (10 feet).

A mechanical, manually operated device to assist in launching a survival craft must be provided if the survival craft weighs more than 90.7 kg (200 lb), and requires lifting more than 300 mm (one foot) to be launched.

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Philadelphia: 215-365-8450

or
CALL TOLL FREE 800-440-VANE

For more information, send an e-mail to us at sales@vanebrothers.com

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