EPIRBs and Distress Signaling Equipment

What the rule requires

The trigger is the operating area

High seas means the waters beyond a line three nautical miles seaward of the Territorial Sea Baseline as defined in 33 CFR 2.20 46 CFR §25.26-1. Every carriage requirement in subpart 25.26 is written the same way — the vessel shall not operate on the high seas, or beyond three miles from the coastline of the Great Lakes, unless she has the specified beacon aboard. Inside that line the section is silent.

Two other things in the definitions decide questions. Length is the length listed on the vessel's Certificate of Documentation or Certificate of Number, not a figure off a tape. And an uninspected passenger vessel is one used, in commercial service, solely to carry passengers for hire or to provide non-emergency assistance towing, and not inspected by the Coast Guard under any other 46 CFR subchapter.

Uninspected passenger vessels

Under 100 gross tons, no EPIRB is required 46 CFR §25.26-10. That covers most of the fleet a newly licensed OUPV or Master 100 GT operator will actually work — the six-pack charter boat running twenty-five miles offshore for tuna carries no EPIRB by regulation, and a question that offers "she must carry a Category 1 beacon because she is beyond three miles" is testing exactly that.

At 100 gross tons or more, the owner, operator, or master must ensure the vessel does not operate beyond three miles from shore as measured from the territorial sea baseline seaward, or more than three miles from the coastline of the Great Lakes, unless she has aboard a float-free, automatically activated Category 1 406 MHz EPIRB stowed so it will float free if the vessel sinks.

Your 92 GT uninspected passenger vessel is chartered for a 40-mile offshore run. The owner asks whether he must buy an EPIRB before you sail. What do you tell him?

Not required. The tonnage gate is the first test, and an uninspected passenger vessel of less than 100 gross tons is not required to carry an EPIRB . The 40 miles never comes into it — you only reach the operating-area test once the vessel is at least 100 gross tons.

Commercial fishing industry vessels

Fishing vessels, fish processing vessels and fish tender vessels are required to carry an EPIRB as specified in part 25, subpart 25.26 46 CFR §28.150. The same subpart splits them three ways at 11 meters (36 feet) 46 CFR §25.26-5:

11 meters (36 feet) or more — a float-free, automatically activated Category 1 406 MHz EPIRB, stowed so it will float free if the vessel sinks.
Less than 11 meters, or 11 meters and over with a builder's certification that the vessel is constructed with sufficient inherently buoyant material to keep the flooded vessel afloat — installed in a readily accessible location at or near the principal steering station, either a manually activated Category 2 406 MHz EPIRB or a float-free, automatically activated Category 1.
11 meters or more with no installed galley or berthing facilities — a float-free, automatically activated Category 1, stowed to float free.

That third branch is where candidates go wrong, because the absence of a galley and bunks sounds like an exemption and is written as one of the paragraphs the first branch excepts. It is not relief. It routes a large open boat to the same Category 1 beacon by a different paragraph.

The definitions decide whether a vessel is in that branch at all. A galley is a space providing for the preparation and extended storage of food; small alcohol or propane stoves with limited cooking capability, and ice chests or similar devices intended for small quantities of food for short durations, do not make one . A berthing space is intended for sleeping and provided with installed bunks and mattresses.

Stowage, setting and type acceptance

An EPIRB, for these purposes, is one Type Accepted by the Federal Communications Commission under 47 CFR parts 2 and 80. A vessel operating on the high seas or beyond three miles from the Great Lakes coastline must have aboard an FCC Type Accepted Category 1, 406 MHz EPIRB installed to automatically float free and activate 46 CFR §180.64.

The stowage requirement is a condition of compliance, not housekeeping. When the vessel is underway the beacon must be stowed in its float-free bracket with the controls set for automatic activation, mounted so it will float free if the vessel sinks 46 CFR §199.510. A Category 1 beacon in a locker, or in its bracket with the controls off, does not meet the requirement. The bracket carries a hydrostatic release so the beacon floats clear and self-activates when the vessel goes down USCG Boat Crew Seamanship Manual §5-B; once activated it transmits a distress signal carrying the vessel's identity to search-and-rescue satellites, and its position if it has an internal GPS.

Any vessel using radio communication equipment must hold a Ship Radio Station License issued by the FCC under 47 CFR part 80 .

Pyrotechnics — which signal, and when

Each type does one job :

Red parachute (rocket) flare — shoots high and burns while descending. Long-range attention at night.
Red hand-held flare — closer range, and to guide rescuers in on the final approach.
Orange smoke, hand-held and floating — day use. Marks a position and shows wind direction.

Pyrotechnics are one-shot and time-limited, so they are used when there is a real chance they will be seen and otherwise saved until a potential rescuer is in range. Handling is the part exam questions like: pointed downwind and away from the body and the boat, held over the side, treated as burning devices that drip hot slag.

Survival craft also carry SARTs, which paint a homing line on a searching ship's radar, and waterproof handheld VHF radios.

Signaling priority

Distress signaling runs in a set order USCG Boatswain Manual Ch. 7 §7.2: VHF Channel 16 MAYDAY with DSC if equipped, which transmits identity and position automatically; then EPIRB activation if a rapid response is critical; visual flares and a signal mirror as backup. Continue to transmit MAYDAY until it is acknowledged.

Telling it apart

The one criterion separating the categories is how the beacon reaches the water and gets switched on.

Category 1 — float-free and automatically activated, stowed so it floats free if the vessel sinks 46 CFR §25.26-5. This is the answer everywhere the subpart bites except one branch. Most often misfiled: a compliant Category 1 beacon stowed unmounted. The float-free installation is part of the requirement, not an option on it.
Category 2 — manually activated, installed in a readily accessible location at or near the principal steering station. It appears in one place only: fishing industry vessels under 11 meters, or 11 meters and over with a builder's certification of sufficient inherent buoyancy. Most often misfiled: offered as the answer for a 42-foot fishing vessel with no such certification, which takes Category 1.

The shorthand instructors use is that a Category 1 leaves without you and a Category 2 leaves with you. It is lossy in one direction: where Category 2 is permitted, Category 1 is expressly permitted as the alternative, so "a Category 2 vessel" never means "Category 2 only".

Working a question

A 78-foot, 95 GT vessel carries six passengers for hire 22 miles offshore. Does she need an EPIRB, and which one?

Classify the vessel. Passengers for hire, not inspected under any other subchapter — uninspected passenger vessel 46 CFR §25.26-1. That fixes which section governs before anything else is looked at.
Test the tonnage gate. 95 GT is less than 100. No EPIRB required 46 CFR §25.26-10. The 22 miles is never reached.
Change one fact — 110 GT. Now the operating-area test runs: 22 miles is beyond three miles measured from the territorial sea baseline seaward, so the requirement bites.
Name the beacon. Float-free, automatically activated Category 1 406 MHz, stowed so it will float free if the vessel sinks.
Check the installation. Underway, in its float-free bracket with the controls set for automatic activation 46 CFR §199.510. A question that puts the beacon in a wheelhouse cabinet is testing this step, not step 4.
Change the class instead. The same 78-footer sails on a voyage catching fish that are to be sold, with passengers aboard. She is a commercial fishing industry vessel for EPIRB purposes . Her documented length exceeds 36 feet and there is no buoyancy certification, so Category 1 again 46 CFR §25.26-5 — and whether she has a galley or bunks changes nothing.

Twenty-five miles offshore your vessel is flooding, the VHF is working and you have DSC. Nothing is in sight. What is your first action?

Transmit MAYDAY on VHF Channel 16 using DSC, which sends your identity and position automatically USCG Boatswain Manual Ch. 7 §7.2. Keep transmitting until acknowledged. The EPIRB follows if rapid response is critical; flares are backup and are held until a potential rescuer is in range USCG Boat Crew Seamanship Manual §5-B.

Where candidates lose the point

Picking Category 2 for a 45-foot fishing vessel because it will be at the steering station. The location wording sits inside the branch for vessels under 11 meters or certified inherently buoyant 46 CFR §25.26-5. A 45-footer with no buoyancy certification is Category 1 wherever it is mounted.
Reading "no galley or berthing facilities" as relief. It is its own paragraph and it requires the same Category 1 float-free beacon. An ice chest and a propane camp stove do not create a galley, so the boat lands in that paragraph rather than escaping the section.
Answering the 36-foot test with an overall length that includes a pulpit or bracket. Length is what appears on the Certificate of Documentation or Certificate of Number 46 CFR §25.26-1.
Treating 100 gross tons as the whole test for an uninspected passenger vessel. Tonnage opens the door; the requirement still only applies beyond three miles from the territorial sea baseline seaward or three miles from the Great Lakes coastline 46 CFR §25.26-10.
Choosing "activate the EPIRB" as the first action with a working VHF. Channel 16 MAYDAY with DSC comes first USCG Boatswain Manual Ch. 7 §7.2.
Firing pyrotechnics on discovering the casualty. They are expended when there is a real chance of being seen USCG Boat Crew Seamanship Manual §5-B. Orange smoke in particular is a daylight signal.
Checking only the battery date at inspection. The hydrostatic release has its own expiry, and the beacon's registration and float-free mounting are both inspection items alongside pyrotechnic expiry and the ready supply.

Check yourself

A 38-foot fish tender vessel with a builder's certification of sufficient inherently buoyant material to keep her afloat when flooded works 12 miles out on the Gulf. Which EPIRB satisfies the regulation, and where is it installed?

Either a manually activated Category 2 406 MHz EPIRB or a float-free, automatically activated Category 1, installed in a readily accessible location at or near the principal steering station 46 CFR §25.26-5. The buoyancy certification, not the length, is what puts a vessel of 11 meters or more into this branch.

The same 38-foot tender has no buoyancy certification. Same waters. What now?

Category 1, float-free and automatically activated, stowed so it will float free if the vessel sinks. Above 11 meters (36 feet) with no certification, the Category 2 option is not available.

You are running an uninspected passenger vessel of 140 gross tons on a two-mile coastal transit. No EPIRB is aboard. Is the vessel in violation?

No. The requirement applies beyond three miles from shore measured from the territorial sea baseline seaward, or more than three miles from the Great Lakes coastline 46 CFR §25.26-10. Two miles is inside the trigger.

An inspector finds the Category 1 beacon secured in a wheelhouse locker with its own bracket unmounted, controls off, battery and hydrostatic release both in date. Compliant?

No. Underway, the EPIRB must be stowed in its float-free bracket with the controls set for automatic activation and mounted so it will float free if the vessel sinks 46 CFR §199.510. In-date components do not cure an installation that cannot release.

You are aboard a 60-foot vessel on a voyage catching fish that will be sold, with four paying passengers aboard, operating on the high seas. Which section governs her EPIRB?

The commercial fishing industry vessel requirement. A vessel on a voyage involving catching fish to be sold is a commercial fishing industry vessel for the purposes of the EPIRB regulations even with passengers aboard 46 CFR §25.26-1, which puts her at Category 1 on her length .

Daylight, moderate visibility, and a search vessel comes into sight about two miles off. Which pyrotechnic do you use?

Orange smoke, hand-held or floating — the day signal, and it also shows the searching unit the wind direction USCG Boat Crew Seamanship Manual §5-B. Hold red hand-held flares for guiding rescuers in on the final approach.

Your survival craft is clear of the vessel and a ship's radar is sweeping the area. What aboard the craft helps her find you?

The SART, which paints a homing line on the searching ship's radar. The craft also carries waterproof handheld VHF radios.