PFD types and stowage requirements

What the rule requires

Two boats of the same length can owe different equipment, and the thing that separates them is who is aboard and why. The regulations are split by vessel employment, so the first move on any PFD question is to place the vessel in the right part of the CFR. Everything after that is arithmetic.

The commercial count — 46 CFR §25.25-5

The operative trigger is carrying passengers for hire. A vessel carrying passengers for hire, and a vessel not carrying passengers for hire that is 40 feet in length or longer, must carry at least one PFD approved under approval series 160.055, 160.155 or 160.176, of suitable size, for each person on board 46 CFR §25.25-5. Below 40 feet and not for hire, the standard drops: at least one wearable PFD approved under subchapter Q, of suitable size, per person.

Read that pair carefully. The 40-foot line only decides anything on a vessel that is not carrying passengers for hire. Put one paying angler aboard a 24-foot skiff and she is in the higher category regardless of her length.

Lifebuoys ride on length, not employment. Each vessel 26 feet or longer, barges excepted, must have at least one approved lifebuoy, and each uninspected passenger vessel of at least 100 gross tons must have at least three. Required lifebuoys are approved under series 160.050 or 160.150, and a lifebuoy approved under the former 46 CFR 160.009 before May 9, 1979 may still be used so long as it remains in good and serviceable condition.

Two substitutions are permitted, and they are not symmetrical:

Immersion suit approved under 46 CFR 160.171 — may replace a required wearable PFD only on a vessel not carrying passengers for hire.
Commercial hybrid PFD approved under series 160.077 — may replace a 160.055, 160.155 or 160.176 PFD on any vessel, regardless of length and regardless of whether she is carrying passengers for hire, provided it is used in accordance with the conditions marked on it and in the owner's manual, and is labelled for use on commercial vessels.

Your 30-foot uninspected passenger vessel is running six paying passengers, a master and a deckhand. A crewmember proposes counting two immersion suits toward the required PFDs. Acceptable?

No. The immersion suit substitution under §25.25-5(c)(1) is available only to a vessel not carrying passengers for hire. She needs eight PFDs of suitable size from the 160.055, 160.155 or 160.176 series, and being 30 feet she also needs at least one approved lifebuoy.

The recreational count — 33 CFR Part 175

At least one wearable PFD aboard for each person, used in accordance with any requirement on the approval label and in the owner's manual where the label refers to one 33 CFR §175.15. A recreational vessel 16 feet or more in length carries one throwable PFD in addition to the wearables — the throwable never reduces the per-person count.

Children under 13 years old aboard a recreational vessel under way must be wearing an appropriate Coast Guard-approved PFD unless they are below decks or in an enclosed cabin. Both halves of that rule get tested: the age, and the exception.

Each required PFD must be in serviceable condition, of an appropriate size and fit for the intended wearer as marked on the approval label, and legibly marked with its approval number 33 CFR §175.21. A locker full of adult jackets does not satisfy the requirement for a child aboard, because size and fit are part of the requirement rather than good practice.

Classification is by marked performance

Wearable PFD means a PFD intended to be worn or otherwise attached to the body; a PFD marked Type I, Type II, Type III, or Type V with Type I, II or III performance is a wearable 33 CFR §175.13. Throwable PFD means one intended to be thrown to a person in the water; Type IV, or Type V with Type IV performance. Unless specifically marked otherwise, a wearable is not a throwable.

The device in common use is "one, two and three you wear; four you throw; five, read the label." It is sound as far as it goes, and it is what §175.13 says in substance. Where it is lossy is Type V: Type V is not a category with its own duty, it takes the class of whatever performance is marked on it, so the same "Type V" answer option can be right or wrong depending on the marking the question gives you.

Retroreflective material

Each life preserver, each marine buoyant device intended to be worn, and each buoyant vest carried on a vessel must have Type I retroreflective material approved under subpart 164.018 46 CFR §25.25-15. The quantity is at least 200 square centimetres (31 square inches) on the front, the same on the back, and the same on each reversible side of a reversible device. Placement is specified: divided equally between the upper quadrants of that side, as close as practicable to the shoulder area.

Stowage

The recreational standard uses two different phrases for two different devices. Each required wearable PFD must be readily accessible; each required throwable must be immediately available 33 CFR §175.19.

On a commercial fishing industry vessel, each wearable PFD must be stowed so that it is readily accessible to the individual for whom it is intended from both that individual's normal work station and berthing area, and where no single location serves both, an appropriate device is stowed in each 46 CFR §28.110.

Where the Part 180 life jacket stowage rules apply, the detail is finer 46 CFR §180.78:

Life jackets are stored in convenient places distributed throughout accommodation spaces.
A stowage container must not be capable of being locked, and where practicable must be designed to let the life jackets float free.
A life jacket stowed overhead must be supported so it releases quickly for distribution, and above 2,130 millimetres (7 feet) from the deck a quick-release means must be fitted that a person standing on the deck can operate.
Child size life jackets are stowed separately from adult jackets, in an appropriately marked location, so the two are not mistaken for one another.

PFDs carried in addition to life jackets — ski, boating and fishing vests approved under 160.064, buoyant work vests under 160.053, commercial hybrids under 160.077 — are additional equipment only. They may not be counted against any portion of the required number of approved life jackets, nor substituted for the life jackets required to be worn during drills and emergencies 46 CFR §180.72. Their stowage must be kept separate from the life jackets and arranged so the two are not easily confused.

Telling it apart

Readily accessible against immediately available

The criterion is which device the regulation names, and the two standards are not interchangeable.

Wearable PFD — readily accessible. The device a person will put on before or during an event.
Throwable PFD — immediately available, the higher of the two standards. It is worked in the seconds after someone goes over the side, so it cannot be stowed like a spare jacket.

The distractor writers rely on candidates remembering that two phrases exist without remembering which attaches to which. Fix the pairing, not the words.

Type V

Type V marked with Type I, II or III performance — a wearable, and counts against the per-person requirement.
Type V marked with Type IV performance — a throwable, and counts against the throwable requirement instead.
Type V commercial hybrid approved under 160.077 — substitutable for a 160.055, 160.155 or 160.176 PFD on a commercial vessel when used per its markings and manual and labelled for commercial use 46 CFR §25.25-5, but carried under §180.72 it is additional equipment and counts for nothing.

Working a question

A 38-foot uninspected passenger vessel is running a charter with six passengers for hire, a master and a paid deckhand. What lifesaving equipment must be aboard?

Place the vessel. She is carrying passengers for hire, so the count comes from 46 CFR §25.25-5. Part 175 does not reach her; neither does Table 28.110, which is the commercial fishing industry vessel requirement.
Count persons on board, not passengers. Six plus master plus deckhand is eight. The requirement reads "each person on board."
Fix the grade. Carrying passengers for hire puts her under §25.25-5(b)(2): eight PFDs approved under series 160.055, 160.155 or 160.176, each of suitable size for the person intended. Her 38 feet is irrelevant to this step — the 40-foot line governs only vessels not for hire.
Apply the length trigger. At 38 feet she is 26 feet or longer, so at least one approved lifebuoy under series 160.050 or 160.150. Three lifebuoys would be required only of an uninspected passenger vessel of at least 100 gross tons.
Test the substitutions. Immersion suits are out, because she carries passengers for hire. A 160.077 commercial hybrid is in, if labelled for commercial vessels and used per its markings and manual.
Check the devices themselves. Each life preserver, wearable marine buoyant device and buoyant vest carries Type I retroreflective material — 200 square centimetres per side, split between the upper quadrants near the shoulder 46 CFR §25.25-15.

Nothing in that sequence produces a throwable-per-vessel requirement, and no step counts a lifebuoy toward the eight.

Where candidates lose the point

Answering "one throwable in addition, because she is over 16 feet" on a for-hire question. The 16-foot throwable requirement is 33 CFR §175.15, which governs recreational vessels. The commercial second item is the lifebuoy at 26 feet under 46 CFR §25.25-5.

Reaching for 40 feet as the trigger for the higher PFD grade on a charter boat. The 40-foot threshold applies to a vessel not carrying passengers for hire. Carrying passengers for hire triggers the 160.055/160.155/160.176 requirement at any length.

Swapping the stowage standards, so the throwable becomes "readily accessible" and the wearables "immediately available" 33 CFR §175.19. Both phrases will appear in the options.

Counting a Type IV cushion or a ring buoy as one person's PFD. A wearable is not a throwable unless specifically marked, and the throwable requirement sits on top of the per-person wearable count 33 CFR §175.13.

Counting buoyant work vests or ski vests toward the required number, because they are approved devices and they are aboard. Under 46 CFR §180.72 they are additional equipment and cannot make up any part of the required life jackets.

Treating the child rule as an age other than 13, or dropping the exception. The rule reaches a recreational vessel under way with a child under 13 aboard, and it is satisfied by the child being below decks or in an enclosed cabin as well as by wearing an approved PFD.

Passing a boat with the right number of adult jackets and a child aboard. Appropriate size and fit for the intended wearer is a requirement in its own right, alongside serviceable condition and a legible approval number 33 CFR §175.21.

Applying Table 28.110's immersion suit entries to a passenger charter. That table is the commercial fishing industry vessel requirement 46 CFR §28.110, and its waters-based rows are read only after the vessel is placed in Part 28.

Check yourself

You are operating a 44-foot uninspected vessel with no passengers for hire aboard, five persons total. What is the minimum PFD outfit?

Five PFDs approved under series 160.055, 160.155 or 160.176, of suitable size for each person, because she is 40 feet or longer even though she is not for hire, plus at least one approved lifebuoy since she exceeds 26 feet 46 CFR §25.25-5. Immersion suits under 160.171 may be substituted for the wearables here, as she is not carrying passengers for hire.

A recreational 18-foot open boat has four persons aboard and four wearable PFDs stowed under a seat, plus a Type IV cushion in the same locker. Is she in compliance?

Not as described. The count is met — four wearables for four persons, and a throwable is aboard as required at 16 feet and over — but the throwable must be immediately available, and a cushion buried in a locker with four jackets on top of it is not 33 CFR §175.19.

A PFD aboard is marked "Type V with Type IV performance." Toward which requirement does it count?

The throwable requirement. A Type V marked with Type IV performance is a throwable PFD, and a device marked as a throwable does not count against the per-person wearable requirement 33 CFR §175.13.

You are the master of a 102 gross ton uninspected passenger vessel. How many lifebuoys?

At least three. An uninspected passenger vessel of at least 100 gross tons must have at least three approved lifebuoys, approved under series 160.050 or 160.150 .

Life jackets on your vessel are stowed in a deckhead rack 8 feet above the deck. What must be fitted?

A quick-release means operable by a person standing on the deck, since the jackets are stowed more than 2,130 millimetres (7 feet) above it. Overhead stowage must in any case support the jackets so they release quickly for distribution 46 CFR §180.78.

A crewmember on a commercial fishing vessel keeps his PFD in his bunk space. His work station is on the after deck, and nothing in that stowage is accessible from both. What does §28.110 require?

An appropriate device stowed in both locations. The wearable must be readily accessible from the individual's normal work station and berthing area, and where no single location serves both, one is stowed in each 46 CFR §28.110.

Your reversible buoyant vest carries 200 square centimetres of Type I retroreflective material on one side only. What is deficient?

A reversible device needs at least 200 square centimetres on each reversible side, divided equally between that side's upper quadrants and placed as close as practicable to the shoulder area 46 CFR §25.25-15.

An 11-year-old is aboard your recreational vessel under way, seated in the enclosed cabin without a PFD on. Violation?

No. A child under 13 must be wearing an approved PFD or be below decks or in an enclosed cabin 33 CFR §175.15. The child still counts as a person on board for the per-person wearable requirement, and that jacket must be of appropriate size and fit for her 33 CFR §175.21.