PFD Types and Stowage Requirements

TL;DR — Recreational vessels require one wearable PFD per person aboard, plus one throwable PFD on vessels 16 feet or longer; wearable PFDs must be readily accessible while throwable PFDs must be immediately available. 33 CFR §175.15 33 CFR §175.19

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What the Rule Says

Definitions: Wearable vs. Throwable

The regulatory framework begins with a clear definitional split. A wearable PFD is intended to be worn or otherwise attached to the body. Types I, II, III, and Type V with Type I, II, or III performance all qualify as wearable PFDs. A throwable PFD is intended to be thrown to a person in the water. Type IV and Type V with Type IV performance are throwable PFDs. Unless specifically marked otherwise, a wearable PFD is not a throwable PFD. 33 CFR §175.13

This distinction is not cosmetic — it drives every carriage and stowage requirement that follows.

Carriage Requirements for Recreational Vessels

Under 33 CFR §175.15, three baseline rules apply to all recreational vessels:

1. At least one wearable PFD must be on board for each person aboard. 33 CFR §175.15 2. Each PFD must be used in accordance with any requirements on its approval label. 33 CFR §175.15 3. If the approval label references an owner's manual, the PFD must also be used in accordance with that manual. 33 CFR §175.15

For recreational vessels 16 feet or more in length, one throwable PFD is required in addition to the wearable PFDs already required — not as a substitute for any of them. 33 CFR §175.15

For vessels under 16 feet (including canoes and kayaks of any length), only wearable PFDs are required — one per person. No throwable PFD is mandated by this section for those vessels. 33 CFR §175.15

Children Under 13

When a recreational vessel is underway, every child under 13 years of age must either be wearing a Coast Guard-approved PFD of appropriate size, or be below decks or in an enclosed cabin. This requirement applies regardless of vessel length. 33 CFR §175.15

Stowage Standards: The Critical Distinction

The regulation uses two different access standards, and confusing them is a common exam error:

• Wearable PFDs must be readily accessible. 33 CFR §175.19
• Throwable PFDs must be immediately available. 33 CFR §175.19

"Immediately available" sets a higher bar than "readily accessible." A throwable device must be reachable and deployable without delay — it cannot be buried under gear, locked in a compartment, or otherwise obstructed. A wearable PFD stowed in an accessible locker satisfies "readily accessible," but that same locker would not satisfy "immediately available" for a throwable device.

Condition, Size, Fit, and Approval Marking

Every PFD required by 33 CFR §175.15 must meet three additional standards:

1. Serviceable condition — as defined in 33 CFR §175.23. 33 CFR §175.21 2. Appropriate size and fit for the intended wearer, as marked on the approval label. 33 CFR §175.21 3. Legibly marked with its approval number as specified in 46 CFR part 160. 33 CFR §175.21

A PFD that is faded, waterlogged, torn, or missing its approval marking fails this standard and does not count toward the required complement.

Commercial and Uninspected Vessel Requirements

For vessels subject to 46 CFR subpart 25.25, the carriage rules differ by vessel length and whether passengers are carried for hire:

• Vessels not carrying passengers for hire and less than 40 feet in length: at least one wearable PFD approved under subchapter Q, of suitable size, for each person on board. 46 CFR §25.25-5
• Vessels carrying passengers for hire, and vessels not carrying passengers for hire and 40 feet or longer: 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
• Vessels 26 feet or longer (except barges subject to this subpart): at least one approved lifebuoy, approved under series 160.050 or 160.150. Uninspected passenger vessels of at least 100 gross tons must carry at least three approved lifebuoys. 46 CFR §25.25-5

An immersion suit approved under 46 CFR 160.171 may be substituted for a wearable PFD on vessels not carrying passengers for hire. A commercial hybrid PFD approved under series 160.077 may be substituted for a PFD under series 160.055, 160.155, or 160.176 on any vessel, provided it is used per its label and owner's manual and is labeled for use on commercial vessels. 46 CFR §25.25-5

Commercial Fishing Industry Vessels

Commercial fishing industry vessels have their own PFD table under 46 CFR §28.110. The required device type depends on the waters in which the vessel operates:

• Seaward of the Boundary Line and north of 32°N or south of 32°S, and Lake Superior: documented vessels must carry an immersion suit or exposure suit. 46 CFR §28.110
• Coastal waters on the West Coast north of Point Reyes, CA; beyond coastal waters in cold water; and Lake Superior: all vessels must carry an immersion suit or exposure suit. 46 CFR §28.110
• All other waters (including all Great Lakes except Lake Superior): vessels 40 feet or more must carry Type I, Type V commercial hybrid, immersion suit, or exposure suit; vessels under 40 feet may carry Type I, II, III, Type V commercial hybrid, immersion suit, or exposure suit. 46 CFR §28.110

For stowage on commercial fishing vessels, each wearable PFD must be stowed so it is readily accessible to the individual for whom it is intended from both that person's normal work station and berthing area. If no single location satisfies both, a device must be stowed in each location. 46 CFR §28.110

Retroreflective Material

Every life preserver, marine buoyant device intended to be worn, and buoyant vest carried on a vessel must have Type I retroreflective material approved under subpart 164.018. Each side of the device must carry at least 200 sq. cm (31 sq. in.) of retroreflective material, divided equally between the upper quadrants of that side, positioned as close to the shoulder area as practicable. Reversible devices must meet this standard on each reversible side. 46 CFR §25.25-15

Additional PFDs on Inspected Passenger Vessels

On inspected passenger vessels, certain devices may be carried as additional equipment but may not substitute for required life jackets and may not be used in place of required life jackets during drills or emergencies. These include wearable marine buoyant devices (ski vests, boating vests, fishing vests) approved under 46 CFR §160.064, buoyant work vests approved under §160.053, and commercial hybrid PFDs approved under §160.077. Commercial hybrid PFDs carried as additional equipment must be used, stowed, and maintained per the required owner's manual and any label limitations, and all hybrid PFDs aboard must be of the same or similar design with the same method of operation. 46 CFR §180.72

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Why It Matters on the Exam

OUPV and Master 100 GT written exams test PFD rules heavily because they are among the most frequently cited deficiencies in Coast Guard boardings. Expect questions that:

• Ask which PFD types are wearable vs. throwable. 33 CFR §175.13
• Test the 16-foot threshold for the throwable PFD requirement on recreational vessels. 33 CFR §175.15
• Distinguish "readily accessible" (wearable) from "immediately available" (throwable). 33 CFR §175.19
• Ask about the child under-13 rule and its exceptions. 33 CFR §175.15
• Test the 26-foot lifebuoy threshold and the 100 GT three-lifebuoy rule for uninspected passenger vessels. 46 CFR §25.25-5
• Ask about retroreflective material area requirements (200 sq. cm per side). 46 CFR §25.25-15
• Probe the commercial fishing vessel stowage rule requiring accessibility from both work station and berthing area. 46 CFR §28.110

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Common Pitfalls

Pitfall 1: Treating a Type IV as a substitute for a wearable PFD. A Type IV is a throwable device. It satisfies the throwable PFD requirement on recreational vessels 16 feet or longer, but it does not count toward the one-per-person wearable PFD requirement. 33 CFR §175.13 33 CFR §175.15

Pitfall 2: Confusing the stowage standards. "Readily accessible" and "immediately available" are not interchangeable. Throwable PFDs demand the higher standard — immediately available. Stowing a ring buoy in a locked lazarette fails this test. 33 CFR §175.19

Pitfall 3: Forgetting the 16-foot threshold. Vessels under 16 feet (including kayaks and canoes) are not required to carry a throwable PFD under 33 CFR §175.15. The one-per-person wearable requirement still applies. 33 CFR §175.15

Pitfall 4: Assuming any wearable PFD satisfies the passengers-for-hire requirement. Vessels carrying passengers for hire must carry PFDs approved under specific approval series (160.055, 160.155, or 160.176) — not just any subchapter Q wearable PFD. 46 CFR §25.25-5

Pitfall 5: Overlooking the child-under-13 rule's exception. A child below decks or in an enclosed cabin is not required to wear a PFD. The rule applies only to children on deck or in open areas while the vessel is underway. 33 CFR §175.15

Pitfall 6: Miscounting lifebuoys for uninspected passenger vessels. The general rule is one lifebuoy for vessels 26 feet or longer. But uninspected passenger vessels of at least 100 gross tons must carry at least three lifebuoys. 46 CFR §25.25-5

Pitfall 7: Treating additional PFDs as substitutes on inspected vessels. Ski vests, buoyant work vests, and commercial hybrid PFDs carried as additional equipment under 46 CFR §180.72 cannot substitute for required life jackets and cannot be used during drills or emergencies in place of required life jackets. 46 CFR §180.72

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Quick Check

Q1: A recreational vessel is 22 feet long and has 4 persons aboard. What is the minimum PFD complement required?

Four wearable PFDs (one per person) plus one throwable PFD, because the vessel is 16 feet or more in length. The throwable PFD is in addition to — not a substitute for — any of the wearable PFDs. 33 CFR §175.15

Q2: What stowage standard applies to a throwable PFD on a recreational vessel?

Immediately available. This is a higher standard than "readily accessible," which applies to wearable PFDs. A throwable PFD must be reachable and deployable without delay. 33 CFR §175.19

Q3: A 14-foot recreational vessel has two adults and one child age 10 aboard. The child is seated in the open cockpit while the vessel is underway. What PFD requirement applies to the child?

The child must be wearing a Coast Guard-approved PFD of appropriate size. The vessel is under 16 feet, so no throwable PFD is required, but the child-under-13 rule requires the child to wear a PFD unless below decks or in an enclosed cabin. 33 CFR §175.15

Q4: How many lifebuoys must an uninspected passenger vessel of 110 gross tons carry, and what approval series must they meet?

At least three lifebuoys, approved under series 160.050 or 160.150. 46 CFR §25.25-5

Q5: What is the minimum retroreflective material area required on the front side of a wearable PFD?

At least 200 sq. cm (31 sq. in.) of Type I retroreflective material, divided equally between the upper quadrants of the front side, positioned as close to the shoulder area as practicable. 46 CFR §25.25-15

Q6: A commercial fishing vessel operates on the Chesapeake Bay (inside the Boundary Line, mid-Atlantic). The vessel is 35 feet in length. What PFD types satisfy the carriage requirement?

Type I, Type II, Type III, Type V commercial hybrid, immersion suit, or exposure suit — one for each person aboard. The Chesapeake Bay falls under "all other waters" in Table 28.110, and the vessel is less than 40 feet in length. 46 CFR §28.110

Q7: A ski vest approved under 46 CFR §160.064 is carried aboard an inspected passenger vessel. May it be used in place of a required life jacket during an emergency drill?

No. Equipment carried as additional PFDs under 46 CFR §180.72 is not acceptable in lieu of any portion of the required life jackets and must not be substituted for required life jackets during drills or emergencies. 46 CFR §180.72