Lifesaving systems are considered essential systems – see 46 CFR 136.110.  All deficiencies related to lifesaving requirements will, in most cases, have to be resolved prior to the vessel getting underway or issuing/endorsing the Certificate of Inspection (COI).  All lifesaving equipment or arrangement details not covered within 46 CFR Part 141 must be to the satisfaction of the approved third-party organization (TPO) that issued the Towing Safety Management System (TSMS) Certificate and/or the cognizant Officer in Charge, Marine Inspection (OCMI), as appropriate.

Lifesaving equipment and systems are very important in the protection of the vessel’s occupants so they need to be properly maintained and immediately available to provide protection if and when needed.  Inspections and vessel surveys will verify lifesaving equipment and installations readiness and compliance with Subchapter M, the TSMS, Subchapter W and SOLAS as applicable. 

In addition to the master of the vessel, proper installation and maintenance of lifesaving equipment is also the responsibility of the owner and/or managing operator.  Improperly installed lifesaving equipment, equipment that has not been maintained and/or expired equipment would not be considered ready for use.

The below flowchart provides a visual high-level representation of the towing vessel lifesaving equipment requirements.  It should not be used as a standalone tool for determining vessel compliance.  Notes:

1. The carriage requirements listed are for domestic routes.
2. During an inspection for certification the vessel must be equipped for the highest route authorized on the COI.
3. Carriage requirements will need to be adjusted if specialized or additional equipment has been required by the OCMI.

46 CFR Part 140 lists minimum lifesaving training requirements. The lifesaving portion of an inspection or survey is not complete until both the physical lifesaving equipment or system is inspected and the competency of the crew is evaluated.  Drills can be used by the inspector/TPO to evaluate crew competency.  By observing lifesaving drills, the inspector/TPO can gauge whether or not the master and crew are familiar with the vessel and its lifesaving equipment and possess the skills necessary to deal with an emergency.

Regulatory Cites:

46 CFR 141.240 Requirements for training crews.

Category 1 EPIRBs are designed to float-free and activate automatically. A manually activated Category 2 406 MHz EPIRB is not an acceptable substitute on a vessel required by this part to carry a Category 1 EPIRB.  

EPIRBs have proven their effectiveness in saving lives by providing an additional means to quickly locate a vessel and/or the crew during an emergency.  Towing vessels that are not required by this part to carry an EPIRB may carry a Category 1 or Category 2 406 MHz EPIRB as excess equipment provided the EPIRB is maintained in good and serviceable condition and is registered with NOAA.  

Except for an EPIRB installed in inflatable survival craft that is tested during the annual servicing of the survival craft, the EPIRB is required to be tested immediately after installation and at least once each month thereafter.  The test must be conducted in accordance with the manufacturer’s instructions.  If the EPIRB is not operating, it must be repaired or replaced with an operating EPIRB prior to the vessel getting underway.

The EPIRB battery must be replaced immediately after the EPIRB is used (except for testing) and before the battery’s expiration date.

Items to check:

• EPIRB is a Category 1 406 MHz.
• EPIRB has been tested and test results were satisfactory.
• EPIRB marked with the vessel’s name.
• EPIRB properly stowed in a float-free arrangement.
• If the EPIRB uses a hydrostatic release, hydrostatic release not expired.
• EPIRB battery not expired.
• Valid EPIRB registration.

Regulatory Cites:

46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.380 Emergency position indicating radio beacon (EPIRB)
46 CFR 199.190 Operational readiness, maintenance, and inspection of lifesaving equipment
47 CFR 80.1061 Special requirements for 406.0-406.1 MHz EPIRB stations
47 CFR 80.1085 Ship radio equipment—General

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II

Based upon the vessel arrangement and to facilitate immediate accessibility to immersion suit(s) at normally manned spaces such as work station(s), watch station(s) or work site(s), the OCMI/TPO has the discretion to require additional immersion suits .  If additional immersion suits are required, the number of additional suits for the space should equal the number of persons normally on watch or working in the space.  

The total number of immersion suits should not be lower than the total persons allowed to be carried by the COI plus any additional suits required by the OCMI.  

Whistle do not have an approval series; however, MSM Vol. II contains guidance on acceptable whistles.

Items to check:

• Sufficient number of appropriately sized immersion suits.
• All immersion suits Coast Guard approved under approval series 46 CFR 160.171
• Immersion suits properly stowed and readily accessible.
• Immersion suit stowage location(s) properly marked.
• Immersion suits properly marked with the vessel or persons name.
• Immersion suits properly fitted with retro-reflective material.
• Immersion suits fitted with an approved and serviceable lifejacket light.
• Immersion suits fitted with a serviceable whistle.
• Immersion suits in sound (serviceable) material condition – free of defects and/or unauthorized repairs.

Regulatory Cites:

46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.350 Immersion suits
46 CFR 161.012 Personal Flotation Device Lights
46 CFR 164.018 Retroreflective Material for Lifesaving Equipment
46 CFR 199.70 Personal lifesaving appliances

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
NVIC 01-08 Shipboard Inspection and Testing of Immersion Suits
NVIC 03-10 New SOLAS Requirements for Lifejackets and Immersion Suits Effective 1 JULY 2010

Towing vessels can carry line throwing appliance(s) above the minimum carriage requirements as excess equipment provided the equipment meets the same approval standards as those outlined for the required equipment and the equipment is maintained in good and serviceable condition.  

Items to check:

• Line throwing appliance Coast Guard approved under approval series 46 CFR 160.040.
• Line throwing appliance readily accessible.
• All equipment listed on the manufacturer’s equipment list/instruction placard packed with the line throwing appliance.
• An appropriate (length, breaking strength and color) auxiliary line provided.

Regulatory Cites:

46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.385 Line throwing appliance  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II

The minimum number required, the minimum size required, attachments required and stowage location requirements are based on the length of the vessel.  The cognizant OCMI can require additional lifebuoys as deemed necessary based on the vessels operating area.

In accordance with 46 CFR 141.360(b)(1) the lifebuoy must be approved under approval series 160.050 or 160.150.  There is no specific regulatory requirement for a lifebuoy approved under approval series 160.050 to have retro-reflective material; however, a lifebuoy approved under approval series 160.150 must be fitted with approved retro-reflective material in accordance with 46 CFR 160.150-3(f).  Towing vessels on international routes must ensure retro-reflective material is fitted in accordance with IMO Resolution A.658(16).  When retro-reflective material is required, the lifebuoy must be fitted with approved retro-reflective material (tape) with a minimum of 5 cm (2 inches) width around the lifebuoy at four locations spaced equally around the circumference of the lifebuoy.

Detectability is a key component in minimizing the time it takes to rescue a person once they enter the water.  International orange lifebuoys are preferred because they are more visible in white caps and glare; however, lifebuoys can be white or international orange in color unless the vessel is on an ocean, coastwise or international voyage.  A vessel on an ocean, coastwise or international voyage must carry lifebuoys that are international orange in color.  Lifebuoys with properly fitted and serviceable lights and/or smoke signals further enhances the likelihood that a person in the water will be located quickly for a prompt rescue in all operating areas and conditions.  

If a towing vessel only carries one lifebuoy with attached floating electric water light, the water light must not be permanently attached to the lifebuoy.  The water light should be attached by a lanyard and corrosion-resistant clip as required by this section to allow the water light to be quickly disconnected.  

A vessel greater than 79 feet in length must have a lifebuoy located on each side of the primary operating station.  

Items to check:

• Sufficient number of lifebuoys.
• Lifebuoys Coast Guard approved under approval series 46 CFR 160.050 or 160.150.
• Lifebuoys the proper color.
• Lifebuoys properly stowed.
• Lifebuoys properly marked with the vessel name.
• Lifebuoys properly fitted with retro-reflective material.
• Proper number of lifebuoys fitted with approved water lights and lanyards.
• Proper number of lifebuoys fitted with buoyant life-line(s).
• Lifebuoy in sound (serviceable) material condition – free of defects and/or unauthorized repairs.  

Regulatory Cites:

46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.360 Lifebuoys
46 CFR 161.010 or 161.110 Floating Electric Waterlight
46 CFR 164.018 Retroreflective Material for Lifesaving Equipment  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
IMO Resolution A.658 (16) Use and Fitting of Retroreflective material on lifesaving appliances
NVIC 02-63 Guide for Inspection and Repair of lifesaving Equipment

Some lifejacket and lifejacket stowage requirements are found in International Maritime Organization (IMO) standards that have been incorporated by reference (IBR).  This means all applicable parts of the IMO resolutions have the full force of regulation.  

Work vests are considered safety equipment not lifesaving equipment and are not authorized, or an appropriate substitution for a lifejacket(s).  Work vests must be stowed in locations separately from lifejackets.  The stowage location(s) for work vest and the stowage location(s) for approved lifejackets need to be such as not to be easily confused.  

The total number of lifejackets should never be lower than the total persons allowed to be carried by the COI plus the number of additional lifejackets required at the watch stations.  If the COI allows persons in addition to the crew to be carried, there must also be enough Coast Guard approved lifejackets of a suitable size for the additional persons.  

Lifejacket lights that have a non-replaceable power source must be replaced on or before the expiration date of the power source.  If the light has a replaceable power source, the power source must be replaced on or before its expiration date.  

Lifejacket must be fitted with approved retro-reflective material in accordance with IMO Resolution A.658 (16).  Each lifejacket is required to have at least 400 cm2 (62 square inches) of retro-reflective material.  If the lifejacket is reversible, an additional 400 cm2 of properly fitted retro-reflective material would be required on the reversible side.  

Other than on a vessel operating solely within a limited geographic area (LGA), all vessels with berthing must also carry additional approved lifejacket(s) at each watch station for every watch stander.  The term “watch station” used in this section is not defined however; the intent is to have a lifejacket readily accessible at all times for persons standing watch(s) so they will be able to get a lifejacket quickly when needed.  The bridge is one example of a watch station. Additional lifejacket(s) would need to be readily available for watch stander(s) on the bridge as well as other manned watch stations.  Watch station determinations, and the need for additional lifejackets at those workstations, are at the discretion of the OCMI/TPO based upon the vessel arrangement and the operational area.  

Whistle do not have an approval series; however, MSM Vol. II contains guidance on acceptable whistles.  

Items to check:

• Sufficient number of lifejackets.
• All lifejackets Coast Guard approved.
  • Kapok lifejacket: 46 CFR 160.002
  • Fibrous glass lifejacket: 46 CFR 160.005
  • Unicellular plastic foam lifejacket: 46 CFR 160.055
  • SOLAS lifejacket: 46 CFR 160.155
  • Inflatable lifejacket: 46 CFR 160.176
• Lifejackets properly stowed and readily accessible.
• If using inflatable lifejackets, all are a similar design and mode of operation.
• Lifejackets properly marked with the vessel name and retro-reflective material.
• Lifejackets fitted with an approved and serviceable lifejacket light.
• Lifejackets fitted with a serviceable whistle.
• Lifejacket in sound (serviceable) material condition – free of defects and/or unauthorized repairs.

Regulatory Cites:

46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.340 Lifejackets
46 CFR 164.018 Retroreflective Material for Lifesaving Equipment
46 CFR 161.012 or 161.112 Personal Flotation Device Lights.  Approval series 161.012 lights can only be used on domestic routes.

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
IMO Resolution A.658 (16) Use and Fitting of Retroreflective material on lifesaving appliances
IMO Resolution A.760 (18) Symbols related to life-saving appliances and arrangements
NVIC 02-63 Guide for Inspection and Repair of lifesaving Equipment
NVIC 01-94 Marking of Life Preservers and PFDs
NVIC 03-10 New SOLAS Requirements for Lifejackets and Immersion Suits Effective 1 JULY 2010

A towing vessel is allowed to reduce lifesaving equipment carriage requirements while operating on routes subordinate to the highest route authorized by the vessels COI.  The equipment carriage reduction(s) are only allowed on towing vessels that operate on domestic routes and do not maintain international certificates – i.e. SOLAS certificates.  Failure to properly maintain and/or have on board any lifesaving equipment required by an international certificate, regardless of the authorized route or the operational area, will invalidate the international certificate(s).  

Regulatory Cites:

46 CFR 141.105(c) Applicability and delayed implementation for existing vessels

Towing vessel survival craft carriage requirements are based on warm or cold water operation.  Definitions for warm and cold water can be found in 46 CFR 136.110.  

Substituting survival craft of higher precedence is allowed – i.e. an approved lifeboat can be substituted for any survival craft.  The hierarchy of survival craft, from most protective to least protective, is lifeboat, inflatable liferaft, inflatable buoyant apparatus (IBA), life float, and rigid buoyant apparatus.  

Items to check:

• All survival craft Coast Guard approved:

• Lifeboats: 46 CFR 160.135
• Inflatable liferaft: 46 CFR 160.151
• Inflatable liferaft: 46 CFR 160.051 (only allowed as a substitute for an inflatable buoyant apparatus)
• Inflatable buoyant apparatus: 46 CFR 160.010
• Life float: 46 CFR 160.027
• Rigid buoyant apparatus: 46 CFR 160.010

• Survival craft readily accessible.
• Survival craft have enough capacity to accommodate the total number of persons authorized on the vessel’s COI.
• Survival craft provide a means of sheltering appropriate for the route.
• Survival craft properly equipped.
• Survival craft fitted with retro-reflective material.
• Survival craft inspections, testing and maintenance completed and current.
• Survival craft in serviceable condition free of defects, deformities and/or unauthorized repairs.
• Survival craft properly stowed.
• Survival craft and stowage location(s) properly marked.
• If equipped with inflatable survival craft, instruction placards in place.
• If using a skiff to meet survival craft requirements:
  • Skiff is an authorized substitute
  • Adequate for the vessel’s route
  • Can accommodate all persons on board the vessel
  • Properly marked

Regulatory Cites:

46 CFR 136.110 Definitions
46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.305 Survival craft requirements for towing vessels
46 CFR 141.310 Stowage of survival craft
46 CFR 141.315 Marking of survival craft and stowage locations
46 CFR 141.320 Inflatable survival craft placards
46 CFR 141.325 Survival craft equipment
46 CFR 141.330 Skiffs as survival craft
46 CFR 164.018 Retroreflective Material for Lifesaving Equipment
46 CFR 199.130 Stowage of survival craft
46 CFR 199.175 Survival craft equipment
46 CFR 199.176 Markings on lifesaving appliances
46 CFR 199.178 Marking of stowage locations 

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
IMO Resolution A.658 (16) Use and Fitting of Retroreflective material on lifesaving appliances
IMO Resolution A.760 (18) Symbols related to life-saving appliances and arrangements
NVIC 02-63 Guide for Inspection and Repair of lifesaving Equipment
NVIC 04-86 Hydraulic Release Units for Life Rafts, Life Floats and Buoyant Apparatus, and Alternate Float-Free Arrangements
NVIC 07-91 Determination of Cold Water Areas

Flare type signals are considered appropriate for both day and night use.  Smoke type signals are only appropriate for use as day signals. Visual distress signal carriage requirements are based on the vessel's area of operation.  The vessel will be required to carry a combination of either 3 day and 3 night signals or 6 day and 6 night signals.  Vessels that carry visual distress signals that are approved as both day and night signals would only need to carry 3 or 6 visual distress signals, respectively.  For example, if the vessel is required to carry 3 day and 3 night signals, then a total of 3 signals suitable for both day and night would satisfy the requirement.

The stowage and safe handling of distress signals is very important. Distress signals must be stored in a portable, watertight, brightly colored container marked "DISTRESS SIGNALS" in contrasting letters at the operating station or in a pyrotechnic locker located near the operating station.  

A limited number of expired (outdated) distress signals may be carried aboard the vessel for training purposes.  The expired signals must be stored in an appropriate container marked “OUTDATED – FOR DRILLS” and stored separately from the in service visual distress signals.

Items to check:

• Appropriate number of day and night signals for the vessels route.
• All distress signals Coast Guard approved.
  • Day and night visual distress signals:
    • Hand-held red flare 46 CFR 160.021 or 160.121
    • Hand-held red rocket-propelled parachute red flare: 46 CFR 160.036 or 160.136
  • Day only visual distress signals:
    • Floating orange smoke: 46 CFR 160.022, 160.122 or 160.157
    • Hand-held orange smoke: 46 CFR 160.037
• Distress signals not expired.
• Distress signals properly stowed and the stowage location properly marked.
• Distress signals in serviceable condition.

Regulatory Cites:

46 CFR 141.230 Readiness
46 CFR 141.235 Inspection, testing, and maintenance
46 CFR 141.375 Visual distress signals

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
NVIC 02-63 Guide for Inspection and Repair of lifesaving Equipment