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i m p o r t a n t n o t i c e Recent USCG approval of some types of inflatable PFDs (Personal Flotation Devices) has created a great deal of confusion regarding the rules. Currently the USCG requires there be one (1) USCG "approved as a required device" PFD aboard each vessel for every person aboard. Stormy Seas Inc., a manufacturer of Inflatable PFDs, speaks out with some answers to frequently asked questions about USCG approved PFDs and non-approved PFDs. Q. Is Stormy Seas seeking USCG approval for their inflatable lifejackets? A. Not at this time. As a manufacturer of inflatable PFDs for the past twelve years, we do not think inflatables should be "approved as a required device." Q. Why not ? A. It is our sincere belief that no boater should have only an inflatable PFD available for use aboard any commercial or recreational vessel. USCG approval of some types of inflatables will create this potentially dangerous situation. Approved inflatables would be allowed to substitute for inherently buoyant devices to meet vessel carriage requirements. We don't see this as a positive step toward saving lives at sea. Q. Why Not? A. Inflatable devices require a level of care and maintenance that is a good deal more involved than any inherently buoyant PFD. If they don't get it, they might not work properly. In a 1993 Study done by the Boat/US Foundation for Boating Safety (funded by a grant from the United States Coast Guard), inflatable lifejackets were given to a randomly selected group of recreational boaters. After 6-24 months in the field, 45% of these inflatable lifejackets were improperly armed by the end user. The proper use of inflatable PFDs requires an understanding and respect for equipment that can not be legally mandated. It is our belief that there is a way for inflatable PFDs and foam PFDs to co-exist—thus improving boating safety and reducing the loss of life at sea, goals we have always pursued. As an overboard victim—and now as a manufacturer of a device specifically developed for man-overboard situations—it has long been my belief, that if there is any area of boating equipment where redundancy should be encouraged, it is personal safety equipment. Redundancy is already a common practice—many boats have spare radios, radars, bilge pumps, power sources, propulsion systems, etc. Even kayakers take spare paddles. We believe that the stated objectives of the USCG—to improve boating safety and reduce the loss of life at sea— would be much better served by maintaining the vessel carriage requirement for inherently buoyant devices while encouraging the use of more-wearable, personal PFDs, some of which are inflatables. Redundancy is a very good thing in this situation. Confusion is created by the misuse of the word "approved." The actual phrase is "approved as a required device." The USCG could go a long way towards clearing up the confusion by changing the phrase to "complies with USCG carriage requirements." Q. What about the perception that approved devices are better than non-approved devices? A. The perception is the problem, not the products. The stigma is that non-approved devices are inferior, but nothing could be farther from the truth. The USCG standard is a minimum standard, not something to be aspired to. The vessel carriage requirement can still be met with inexpensive foam PFDs. Those who purchase Stormy Seas flotation do so because of the obvious utility of the product and its application to the individual situation. Our list of customers includes the USCG, US Navy, US Forest Service, US Sailing, North Pacific Fishing Vessel Owners, International Halibut Commission, Icelandic Coast Guard, Puget Sound Pilots Association, Sandy Hook Pilots Association, Virginia Beach Pilots Association, Federal Aviation Administration, US Customs Service, Air Taxi Operators, Search and Rescue organizations, Law Enforcement, University Rowing Teams, and many many others. In the twelve years since my overboard experience in the Bering Sea, and the subsequent development of the Stormy Seas concept, we have delivered to the commercial and recreational boating public in excess of 150,000 inflatable garments. Our testing procedures are in excess of the industry standards; our component quality standards are equal to or better than those required for use by the military, the FAA, and the Coast Guard. There is nothing inferior about Stormy Seas products. We are immensely proud of the products we produce and the lives they have helped to save; we have every reason to feel this way. The problem is a perception that is exaggerated by the mis-use of the word "approved." The complete phrase is "approved as a required device"—not "approved because it is a superior device." To illustrate this point you need only examine a standard $6.00 USCG "approved" type II foam lifevest—or the newly "approved" inflatable belt pack. Q. Won't more people buy Stormy Seas if it is approved? A. The vessel carriage requirement can still be met with an inexpensive $6.00 foam PFD. I don't believe that approval alone will cause people to spend 15 -20 times more for an inflatable that meets the simple PFD carriage requirement. Our customers are smarter than that. An inflatable has got to offer an individual something else—something they need. Stormy Seas products do just that. People purchase Stormy Seas products because of the ovbious utility of the concept and the value of its application to their situation. These consumers are unaffected by the hype surrounding the introduction of the first USCG-approved inflatables. With "approval" we might sell a few more garments. But in our estimation, it is not worth the risk of being the sole flotation device aboard commercial or recreational vessels. Our objective has always been to provide people with an additional tool that can help them save their own lives and the lives of others. The substitution of an inflatable to meet vessel carriage requirements does not add a tool—but might possibly remove one. We simply do not see this as a positive step to improved boating safety. We want to continue to be proud of our products and the lives they have saved and will help to save. Q. Why do non-approved PFDs continue to exist? A. Simply put, non-approved PFDs are the future. By designing outside of the current rigid specifications, developers of non-approved PFD's can work to meet the needs of people rather than the needs of a specification. By focusing on high quality components and basic performance criteria, manufacturers of non-approved devices can offer the boating consumer unique designs tailored to specialized needs. There are those who would perpetuate the myth that a USCG approved device is better than a non-approved device. It is critical that the confusion surrounding the term "USCG approved" be cleared up. We believe the Coast Guard has a moral obligation to eliminate this misconception. To quote the Coast Guard, " The best way to minimize the number of deaths due to drowning is to maximize the number of boaters wearing lifejackets." We believe that the best way to accomplish this objective is to allow boaters the freedom to choose the lifejacket that works best for them". Q. Will Stormy Seas ever seek USCG approval for their inflatables? A. I learned a long time ago, "never say never." The problem with the existing or first standard for a USCG approved inflatable PFD, is that it was developed by a committee, designed by a committee, to meet the needs of the committee. Our standards are high, and we refuse to lower our quality standards—or compromise the safety and needs of our customers—just to meet or comply with the first inflatable standard. We will continue to work with the Coast Guard toward the development of a solution that addresses the needs of the boating public, rather than the needs of the committee. The only approval we have ever pursued is the approval of the people who use Stormy Seas. The approval of these users is resounding. Conclusion: Reducing the loss of life at Sea, has always been Stormy Seas focus. We have participated in this noble endeavor by designing and constructing quality products that work because people enjoy wearing them. Some call this "prevention through people"—people exercising their right to create niche products and others executing their right to choose what works for them, their family, and their crew. As we in the boating community continue the heated debates concerning "mandatory wear" of PFDs, I can only hope that those who propose regulations will have the presence of mind to allow a "prevention through people" arena to flourish. US Sailing has recently prescribed a mandatory wear rule for races. Thankfully, the governing body of sailboat racing sees the merit and value of lifesaving appliances that are not recognized by the USCG as "approved as required devices." The result is a rule that allows people the right to choose the device that works best for them.
Sincerely, Mike Jackson |
