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Old 25-02-2018, 07:14   #1
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Life jackets cannot be in closets?

I was reading US Coast Guard guidelines and it reads that life jackets "should not be stowed in plastic bags, in locked or closed compartments, or have other gear stowed on top of them."

Is this is an actual regulation or just advice? Often when I see the word "should" in federal documents, it means it is not an actual regulation.

If it is a regulation, the "closed compartment" language would seem to ban stowing life jackets in a closet.

If this is a real regulation, what is the CFR number?
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Old 25-02-2018, 07:23   #2
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pirate Re: Life jackets cannot be in closets?

I think its a recommendation that they should be kept on an open shelf in the saloon for example.. fast easy access in an emergency.. no fumbling for keys etc.
But I imagine they could get pissy if past experience of MIU is anything to go by.
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Old 25-02-2018, 07:35   #3
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Re: Life jackets cannot be in closets?

I found the regulation (33 CFR 175.19) and it says that the life jackets must be "readily accessible", so there is some ambiguity about what that means. Apparently the CG considers life jackets in closets to not be "readily accessible".
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Old 25-02-2018, 07:45   #4
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pirate Re: Life jackets cannot be in closets?

An 'At Sea' regulation I imagine.. not a 24/7 while tied up or on the hard.
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Old 25-02-2018, 07:49   #5
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Re: Life jackets cannot be in closets?

One of my few water-cop encounters a few years ago involved this very issue. We were just getting ready to haul anchor when we were approached for the infamous “safety check”.

Everything was fine except that I wasn’t wearing my lifejacket at the time. It was in the cockpit, but is an auto-inflater, so technically is not a lifejacket unless worn. Since we were still anchored I technically did not have to have any lifejacket, but no point arguing with police of any sort…

I was just about to get a fine when the fellow asked if there were any other standard jackets on board. “Yes, of course you honour… we have a bunch of crappy normal ones stowed deep, to be used for when guests are on board.”

“Oh, well, in that case you’re fine,” says the friendly officer. And off he goes. No fine.

So…. the auto inflate, which is sitting there ready to be grabbed or tossed in to me is useless. But a standard lifejacket that is buried deep in a sail locker, that would take many minutes to get to, is?!?

Got me out of the ticket so I didn’t argue the point, but certainly added to my skepticism around the whole “safety checks” silliness.

ADD: This was a Canadian water cop experience. But our regs tend to mirror the Americans.
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Old 25-02-2018, 07:53   #6
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Re: Life jackets cannot be in closets?

Well I think all of us know some closets are more readily accessible than others. So my take is you're going to take your chances with whatever OIC (Officer in Charge) you encounter that day and what kind of day he/she has had to that point. It will most probably be his/her evaluation that determines if your PFDs are "readily accessible" or not.

That said there was a thread some months ago about a large family on a big Cat, maybe a Lagoon?, and they ran up on a reef in the middle of the night due to bad piloting. I was watching a YouTube by another sailing family that interviewed the first family well after the fact. It came out their PFDs were stowed somewhere in the bow in a compartment and NOT readily accessible. The vessel was ultimately stripped, towed off the reef and sunk as it was that badly damaged.

Seriously???? You have your wife and kids on board and traveling way fast, at night in a remote and unknown to you area and the PFDs are stowed away and not readily accessible???

Sounds critical of them, I know, and I shouldn't be as I don't know them and wasn't there but I offer it as a learning experience for all.
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Old 25-02-2018, 08:27   #7
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Re: Life jackets cannot be in closets?

Surely we all know the difference between "being in compliance" and "being safe"?

Bass-ackwards though it is, the first thing you ensure is that you are in compliance. THEN you do what you need to do to be safe.

As for the verbiage in REGs. read "should" as a recommendation, read "must" as a command.

Waterborne LEOs of every kind are generally just earning an honest living. So let's make life easy for them :-)

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Old 25-02-2018, 08:31   #8
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Re: Life jackets cannot be in closets?

Quote:
Originally Posted by jsc7 View Post
I found the regulation (33 CFR 175.19) and it says that the life jackets must be "readily accessible", so there is some ambiguity about what that means. Apparently the CG considers life jackets in closets to not be "readily accessible".
I think it really depends on where the closet is located and how accessible it is. We have 2 closets, one in the V-berth that is behind the forward cabin door if it is open. Another in the quarter berth, that can be opened from outside the quarter berth if the door is open. Under normal circumstances, I would consider the v-berth closet to not meet the requirements of accessible while the quarter berth closet would be accessible.

All this rule really does, is codify good safety practices. All safety equipment needs to be easily accessed because you won't have time to dig through lockers to find that ratty moldy orange life jacket in an emergency.
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Old 25-02-2018, 08:36   #9
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Re: Life jackets cannot be in closets?

"Readily Accessible" means NOT behind closed doors, hatches, cabinets or buried under other "Stuff". It mean's it must be out, visible and at hand at all times. If it's behind a door or hatch, it is accessible, but NOT readily accessible. Readily Accessible means it must be Visible.

I always have enough life jackets on deck and in the cockpit for all on board... at all times, Even at anchor. Only at the dock are the life jackets stowed in the lazzerette. You could also have them out in the salon, quarter berth, etc, as long as they are easily at hand and plainly visible.

The Clark County building department (Vegas baby) once long ago taught me the meaning of the words "Readily Accessible". It's a well defined term with little ambiguity.
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Old 25-02-2018, 08:38   #10
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Re: Life jackets cannot be in closets?

Quote:
Originally Posted by jsc7 View Post
"in locked or closed compartments."
Im not so sure
certainly not locked, is that what theyre getting at?
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Old 25-02-2018, 08:39   #11
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Re: Life jackets cannot be in closets?

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Originally Posted by sailorchic34 View Post
"Readily Accessible" means NOT behind closed doors, hatches, cabinets or buried under other "Stuff". It mean's it must be out, visible and at hand at all times. If it's behind a door or hatch, it is accessible, but NOT readily accessible. Readily Accessible means it must be Visible.

I always have enough life jackets on deck and in the cockpit for all on board... at all times, Even at anchor. Only at the dock are the life jackets stowed in the lazzerette. You could also have them out in the salon, quarter berth, etc, as long as they are easily at hand and plainly visible.

The Clark County building department (Vegas baby) once long ago taught me the meaning of the words "Readily Accessible". It's a well defined term with little ambiguity.
ok then
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Old 25-02-2018, 08:54   #12
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Re: Life jackets cannot be in closets?

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Originally Posted by sailorchic34 View Post
"Readily Accessible" means NOT behind closed doors, hatches, cabinets or buried under other "Stuff". It mean's it must be out, visible and at hand at all times. If it's behind a door or hatch, it is accessible, but NOT readily accessible. Readily Accessible means it must be Visible.

I always have enough life jackets on deck and in the cockpit for all on board... at all times, Even at anchor. Only at the dock are the life jackets stowed in the lazzerette. You could also have them out in the salon, quarter berth, etc, as long as they are easily at hand and plainly visible.

The Clark County building department (Vegas baby) once long ago taught me the meaning of the words "Readily Accessible". It's a well defined term with little ambiguity.
Best answer.
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Old 25-02-2018, 08:58   #13
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Re: Life jackets cannot be in closets?

As the RNLI say, "Useless unless worn". End of.
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Old 25-02-2018, 09:17   #14
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Re: Life jackets cannot be in closets?

We have and almost always wear auto-inflatables, but also have two or more conventional lifejackets aboard. In a small boat, just about all storage spots are "accessable". So we are meeting both the letter and the spirit of the law.

I would hope that common sense prevails; if a life jacket isn't readily to hand in a visible location, it's not really doing you any good.

I do know that commercial boats have life jackets stowed in various places, but there's always obvious signage saying that life-jackets are here. Maybe the same thing could apply - if you have life jackets in a closet, have a big-ass sign on that closet saying LIFE JACKETS?
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Old 25-02-2018, 09:27   #15
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Re: Life jackets cannot be in closets?

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Originally Posted by jsc7 View Post
I was reading US Coast Guard guidelines and it reads that life jackets "should not be stowed in plastic bags, in locked or closed compartments, or have other gear stowed on top of them."

Is this is an actual regulation or just advice? Often when I see the word "should" in federal documents, it means it is not an actual regulation.

If it is a regulation, the "closed compartment" language would seem to ban stowing life jackets in a closet.

If this is a real regulation, what is the CFR number?
The lifejackets can be stored in plastic bags and can be stored in a closet or locker. Mine are in a locker (no lock) and are stored in a air tight, dry plastic clear bags and are easily accessible. On the door I have a label indicating "lifejackets". I was an inspector for Canadian Coast Guard Auxiliary. Now for the inflatables, they are "extras" and do not count for minimum equipment list.
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