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Old 25-02-2018, 11:37   #31
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Re: Life jackets cannot be in closets?

Life jackets are hell on bikini tan lines, aren't they?

I'm comfortable in the water, more so below it than on the surface, but I still respect it. I know how easy it can be to drown, so I never had a problem with wearing life jackets, and bought my inflatable PFD before there were any USCG certifications for inflatables. I figured, since the president wears the same type of thing when flying on MarineOne, it probably works well enough for me, no matter what the USCG thinks.

I don't preach or argue about PFDs, I just try to lead by example. If I'm heading out by launch, it usually is in my daypack, and one day I said to myself "Wouldn't I feel like a fool if I went overboard and my PFD was safely drifting away in my pack?" I'm also used to arguments from kids "I don't want to wear that, no one else is wearing that" so if there are any on the launch...I make sure to put mine on, so it no longer is a stygma to them.

Same thing in the boat. We used to keep a couple of comfortable Type3 zippered vests and just zip them over the stern rails or lifelines so they were "readily" available in the cockpit, while doubling as cockpit cushions. (The inflatables worn but still not legal for anything back then.) Any idiot, ergh, earnest public servant, who wanted to check for life vests could see them without boarding.

And then of course there's the old old life vest that lives in the bottom of the lazarette. Makes a great knee pad when you're down there working on something. Keeps the spare anchor from rattling around. I'd never keep it in a "closet".(G)
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Old 25-02-2018, 11:38   #32
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Re: Life jackets cannot be in closets?

Absolutely
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Old 25-02-2018, 11:43   #33
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Re: Life jackets cannot be in closets?

The term “Readily Assessable” implies that the item can be obtained with minimal effort. It does not mean that your life jacket must be stacked on the salon table or lying on the cockpit seats or all to see, nor does it mean that they must be personally handed to every guest or crewmember that boards. Mine are stowed in two places; in a top-loading compartment in the salon with a loose-fitting top that is simply lifted off and in an unlockable cabinet in the forward cabin immediately inside the cabin door. Both can be accessed with one hand and both are marked with large identifying signs which state the number and type of PFDs therein (Adult or Child). The same with fire extinguishers.

As an aside, the FAA requires that aircraft life jackets be in a sealed plastic bags, whereas the US Coast Guard will admonish you if you leave PFDs in even unsealed protective coverings. I guess the USCG would prefer that your PFDs become soiled, punctured, worn and torn form storage and from being played with by kids so they you will have buy new ones to aid the marine supply industry.

I can’t speak to the rights of citizens of other countries but in the US only the United States Coast Guard has the authority to board a US flag vessel without probably cause, not water cops, local police or anyone else claiming authority. Local authorities in some states may have this power for state registered boats. If both state registered and US documented, who knows?

Some water cops know this, my guess is the majority either don’t know or don’t care but I have had them approach (intent on boarding) but turn away when noticing or asking if my boat was documented.
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Old 25-02-2018, 11:47   #34
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Re: Life jackets cannot be in closets?

Quote:
Originally Posted by sailorchic34 View Post
See the link I posted a bit higher at the end of my last post. Also here-->Life Jacket Wear / Wearing your Life Jacket

Scroll down to accessibility...

From what I've read elsewhere, if the lazzerette is lockable, then, even if it's not locked, it does not meet the intent.

Commercial vessels are under a completely different code and in addition are coast guard inspected and and crewed by well trained people.

Generally Recreational vessels are not inspected, which is why they have different requirements.

"Readily accessible" , means not behind an obstruction. That obstruction may be a closed door or hatch. It need not be locked either, Just a door or hatch, you have to open. It's accessible, just not readily accessible.

Believe me I had a similar discussion about the definition of "readily accessible" with the fine folks at clark county building department.
The building department is also different! I've enjoyed similar discussions, I'm sure.

A code link or letter of interpretation (anyone?) is needed to settle this. The link you gave says "should," which as you know is not "will" or "shall."

I've never had a lockable lazerette, so that is a non-concern for me.
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Old 25-02-2018, 11:54   #35
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Re: Life jackets cannot be in closets?

Quote:
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.
If you have ever been on a ferry or passenger boat, even a charter fishing boat, you will notice a container OR locker that is labeled "LIFE VESTS" along with the quantity. As long as the locker they are stowed in is NOT lockable, they can be stowed in a locker.

Here are the rules for commercial vessels , Pleasure vessels are not as stringent.

§ 117.78 Stowage of life jackets.
(a)General. Unless otherwise stated in this section, life jackets must be stored in convenient places distributed throughout accommodation spaces.

(1) Each stowage container for life jackets must not be capable of being locked. If practicable, the container must be designed to allow the life jackets to float free.

(2) Each life jacket kept in a stowage container must be readily available.

(3) Each life jacket stowed overhead must be supported in a manner that allows quick release for distribution.

(4) If life jackets are stowed more than 2,130 millimeters (7 feet) above the deck, a means for quick release must be provided and must be capable of operation by a person standing on the deck.

(5) Each child size life jacket must be stowed in a location that is appropriately marked and separated from adult life jackets so the child size life jackets are not mistaken for adult life jackets.

(b)Additional personal flotation devices. The stowage locations of the personal flotation devices carried in addition to life jackets under § 117.72 must be separate from the life jackets, and such as not to be easily confused with that of the life jackets.

M
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Old 25-02-2018, 12:04   #36
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Re: Life jackets cannot be in closets?

I read the CFR reference; no clarification there.

The best I have found is this less formal USCG reference (Life Jacket Wear / Wearing your Life Jacket)

Lifejackets must be
  • Coast Guard approved,
  • in good and serviceable condition, and
  • the appropriate size for the intended user.
Accessibility
  • Wearable lifejackets must be readily accessible.
  • You must be able to put them on in a reasonable amount of time in an emergency (vessel sinking, on fire, etc.).
  • They should not be stowed in plastic bags, in locked or closed compartments or have other gear stowed on top of them.
Notice the difference between the use of must and should. In a government document, these words are not synonyms. This is puzzling, though, because surely, they must not be in a locked compartment. But if that were the case, they should have said must, but in doc after doc, it says you must have the PFDs, they must be accessible, and the should not be in bags. This is not coincidence or slopping writing, this is an intentional effort to leave room for judgment. That is the only rational conclusion, from the evidence. That said, the judgment of the inspector may vary... like the building department example.
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Old 25-02-2018, 12:04   #37
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Re: Life jackets cannot be in closets?

About 20 years ago I was boarded by the US Coast Guard for a safety inspection. Things change and as time moves on additional regulations become more restrictive so take this with a grain of salt. My life jackets were stored in a Life jacket case which was kept in a cabinet in the saloon. It was suggested that a couple of jackets be put in the lazerette where it would be convenient to reach from the cockpit. There were 2 of us aboard at the time.
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Old 25-02-2018, 12:33   #38
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Re: Life jackets cannot be in closets?

Quote: "This is puzzling, though,...This is not coincidence or slopping writing, this is an intentional effort to leave room for judgment."

To observations:

1) Why would you expect greater than normal command of English from the drafter, or indeed from the proof-reader of Government pamphlets? IMO that stretches credulity. Confounding "should" and "must" is a common if inexcusable error.

2) That the drafters of these sorts of publications (and their proof-readers) should be under orders to "leave room for judgement" by the functionaries on the pointy end also stretches credulity. Given the nature and the interests of the chaps on the pointy end, there would be benefit for them as well as for the public in phrasing publication for the guidance of the public clearly and unambiguously. Given that the day will never come when that will be the case, we are all better off by just accepting that FIRST you come in compliance, interpreting "should" as "must", and THEREAFTER we, as skippers, do what is necessary to ensure the safety of the crew. And, as we all know, we cannot do that, unless we first ensure the safety of the vessel we command.

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Old 25-02-2018, 12:37   #39
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Re: Life jackets cannot be in closets?

On one boat I owned, The life jackets where held against the headlining with bungee restrained netting, visible, accessible and minimal chance of damage.
Liferafts are equally important, should be able to be launched in less than 30 seconds by a single crew member, and tethered to the boat when launched.
The RORC rules are as good a commonsense checklist as one can find.
http://www.rorc.org/downloads/images...st_2016_V2.pdf
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Old 25-02-2018, 12:58   #40
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Re: Life jackets cannot be in closets?

[QUOTE=TrentePieds;2585240To observations:

1) Why would you expect greater than normal command of English from the drafter, or indeed from the proof-reader of Government pamphlets? IMO that stretches credulity. Confounding "should" and "must" is a common if inexcusable error.

2) That the drafters of these sorts of publications (and their proof-readers) should be under orders to "leave room for judgement" by the functionaries on the pointy end also stretches credulity....

TP[/QUOTE]

Having worked with US agencies on regulatory matters, I stand by what I said. This is EXACTLY how they think. Leaving ambiguity is another way of passing the buck.
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Old 25-02-2018, 13:01   #41
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Re: Life jackets cannot be in closets?

We have, I think, a couple Mae Westy type lifejackets buried somewhere or other for potential guests, who I try to dissuade anyway after my sister, my step sister, and her friend continued to vomit the entire times they were aboard. Seafaring guests I ask to bring their own. We have 3 manual inflating with harnesses on board which we wear a lot, but are in the wet locker just inside the companionway, and we have 2 belt type manual inflating life vests that we always wear when in the tender.
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Old 25-02-2018, 13:09   #42
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Re: Life jackets cannot be in closets?

Quote:
Originally Posted by TrentePieds View Post
Quote: "This is puzzling, though,...This is not coincidence or slopping writing, this is an intentional effort to leave room for judgment."

To observations:

1) Why would you expect greater than normal command of English from the drafter, or indeed from the proof-reader of Government pamphlets? IMO that stretches credulity. Confounding "should" and "must" is a common if inexcusable error.

2) That the drafters of these sorts of publications (and their proof-readers) should be under orders to "leave room for judgement" by the functionaries on the pointy end also stretches credulity. Given the nature and the interests of the chaps on the pointy end, there would be benefit for them as well as for the public in phrasing publication for the guidance of the public clearly and unambiguously. Given that the day will never come when that will be the case, we are all better off by just accepting that FIRST you come in compliance, interpreting "should" as "must", and THEREAFTER we, as skippers, do what is necessary to ensure the safety of the crew. And, as we all know, we cannot do that, unless we first ensure the safety of the vessel we command.

TP
I disagree. In the highly litigious US, most of these type of things are created or checked by lawyers, and the difference between "must" and "should" is very clearly understood. I agree about the rest of your comments regarding bureaucracies, but not this.

On another note, I have four cabins. Each has two Type I jackets hanging very accessibly in its unlockable hanging locker. There are four more Type 1's in an unlockable cockpit locker, all quite accessible. There are two throwables, in addition, all ready to go. One has an MOB pole, and the other is a lifesling. These are additional to the inflatable ones that some of us actually use. Also readily accessible is a heaving line. I have been boarded many times by the USCG, including last year, and never have they uttered so much as a peep.
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Old 25-02-2018, 13:19   #43
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Re: Life jackets cannot be in closets?

Quote:
Originally Posted by jmschmidt View Post
The term “Readily Assessable” implies that the item can be obtained with minimal effort. It does not mean that your life jacket must be stacked on the salon table or lying on the cockpit seats or all to see, nor does it mean that they must be personally handed to every guest or crewmember that boards. Mine are stowed in two places; in a top-loading compartment in the salon with a loose-fitting top that is simply lifted off and in an unlockable cabinet in the forward cabin immediately inside the cabin door. Both can be accessed with one hand and both are marked with large identifying signs which state the number and type of PFDs therein (Adult or Child). The same with fire extinguishers.

As an aside, the FAA requires that aircraft life jackets be in a sealed plastic bags, whereas the US Coast Guard will admonish you if you leave PFDs in even unsealed protective coverings. I guess the USCG would prefer that your PFDs become soiled, punctured, worn and torn form storage and from being played with by kids so they you will have buy new ones to aid the marine supply industry.

I can’t speak to the rights of citizens of other countries but in the US only the United States Coast Guard has the authority to board a US flag vessel without probably cause, not water cops, local police or anyone else claiming authority. Local authorities in some states may have this power for state registered boats. If both state registered and US documented, who knows?

Some water cops know this, my guess is the majority either don’t know or don’t care but I have had them approach (intent on boarding) but turn away when noticing or asking if my boat was documented.
Sounds as if you have a hard-on for guys doing their job. I doubt the CG or local cops are out to cause a problem. Thank God they are there when needed or keeping idiots in check. If it floats they can board. I can see not problem with that.
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Old 25-02-2018, 13:30   #44
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Re: Life jackets cannot be in closets?

A small percentage of inflatable PFDs do not need to be worn to meet USCG requirements. They need certain features like an external arming gauge and that the PFD not have a tether clip. Most inflatables do not meet these requirements, there are other requirements I forget. You may also need to do some fast talking if a LEO not familiar with them boards.
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Old 25-02-2018, 13:45   #45
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Re: Life jackets cannot be in closets?

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Originally Posted by CFS Klopas View Post
A small percentage of inflatable PFDs do not need to be worn to meet USCG requirements. They need certain features like an external arming gauge and that the PFD not have a tether clip. Most inflatables do not meet these requirements, there are other requirements I forget. You may also need to do some fast talking if a LEO not familiar with them boards.
Unless something has changed? Inflatables are a nice to have but do not qualify as a PFD. Comfort for being on deck.
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