New USCG requirements for PFDs

[sailingharry]

Most of you have probably heard rumblings of changes to the US standard for PFDs. Going from Type 1-5 to a more international standard. One priority was to harmonize US and Canada, being that we are so close.


There is like ZILCH in useful information out there. While "Type" standards will cover us for years to come, I'd like to know what the actual new requirements are. I googled six ways to Sunday, and can't find details.

This one article is pretty good: https://blog.dockwa.com/new-uscg-lif...fications-2025
It's by Dockwa, which makes me barf, but it's still pretty good. EXCEPT (if you take the article as gospel):
* A Level 50 is only good if worn. And only good for "specialized activity" which, for instance, does not include sailing a Laser. And certainly does not include riding on the ski boat before/after your turn to ski (even if worn, you need a Level 70 below). Problem is, the Interweb is full of marketing and story telling that indicates a Level 50 is awesome for dinghy sailing!
* A Level 70 is for inshore. It's not "legal" for coastal/offshore. Really? If the primary focus on PFD's (beyond wearing the one you like when needed) is to make sure you have one for everyone when the Gestapo comes knocking, then buying a mess of 70's because you sail the Chesapeake is a bad move because you can't take a weekend to Ocean City.
* Under the old system (Types), many inflatables were approved even if not worn (they had to be Type II or Type III, which rules out most harness style -- they are Type V, but I own a couple of Type II that do NOT have to be worn). Under the new rules, it appears that inflatables no longer count unless worn. Which means, you still need the requisite number of foam style (unless you are super fanatical about NEVER leaving the dock without it on).



* This link states (apparently incorrectly) that jackets below Level 70 (ie, a Level 50) are not approved. https://www.boatus.org/life-jackets

It sounds like what is supposed to make it easier makes it harder!


Anyone have a link to some sort of credible authority?
Law, here, still refers to "Types." https://www.ecfr.gov/current/title-3...-175/subpart-B
This link talks about Level 50 and 70 (and requires 50 to be worn) but provides little additional information https://www.ecfr.gov/current/title-4...ubpart-160.276

[PippaB]

From the USCG Engineering Office, seems actually somewhat old news:

PFD APPROVAL SERIES AND GENERAL GUIDANCE
COMMERCIAL PFDs / LIFEJACKETS
APPROVAL SERIES: 160.155, 160.176, and 160.255

APPROVAL GUIDANCE & INFORMATION:

SOLAS lifejackets are approved under approval series 160.155. SOLAS lifejackets must meet the minimum requirements for a Type I lifejacket AND the requirements in LSA Code 2.2 and MSC.81(70) Sec. 2.

Non-SOLAS lifejackets that rely on inherent buoyancy are approved under approval series 160.255. Non-SOLAS lifejackets that rely entirely on inherent buoyancy are classified as Level 100 PFDs and meet the requirements in ANSI/CAN/UL 12402-4.

Non-SOLAS lifejackets that reply fully or partially on inflation are approved under series 160.176. Non-SOLAS lifejackets that reply on inflation must meet the requirements in 46 CFR 160.176.

Commercial PFDs were previously approved under series 160.002, 160.005, and 160.055. The Coast Guard is no longer approving new PFDs under these series. However, PFDs approved under these series can continue to be manufactured during the validity period of their approval certificates. They can be used to meet carriage requirements on vessels in accordance with their labels as long as they are in good and serviceable condition.

Effective August 1, 2021, the USCG will accept Level 100 lifejackets complying with UL 12402-4 using inherently buoyant material, and tested according to UL 12402-9, as equivalent to life preservers meeting the requirements in 46 CFR 160.055. For more information on the adoption of ANSI/CAN/UL 12402-4, see ENG policy letter 02-21.

RECREATIONAL PFDs / BUOYANCY AIDS
APPROVAL SERIES: 160.264, 160.276

APPROVAL GUIDANCE & INFORMATION: Wearable PFDs are classified by performance level. Level 70 PFDs are approved under series 160.264 for inherently buoyant devices or 160.276 for fully or partially inflatable devices. Level 70 PFDs meet the requirements in ANSI/CAN/UL 12402-5 for a Level 70 PFD. All PFDs must be evaluated and tested by a Coast Guard recognized Laboratory. The recognized laboratory evaluates the product, conducts the necessary testing, certifies compliant devices, and conducts factory inspections. Almost all applications for Coast Guard approved PFDs should be submitted directly to the applicant’s chosen recognized laboratory.

The Coast Guard does not review the PFD design, construction, or performance; however, we will conduct a pre-approval review of any new or novel PFD prior to the manufacturer submission to the recognized laboratory. The purpose of the pre-approval review is to identify serious and obvious design problems and to determine if any special testing or coordination with the laboratory may be required.

As a condition of Coast Guard approval, manufacturers must comply with the recognized laboratory’s follow-up services production inspection program.

Recreational PFDs were previously approved under series 160.064, 160.076, and 160.077. The Coast Guard is no longer approving new PFDs under these series. However, PFD approved under these series can continue to be manufactured during the validity period of their approval certificates. They can be used to meet carriage requirements on vessels in accordance with their labels as long as they are in good and serviceable condition.

Effective August 1, 2018, the Coast Guard now accepts level 70 PFDs complying with ANSI/CAN/UL 12402-5 and tested according to ANS/CAN/UL12402-9, and will issue USCG approval to those devices. Please see ENG policy letter 02-18.

The 2018 Engineering Letter. In a large part this seems to move PFD approval to UL, and relies on standardization there.

Unfortunately, they do not seem to be working too quickly on this part, because all their consumer facing literature still refers to type:

Note: The Coast Guard is working with the PFD community to revise the classification and labeling of PFDs. When completed, this information will be updated and hopefully be somewhat easier to understand. Meanwhile, spending a few minutes to understand the many options available to find a PFD that you’re willing to wear could mean the difference between life and death for you or a loved one.

[sailingharry]

My frustration is the lack of clarity. Under the old system, it was moderately clear (still had craziness about "not in the zippered package, but OK tossed in a locker").


The long, very well written, but perhaps very wrong article on the Dockwa site, written by the credible NauticEd, demonstrates how unclear it is. The article appears to incorrectly state:
* Level 50 cannot be worn to comply on a Laser (or any other boat besides a kayak).
* Level 70 does not meet carriage requirements for coastal or offshore sailing.
* No new inflatable PFD will meet carriage requirements (unless worn).


The info you provided appears to be 100% focused on commercial boats, so may not apply.


While Level 100 are acceptable for commercial use, they do not appear to be sold in the US.

[GordMay]

"Understanding NEW Changes in PFD Regulations” ~ by Mustang Survival, June 02, 2025
➥ https://mustangsurvival.ca/blogs/res...fd-regulations

“Everything You Need to Know About Personal Flotation Devices (PFDs): Types, Benefits & Applications” ~ by Mustang Survival, May 21, 2025
➥ https://mustangsurvival.com/blogs/ne...verning-bodies

[PippaB]

The second section of the information posted is on recreational vessels. It does state the equivalence of Level 70 with the carriage requirements for US recreational vessels.

What it does not address is Level 50, that seems to be covered in the CFR under the "incorporation by reference" of ANSI/CAN/UL 12402-5:2022. So, it would seem that the real "regulations" are now buried behind a UL paywall rather than being in CFR/USCG documents.

One more source:

Lifejacket Approval Harmonization; Final Rule
Dec. 13, 2024 | By Jacqueline Yurkovich (CG-ENG-4)

With this rulemaking (Docket No. USCG-2022-0120) we are incorporating the American National Standards Institute (ANSI) standards ANSI/CAN/UL 12402-5 for Level 50 and Level 70 personal flotation devices (PFDs), ANSI/CAN/UL 12402-4 for Level 100 PFDs, and ANSI/CAN/UL 9595 for quality assurance. In addition, we are incorporating the ANSI/UL 1123 and ANSI/UL 1175 standards for marine buoyant devices and inherently buoyant and inflatable throwable PFDs, respectively. The rule is effective on January 6, 2025.

When this rule becomes effective, manufacturers of Coast Guard approved lifejackets and PFDs will be able to seek Coast Guard approval of Level 50 and Level 70 buoyancy aids (approval series 160.264 and 160.276) and Level 100 lifejackets (approval series 160.255). Because the incorporated standards are adopted in the US and Canada, these devices meet carriage requirements in both the US and Canada.

The rule does not affect currently approved equipment. Manufacturers may continue to manufacture all approved PFDs in accordance with their follow-up program. PFDs under approval series 160.055, 160.064, 160.076, and 160.077 may continue to be manufactured, sold, and used to meet carriage requirements. However, no new approvals will be issued under these approval series.

A Small Entity Compliance Guide about these new approval requirements is at— Small Entity Compliance Guide.

Another policy letter from 2018 USCG-2018-0565-0004_content.pdf source:

In 2015, UL 12402-5 and UL 12402-9 were published as bi-national standards in the United States and Canada. UL 12402-5 sets forth requirements for PFDs intended for use close to shore or where rescue would be imminent. Typically, these devices are used by occupants on recreational boats.
Within UL 12402-5, there are two levels of performance, Level 50 and Level 70.4 A Level 70 PFD provides an equivalent in-water performance to a Type III PFD currently approved under approval series 160.064. A Level 50 PFD provides a reduced level of performance. UL 12402-9 sets forth the test methods for determining compliance.

And finally, after much digging, the final rule from USCG, which covers most of the questions.

Additionally, the Coast Guard expects that the introduction of Level 50 devices, coupled with the requirement to wear them if they are to count for the purposes of PFD carriage requirements, will lead to an unquantifiable increase in PFD wear rates among recreational boaters, and thereby potentially decrease the rate of drowning in the event of an accident. Only Coast Guard approved devices are eligible to count for PFD carriage requirements, and, for Level 50 devices to count, they must be worn. The Coast Guard therefore expects that recreational boaters purchasing Level 50 PFDs for the purposes of carriage are more likely to wear them. Drowning is the leading cause of death in recreational boating accident and a study of drowning incidents found that, 86 percent of the time, individuals who drowned were not wearing a PFD.[20]

Absent these regulations, Level 50 devices cannot be sold as Coast Guard approved devices, and the expected increase in PFD wear rates among recreational boaters will not materialize.

...

Since the Level 50 devices provide a lower level of buoyancy than Level 70 devices, a direct comparison is not possible. However, the view of the subject matter experts (SMEs) in the Coast Guard's Office of Boating Safety is that the wearing of Level 50 PFDs by recreational boaters and the general boating public improves safety on the water. Recreational boaters fail to wear lifejackets 76 percent of the time, leaving themselves vulnerable to drowning. The Coast Guard believes that, by offering recreational boaters an additional choice of a Level 50 PFD, which is required to be worn, more recreational boaters will choose to wear their lifejacket while engaged in boating activities. A lifejacket that is worn by the user is more effective than a lifejacket stowed on the boat.

IOW, if we can get them to wear something, that is better than a lifejacket in a locker, even if what they wear does not meet the old standards for flotation, etc.

What is interesting is that the UL standards are all for "near shore" use, and what happens for those of us who venture far offshore? I am guessing SOLAS/Level 100?

[Lady_C]

Originally Posted by PippaB

What is interesting is that the UL standards are all for "near shore" use, and what happens for those of us who venture far offshore? I am guessing SOLAS/Level 100?

in France :
50 N up to 2 milles. ISO 12402-5 CE
100 N up to 6 milles. ISO 12402-4 CE
150 N after. ISO 12402-3 CE
275 N in extreme conditions. ISO 12402-2 CE
100 N for children
to adapt according size and weight

[sailingharry]

Originally Posted by PippaB

IOW, if we can get them to wear something, that is better than a lifejacket in a locker, even if what they wear does not meet the old standards for flotation, etc.

This is a worthy thought. Personally, I don't agree with their logic. In my personal view (different than anyone else's), a jacket that doesn't count if not worn doesn't count. I won't constrain myself to wearing it 100.00% of the time, so I can't be legal. Is carriage an issue at anchor, so it has to be worn an anchor? Even if I'm a strong proponent of wearing, will I ever take it off on a hot calm day when drift fishing? Etc. I want my carriage requirement to be met with no user thought. So my nice inflatable harnesses aren't in my personal count.

Originally Posted by PippaB

What is interesting is that the UL standards are all for "near shore" use, and what happens for those of us who venture far offshore? I am guessing SOLAS/Level 100?

Yes, this is very troubling. And again, if my primary reason for having PFDs is compliance, I want to be sure that the jackets I buy for the next 2 years will work 3 years from now when I do a DELMARVA circumnavigation. So if 70 is not compliant, I will buy only 100 -- and then under the USCG thoughts, be LESS likely to wear them! LOL.


To be clear, when I say "my primary reason..." I don't mean I am anti-jacket, or never wear them. But rarely do I count the number of jackets aboard for "safety" reasons. Much of my boating, I can swim to shore. But, for instance, my dink has 2 jackets permanently stored aboard (so I never think about them), but if I go to another boat 200 yards away to pick up dinner guests, I ensure that I have more jackets aboard -- not because I fear a horrible boating accident in the anchorage, but so I don't get ticketed (happened to a friend last year, taking two boaters from shore to their boat).

[sailingharry]

Originally Posted by Lady_C

in France :
50 N up to 2 milles. ISO 12402-5 CE
100 N up to 6 milles. ISO 12402-4 CE
150 N after. ISO 12402-3 CE
275 N in extreme conditions. ISO 12402-2 CE
100 N for children
to adapt according size and weight

UGH!

So, if you occasionally go more than 6 miles offshore, you are required (when that far out) to have 150N for each person. So that means you buy and store 150N for the number you are likely to have aboard that far out. So then, unless you buy another set of jackets for actual use, your only jackets to offer an uneasy guest is a 150N.

Then, when "extreme" conditions arise, you are suddenly illegal with your 150N!

And "extreme" is a problem -- lots of us won't go out until at least Small Craft Warnings! LOL. But seriously, I enjoy sailing in conditions others are appalled at -- there is a LOT of variation in understanding what is "extreme."

Interesting tangent. Here in the US, "most" law is publicly available. It's published in the Code of Federal Regulations (CFR) and can be easily found by Google. I tried to look up ISO 12402-2 CE to see if it defines "extreme" and, well, I don't feel like paying for the information. Is that normal in EU? Where the laws are hidden behind a paywall? How does one comply?

[Lady_C]

Originally Posted by sailingharry

UGH!

So, if you occasionally go more than 6 miles offshore, you are required (when that far out) to have 150N for each person. So that means you buy and store 150N for the number you are likely to have aboard that far out. So then, unless you buy another set of jackets for actual use, your only jackets to offer an uneasy guest is a 150N.

Then, when "extreme" conditions arise, you are suddenly illegal with your 150N!

And "extreme" is a problem -- lots of us won't go out until at least Small Craft Warnings! LOL. But seriously, I enjoy sailing in conditions others are appalled at -- there is a LOT of variation in understanding what is "extreme."

Interesting tangent. Here in the US, "most" law is publicly available. It's published in the Code of Federal Regulations (CFR) and can be easily found by Google. I tried to look up ISO 12402-2 CE to see if it defines "extreme" and, well, I don't feel like paying for the information. Is that normal in EU? Where the laws are hidden behind a paywall? How does one comply?

ISO are international.
C.E. or USA, you must pay to have the rules.

https://www.shopulstandards.com/Prod...ctId=UL12402-5
also not free !

but it's possible to find without paying, when someone breaks the Non-Disclosure-Agreement
A draft is available https://cdn.standards.iteh.ai/samples/60334/658494eb25ad4ad8a83a7ff02d4654a8/ISO-12402-2-2020.pdf

PFD are linked to the boat category (waves and wind) and to your certification.
boats up to 2 milles
boats up to 6 milles
boats more than 6 milles.
if your certification allows more than 6 milles, purchase 150 N :-)
if you plan circum navigation around the South Pole, purchase 275 N.

[sailingharry]

Originally Posted by Lady_C

ISO are international.
C.E. or USA, you must pay to have the rules.

but it's possible to find without paying, when someone breaks the Non-Disclosure-Agreement
A draft is available https://cdn.standards.iteh.ai/samples/60334/658494eb25ad4ad8a83a7ff02d4654a8/ISO-12402-2-2020.pdf

PFD are linked to the boat category (waves and wind) and to your certification.
boats up to 2 milles
boats up to 6 milles
boats more than 6 milles.
if your certification allows more than 6 milles, purchase 150 N :-)
if you plan circum navigation around the South Pole, purchase 275 N.

Ah, OK. The ISO standard is not "law." Yes, it applies here in the US, and is sort of law. The law says "must meet these standards." While it is useful to know the standard and what goes into it, you really don't need to know to comply. The law says "Level 100" and all you need to know is that the tag on the jacket says "Level 100." You don't need to know the denier of the fabric, for instance (if that's even covered -- I just made that up).


ISO (at least the one you linked) does not require carriage at all, and does not state which one must be carried when/where. That's the same thing here, generally. Under the old rules, a "Type III" was defined and established (by UL, I assume?) and a user simply knew that a Type III was required for everyone aboard (that was "fairly clearly" defined in CFR).


I said "fairly clearly" because I hate the unwritten, unpublished, locally established "defacto law." Find in an authoritative document where a throwable 6 feet from the operator does not meet the requirement for "immediately available." There are anecdotes where a throwable hanging on the front of a center-console pedestal was considered unacceptable.

[rslifkin]

Originally Posted by sailingharry

UGH!

So, if you occasionally go more than 6 miles offshore, you are required (when that far out) to have 150N for each person. So that means you buy and store 150N for the number you are likely to have aboard that far out. So then, unless you buy another set of jackets for actual use, your only jackets to offer an uneasy guest is a 150N.

Then, when "extreme" conditions arise, you are suddenly illegal with your 150N!

And "extreme" is a problem -- lots of us won't go out until at least Small Craft Warnings! LOL. But seriously, I enjoy sailing in conditions others are appalled at -- there is a LOT of variation in understanding what is "extreme."

Interesting tangent. Here in the US, "most" law is publicly available. It's published in the Code of Federal Regulations (CFR) and can be easily found by Google. I tried to look up ISO 12402-2 CE to see if it defines "extreme" and, well, I don't feel like paying for the information. Is that normal in EU? Where the laws are hidden behind a paywall? How does one comply?

Depending on how many PFDs you carry it may not be a big pain to carry multiple types. We already carry ski vest types for use in the dinghy and to have enough for guests, inflatables for when we want to wear one on the mothership, etc. Splitting up the ski vest types into 2 different types wouldn't be a big deal I think.

[sailingharry]

Originally Posted by rslifkin

Depending on how many PFDs you carry it may not be a big pain to carry multiple types. We already carry ski vest types for use in the dinghy and to have enough for guests, inflatables for when we want to wear one on the mothership, etc. Splitting up the ski vest types into 2 different types wouldn't be a big deal I think.

But it's not "splitting them." True, I'm much more likely to have 8 folks on board in the Chesapeake than on a trip to New England, so I could have say 4 Level 275 (a few years ago, I had a rip-roaring trip down the NJ coast in gusts to 40 and seas to 8' -- is that "extreme?). Then 4 more 70 (or maybe 100?) to cover the fireworks cruise.


Of course, the "readily available rule" as interpreted by the Gestapo means you have to dig out those 275's, which may be large and hard to have "readily available."


Yes, we keep vests in the dink permanently, and we have the harnesses (that don't count, but are the ones WE think of as our "go to").

[sailingharry]

A slight aside on inflatables. I have an ancient float coat. A friend gave it to me. I've inspected and inflated and all that, so even though it's old it's good. It is a "jacket," a very comfortable waist length lined windbreaker. Inside it is an inflatable bladder (manual only), not unlike our harness or what comes on an airplane. It is truly my go-to. I wear it a lot. It's comfy, warm, rainproof -- and you forget it is a PFD. It's not USCG (not even Type-V), but who cares. The question -- has anyone ever seen anything like this? I'd love to buy one that was made in this century!

[rslifkin]

Originally Posted by sailingharry

But it's not "splitting them." True, I'm much more likely to have 8 folks on board in the Chesapeake than on a trip to New England, so I could have say 4 Level 275 (a few years ago, I had a rip-roaring trip down the NJ coast in gusts to 40 and seas to 8' -- is that "extreme?). Then 4 more 70 (or maybe 100?) to cover the fireworks cruise.


Of course, the "readily available rule" as interpreted by the Gestapo means you have to dig out those 275's, which may be large and hard to have "readily available."


Yes, we keep vests in the dink permanently, and we have the harnesses (that don't count, but are the ones WE think of as our "go to").

That's exactly what I was thinking. The most people we may possibly take out for a day is more than the most we'd ever have on board while traveling or in rough conditions. And some of the light weather / near shore vests are also the ones we throw in the dinghy when we use it.

Readily available is a tough one, but we've settled on splitting our vests between one of the hanging lockers below and under one of the seats on deck. None take more than a few seconds to access, and they're readily accessible in 2 different parts of the boat. I figure that should be good enough to satisfy all but the most picky.

[Shrew]

Originally Posted by sailingharry

as interpreted by the Gestapo

That's the same gestapo reference twice in a matter of 5 posts. Tell us your an anti-authoritarian without telling us you're an anti-authoritarian.

You understand the laws were passed due to repeated drownings right? This is not a means to oppress you. This is an attempt to reduces recoveries and increase rescues.

Curiosity is one thing, but you're banging the "gavel of righteousness" about literally nothing. Buy decent PFD's and enjoy the experience.