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june 2015 FOGHORN 21 LEGISLATIVEReport annual inspections by trained Coast Guard personnel. A commercial passenger vessel must provide a Personal Flotation Device PFD a life preserver for every person the vessel carries. In addition the vessel must carry survival craft of a type specified by the Coast Guard. There are different forms of survival craft. They include life floats inflatable buoyant apparatus and even traditional lifeboats. Over the years the Coast Guard has used an analysis of risk to specify the type and number of survival craft to be carried on a particular vessel. In 2010 Congress enacted a law that overrode the Coast Guards time-tested risk-based system for determining the appropriate type of survival craft on a passenger vessel. That law mandates that as of a specified date now set at February 2016 no survival craft can be approved for use unless it is designed in a way to keep all occupants from being exposed to water. The effect of this one-size-fits-all provision if not superseded will be to foreclose further use of life floats the type of survival craft currently carried by many PVA vessels especially those that operate in warm water close to shore or where third-party assistance is readily available. Given the excellent safety record of the U.S. passenger vessel industry PVA believes that Congress erred in enacting the 2010 mandate. Since that time PVA has been engaged in seeking legislative reconsideration. First PVA and its allies convinced Congress in 2012 to enact a law directing the Coast Guard to produce a study on the pros and cons of the out-of-water survival craft provision and delaying the original implemen- tation date for the 2010 law. The Coast Guards report delivered in August 2013 and entitled Survival Craft Safety declares Based on analysis of available casualty data carriage of out-of-water survival craft in place of life floats and buoyant apparatus is not anticipated to have a significant effect on vessel safety. The report further states .... the absence of fatalities attributed to type or number of survival craft since 1996 suggests that the Coast Guards risk- based regulations have provided adequate protection and does not support a compelling need for addi- tional requirements for out-of-water survival craft for these vessels. In other words the Coast Guard is saying that the U.S. passenger vessel industry has an excellent safety record that the current system of allowing certain vessels to carry life floats is effective and that there is no safety reason for requiring every MARINE GROUP B o a t w o r k s marinegroupbw.com leahmarinegroupbw.com 619 621-2220 Marine Group Boat Works is the newest California boatbuilder and repairer of steel and aluminum high-speed ferries catamarans and passenger vessels up to 665-tons. Operating two shifts six days per week for fast turnarounds and minimized vessel time out-of-service. New construction in steel aluminum and composite Hull modifications and extensions engine repowers Complete service life extension refits Complete USCG dry docking services USCG regulatory experts on staff ABSUSCG-certified welders