Ever been confused by the codes used to refer to different types of personal flotation devices ("PFD")? You know, the Type I, II and III PFD language that's thrown around in various Coast Guard literature? Apparently, you're not alone, or, at least that's what the Coast Guard wants you to believe.

In a recent Notice of Proposed Rulemaking, the Coast Guard proposes that, among other things, in connection with recreational vessels the codes be replaced with descriptive language. That is, the type codes would be boiled down to the descriptors "Wearable PFD" and "Throwable PFD." There are concerns, however, with dumbing-down these PFD descriptions. Firstly, is it really necessary? We haven't seen any formal evidence/testing/polling/statistics which show that the "type" references are causing confusion. Yes, vague reference is made to the "volume of inquiries" on this issue, but is word play the sort of thing the Coast Guard should be worrying? Good arguments exist that boat owners should be engaged enough in the weighty responsibility of vessel navigation to unravel the easily understood "type" descriptors. Morever, the descriptors provide seemingly good categorization of various PFD usages and capacities which will now be lost in the vagary of these broad descriptions.

For more information about these changes to PFD regulations, contact Proctor-in-Admiralty and licensed mariner, John K. Fulweiler, Esq. at 1-800-383-MAYDAY (6293). You can read the Notice of Proposed Rulemaking by clicking HERE.

Underway and making way.

--- Fulweiler llc

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