Development of Harmonized North American Life Jacket Standards
The development of harmonized North American life jacket standards led by Brandi Baldwin in the Lifesaving & Fire Safety Division at the Office of Design & Engineering Standards is a crucial regulatory process. It involves regulatory progress, standards development, consensus processes, and ongoing efforts to enhance safety through the adoption of new industry standards and reforms in life jacket labeling. The journey includes various milestones such as the resolution of comments, public comment periods, rulemaking processes, and the establishment of bi-national standards to ensure the highest level of safety for life jacket users in North America.
- Regulatory progress
- Standards development
- Life jacket safety
- North American standards
- Brandi Baldwin
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Presentation Transcript
Development of Harmonized North American Life Jacket Standards Brandi Baldwin Lifesaving & Fire Safety Divison Office of Design & Engineering Standards
Resolution 2009-83-1 Regulatory Progress Standards Development Progress Provisional Timelines PFD Label Reform Questions
Regulatory Process Notice of Proposed Rulemaking (NPRM) What we want to do What impact we think it will have Public comment period Resolution of comments Final Rule (FR) Must address all comments Logical outgrowth/sufficient notice
Regulatory Progress Aug/2013: NPRM to remove Type Codes Comment deadline: 15-Oct Final Rule imminent Next steps: NPRM to adopt new and revised industry standards Public comment period Final rule Standards must be published first 2-5 years from publication of new standards to final rule
Standards Process The Consensus Process Proposal development TG or individual Preliminary Review (comments only) Resolution of Comments Balloting for consensus 50% votes returned, 2/3 of those positive Resolution of Comments & No votes Recirculation Consensus is slow and iterative
Standards Under Development Harmonized standard (UL 12402) Reorganization of Task Group Withdraw previous proposal New Prelim anticipated after PFDMA Tentative publication early 2015 Label Reform (UL 1123, 1180, 12402) 1123 (inherent) proposal gained consensus 1180 (inflatable) comments under review 12402 (harmonized) proposal review by TG
Standards Under Development Think Safe Reform Merge with Wise Choice Safe Choice Magic decoder for new label format Proposal stage Prelim after PFDMA Follow-Up standards (UL 9595) Resolving comments from Prelim Entering ballot after PFDMA Throwables TG proposal stage
Standards Development Bi-National Standards CAN/ANSI/UL 12402 CAN/ANSI/UL 9595 CAN/ANSI/UL 1180 Task Groups formed/expanded Canadian stakeholders More non-industry voices TGs meeting at PFDMA (June 11)
Provisional Timeline Spring 2015? Standards get published USCG initiates regulatory action USCG can approve any PFDs that are currently approvable, using the new standard. Labels will change on all new product Mid-late 2015 PFDs with new labels available on the market
Provisional Timeline (contd) 2018ish USCG can approve new PFDs Youth inflatables (age 16 and over) Level 50 inherent (15 lb minimum buoyancy) Level 50&70 inflatables (33 lb minimum buoyancy) 2025 or later PFD with old labels become non-serviceable
Where can I use it? The icons denote the area where the lifejacket is appropriate. The numbers are the tie to the ISO (international) standard. Do they add confusion? Calm water, rescue close at hand Enough confusion to sacrifice this element of harmonization with European (CE marked) devices? Off-shore Near shore
How much does it float? Do the numbers printed below the arrows add clarity or confusion? What about device which are not currently available? (eg Level 275) Uninflated performance for hybrids & inflatables
Does it Turn? Which graphic do you prefer? Are the words helpful or confusing?
Activities PWCs & Towed Sports The approval for PWCs and towed sports will always come together (either all yes or all no). Should we use both, or develop a single icon that denotes all activities? Which devices should have the icon? Only where PWC/tow is prohibited, Only where PWC/tow is allowed, All should indicate if PWC/tow is allowed or prohibited.
Activities Other Inflatables: not approved for whitewater paddling Develop an icon? Which ones get marked? Allowed, Not Allowed, or All? Intended uses Perception of legality vs appropriateness Optional labels/icons Should they be standardized? Who develops/maintains them? Enforcement implications?
Anything else? This is pretty much last call Once the standard is approved, manufacturers will start redesigning existing labels. We do not want to make this transition more than once. Volunteers are welcome on all TGs
