USCG Requirements Regarding Life Floats and Buoyant Apparatus

February 17, 2016

Congress has passed the Coast Guard Authorization Act of 2015 and the President has signed it into law. The Act as passed changes several components that went into Policy Letter 15-05 (below). It appears that prior to the requirements changing the Coast Guard needs to change the regulations in 46CFR (a policy letter will not suffice).

Confusing, you bet! Even the Coast Guard is confused but as of today I am told that the regulations have not changed for either commercial fishing or passenger carrying vessels.

If you have questions, give me a call at (253) 627-6000.

Rollie Herman


December 18, 2015 the USCG published Policy Letter 15-05 which outlines the requirements for “out of water” survival craft that go into effect February 26, 2016.

This letter covers phase in policies for all classes of vessels required to carry survival craft. I do not believe that it covers the changes voted on by the US Senate December 18, 2015 which if accepted by the House would make a difference to passenger carrying vessels.

The Coast Guard has tried to make a difficult subject simple with tables at the end of the document. There are still changes that need to made to the Code of Federal Regulations so I doubt this letter is the last word but it is an excellent start.

Inflatable Buoyant Apparatus News


Congress has just passed the 2012 Coast Guard and Marine Transportation Act and it includes one major change regarding the required transition from life floats to inflatable buoyant apparatus (IBA’s). Prior to this act all US Flag vessels that were required to carry life floats would have had to change to carrying IBA’s by January 1, 2015. This date has now been put on hold pending further data collection.

If you want to read the Coast Guard and Marine Transportation Act of 2012 the link will take you to the Library of Congress download. The section regarding IBA’s is on page 24.

I still feel that life floats are not an adequate piece of life saving equipment since they do not get victims out of the water. Hypothermia sets in rapidly and the consumption of alcohol worsens your chances (since many life floats are used on “party boats”, alcohol consumption is prevalent) of survival. The main reason life floats are so common is their cost. They are less expensive to purchase and do not require annual servicing like an IBA.

More on the tour boat Ethan Allen

In 2005 the tour boat Ethan Allen overturned on Lake George in New York causing  20 people to lose their lives. This tragedy spurred the government into a new regulation mandating life saving equipment that keeps the victims out of the water.

As of January 1, 2015 life floats like the one shown will no longer be allowed. [12/14/2012: the 1/1/15 deadline has been postponed, read our post from December 14th]


There are still lawsuits pending and it seems that one claiming damages against government inspectors has just been ruled on. Reading the comment from the National Transportation Safety Board it makes one realize that the government is not actively out there ensuring that vessels are safe for their passengers and crew. Budgets are strained and people’s lives have suffered.