Special Life Rafts for Training!

Here's a very interesting but little known fact about vessel safety equipment.

We all know that certain vessels are required by law to carry inflatable life rafts and/or other types of survival craft, e.g. lifeboats, rescue craft, etc. These life saving vessels must be inspected and certified every so many years, usually no more than two or three at the most in the case of inflatables. The cost for this inspection (and repacking of your life raft) depends on the capacity of the raft and whether or not it is SOLAS equipped. However, no matter what type of certification it has, no matter its size, repacking is expensive. In fact, for many mariners, particularly owners of small boats that are not required to carry survival craft, repacking and inspection costs are prohibitive.

Here's another thing. The equipment aboard every vessel, regardless of its type or classification, must be approved, inspected, certified, current and up to date and in operating condition. If you have aboard your vessel a broken radar, an expired fire extinguisher, outdated flares, or a life raft in need of inspection and repacking, your vessel is non-compliant.

But here's where a loophole in the Code of Federal Regulations might help you out and might save your life.

A section in CFR 199.180 Subpart B Page 462 (g5) states:

(5) On board training in the use of davit-launched life rafts must take place at intervals of not more than 4 months on each vessel with davit-launched life rafts. Whenever practicable, this training must include the inflation and lowering of a life raft. If this life raft is a special life raft intended for training purposes only and is not part of the vessel’s lifesaving equipment, this life raft must be conspicuously marked.

This means you can still be compliant even if you have a life raft on your vessel that has not been repacked and/or inspected, provided the raft is conspicuously marked FOR TRAINING PURPOSES ONLY.

If I'm not mistaken, all commercial fish boats and all commercial passenger vessels on routes more than three miles from shore in cold waters must have an inflatable life raft aboard. These rafts must be inspected and certified and must be 100% complaint and ready to use in an emergency.

But if you're not one of these vessels, and you want to have a life raft with you without having to spend $800 to $1200 every two or three years, you can still carry one as long as it is clearly marked as indicated above.

I'm not advocating circumventing sensible safety rules. Because there's no guarantee your raft will open the way it's supposed to when the time comes if it hasn't been inspected and repacked. That said, there are no guarantees -- period! I know of one mariner who had a number of dead flares in a freshly repacked raft. Let me add that I have popped the cork on two life rafts that have gone well past their expiration dates and neither one of them failed to open. Similarly, a good friend who conducts routine training exercises with the U.S. Coast Guard informs me that he has personally fired off hundreds of long-expired flares without a single failure. This speaks highly for the manufacturing quality of our safety gear, but maybe not so highly for the integrity of our manufacturers and regulatory organizations.

Let me again repeat myself: I AM NOT ADVOCATING CARRYING NON-COMPLIANT SAFETY EQUIPMENT!

If you are required by law to carry an inspected life raft, you better have one. Moreover, chances are you can trust one that has been repacked and inspected more than you can trust one that hasn't.

On the other hand, I'd rather have a non-compliant life raft aboard than no life raft at all.

-seabgb