Tier I - Policy – Acceptance of lifejackets and personal flotation devices certified to the standard ANSI/CAN/UL 12402 as substitute safety equipment

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1. Policy objective

1.1 To improve safety by accepting new updated standards enabling manufacturers to produce more innovative equipment that meets requirements for certification in both Canada and the United States.

1.2 To improve safety on Canadian vessels by providing increased choices to consumers of more comfortable and innovative personal flotation devices (PFDs) that promote their constant wear.

2. Policy statement

2.1 Transport Canada recognizes, as substitutes for the lifejackets and PFDs currently required under the Small Vessel Regulations, and the Fishing Vessel Safety Regulations, devices that are tested and certified according to the standard ANSI/CAN/UL 12402-9: Personal Flotation Devices – Part 9: Test Methods and certified or listed as complying with the requirements of the standard:

  1. ANSI/CAN/UL-12402-4: Personal Flotation Devices – Part 4: Lifejackets, Performance Level 100 – Safety Requirements
  2. ANSI/CAN/UL-12402-5: Personal Flotation Devices – Part 5: Buoyancy Aids (level 50) – Safety Requirements
  3. ANSI/CAN/UL-12402-6: Personal Flotation Devices – Part 6: Special Application Lifejackets and Buoyancy Aids – Safety Requirements and Additional Test Methods and the Canadian modifications set out in Annex 2 of this policy

2.2 These lifejackets and PFDs must be certified by a Canadian recognized organization or product certification body in accordance with TP 14612 – Procedures for approval of life-saving appliances and fire safety systems, equipment and products.

2.3 For a standard listed in the Schedule of the Small Vessel Regulations and column 1 of the Table of Substitutions in Annex 1, a lifejacket or PFD meeting that standard can be replaced with one certified as meeting the subpart(s) of ANSI/CAN/UL 12402, and having the corresponding performance level, specified in column 2, provided the device is used in accordance with the limitations set out in column 3.

3. Scope

3.1 This policy applies to:

  • 3.1.1 vessels that must comply with requirement of the Small Vessel Regulations or Fishing Vessel Safety Regulations for the carrying and wearing of approved lifejackets and personal flotation devices, and
  • 3.1.2 Manufacturers of lifejackets and PFDs.

4. Authority

4.1 Section 4 of the Small Vessel Regulations and section 3.21 of the Fishing Vessel Safety Regulations both made under the Canada Shipping Act, 2001.

4.2 This policy falls under the overall administrative authority of the Director General, Marine Safety and Security.

4.3 The Marine Safety and Security Executive (MSSE) committee has approved this policy for general application.

5. Responsibility/further information

5.1 The Executive Director, Domestic Vessel Regulatory Oversight, is accountable for developing, approving and maintaining this policy.

5.2 The Regional Directors of Marine Safety and Security are responsible for implementing this policy.

5.3 Please email questions or comments to marinesafety-securitemaritime@tc.gc.ca or mail to:

Manager, Small and Fishing Vessels, Design and Equipment Standards
(AMSDS)
Transport Canada
Place de Ville, Tower C
330 Sparks St
Ottawa, ON K1A 0N5

6. Related documents

6.1 TP 14475 - Canadian Life Saving Appliance Standard

6.2 TP 14612 - Procedures for Approval of Life-Saving Appliances and Fire Safety Systems, Equipment and Products

6.3 ANSI/CAN/UL-12402-4: Personal Flotation Devices – Part 4: Lifejackets, Performance Level 100 – Safety Requirements

6.4 ANSI/CAN/UL-12402-5: Personal Flotation Devices – Part 5: Buoyancy Aids (level 50) – Safety Requirements

6.5 ANSI/CAN/UL-12402-6: Personal Flotation Devices – Part 6: Special Application Lifejackets and Buoyancy Aids – Safety Requirements and Additional Test Methods

6.6 ANSI/CAN/UL 12402-9: Personal Flotation Devices – Part 9: Test Methods

6.7 Policy Tier I - Memorandum of understanding for approval of personal lifesaving appliances

7. Background

7.1 The lifejackets currently required by the Small Vessel Regulations, and the Fishing Vessel Safety Regulations are those which must meet:

  • 7.1.1 Canadian General Standards Board (CGSB) Standard for a Small Vessel Lifejacket in CAN/CGSB-65.7-M88, Lifejackets, Inherently Buoyant Type;
  • 7.1.2 CGSB Standard for a standard lifejacket in CAN/CGSB-65-GP-14M, Life Jackets, Inherently Buoyant, Standard Type; or
  • 7.1.3 CGSB Standard for a Class 1 or Class 2 lifejacket in CAN/CGSB-65.7-2007, Life Jackets.

7.2 The PFDs currently required under the Small Vessel Regulations and the Fishing Vessel Safety Regulations are those which must meet:

  • 7.2.1 CGSB Standard CAN/CGSB-65.11-M88, Personal Flotation Devices;
  • 7.2.2 CGSB Standard CAN/CGSB-65.15-M88, Personal Flotation Devices for Children; or
  • 7.2.3 Underwriters Laboratories, Inc. Standard UL 1180, Fully Inflatable Recreational Personal Flotation Devices, and the Canadian modifications set out in TP 14475.

7.3 Transport Canada has worked with the U.S. Coast Guard and industry to create new standards that would support the development of PFD products that boaters are more likely to wear. As part of this work, Underwriters Laboratories, Inc. published Parts 4, 5, 6 and 9 of the new ANSI/CAN/UL 12402 Standard. These are based on the ISO 12402 Standard and have been adopted as national standards by the Standards Council of Canada (SCC) and the American National Standards Institute (ANSI).

7.4 UL 12402, Part 5 provides options for both Level 70 and Level 50 buoyancy aids.

  • 7.4.1 Level 70 buoyancy aids have greater design flexibility. This allows for greater comfort and freedom of movement while still offering the same level of safety as PFDs certified to CAN/CGSB 65.11-M88 and CAN/CGSB 65.15-M88.
  • 7.4.2 Level 50 buoyancy aids are intended for use by strong swimmers in areas where help and rescue are readily available. They have less material which improves motion and comfort for active wear, however the user’s participation is required to achieve the intended performance. Therefore, these devices are only approved when worn in sheltered or near shore waters, and only if used according to all limitations and warnings that appear on the label.

7.5 UL 12402, Part 4 provides design options for Level 100 devices that are more comfortable and wearable while still providing a level of safety equivalent to that of lifejackets certified to CAN/CGSB 65.7-2007, or CAN/CGSB-65.7-M88.

7.6 Special application PFDs meet the basic performance requirements of a lifejacket or buoyancy aid but have added features for specific uses. These can require from users additional actions, special knowledge, skills, training or participation. These devices may therefore only be suitable for certain activities or users. For UL 12402-6, there are two main categories of these PFDs:

  • 7.6.1 User assisted PFDs, which include user-convertible inflatable PFDs and inherently buoyant flotation suit PFDs; and
  • 7.6.2 Application specific PFDs, which include offshore sailing lifejackets, PFDs for firefighting application, commercial white-water PFDs, PFDs for personal watercraft, water skiing, or similar towed uses, inflatable PFDs for cold environment, PFDs for swift water rescue, and PFDs for fall arrest.

7.7 This policy supports the Memorandum of Understanding between the United States Coast Guard and Transport Canada regarding Approval of Personal Lifesaving Appliances.

8. Date of application

8.1 This policy is effective on the date it is published.

9. Date for review or expiry

9.1 This policy will be reviewed 5 years after it is published.

10. SharePoint reference

10.1 The English version of this document is saved in SharePoint (Acceptance of lifejackets and personal flotation devices certified to the standard ANSI CAN UL 12402 as substitute safety equipment.docx).

10.2 La version française du présent document est dans SharePoint (Acceptation des gilets de sauvetage et des vêtements de flottaison individuels (VFI) certifiés en vertu de la norme ANSI CAN UL 12402 en tant qu’équipement de sécurité de substitution.docx).

10.3 This is the first approved and finalized English version of this document which updates and combines the two earlier policies: Acceptance of level 70 buoyancy aids certified to UL 12402-5 as personal flotation devices (saved in RDIMS under reference number 12122279) and Acceptance of lifejackets certified to UL 12402-4 as equivalent to those certified to CAN/CGSB 65.7-2007 class (saved in RDIMS under reference number 17562648).

11. Keywords

  • Personal flotation devices
  • PFD
  • UL 12402
  • Lifejackets
  • Buoyancy Aids
  • Level 50
  • Level 70
  • Level 100
  • Level 150
  • Level 275

Annex 1

Table of substitutions

Small Vessel Regulations (SVR) Required Standard

Performance Level and ANSI/CAN/UL 12402 subpart(s)

Limitations

PFDs

CAN/CGSB-65.11-M88, Personal Flotation Devices

CAN/CGSB-65.15-M88, Personal Flotation Devices for Children

Level 50

meeting:
ANSI/CAN/UL 12402, Part 6 and/or Part 5

  1. May be used as a required device on pleasure craft operated on sheltered waters, or no more than 2.5 NM from shore on inland water;
  2. If used as the required device on a pleasure craft, it must be worn at all times by a person in an open vessel or, if the vessel is not open, worn whenever the person is on deck or in the cockpit, and the vessel is underway;
  3. Cannot be carried on a vessel other than a pleasure craft as a substitute for a lifejacket required to be carried;
  4. Must be used in accordance with any warningsFootnote 1 or limitations printed on the label;
  5. Cannot be used on a vessel operated in white-water, or for an activity for which a warning graphic or statement appears on the label indicating the device has not been designed for that activity;
  6. An inflatable device cannot be used by a person on a personal watercraft; and
  7. Inflatable devices are approved only for use by persons 16 years of age or more.

UL 1180, Fully Inflatable Recreational Personal Flotation Devices, and the Canadian modifications set out in TP 14475

Level 70

meeting:
ANSI/CAN/UL 12402, Part 6 and/or Part 5

  1. Inflatable devices and inherently buoyant flotation suit PFDs must be worn by a person in an open vessel or, if the vessel is not open, worn whenever the person is on deck or in the cockpit, and the vessel is underway;
  2. Inflatable devices cannot be used on a personal watercraft, nor on board a vessel operated in white-water; and
  3. inflatable devices are approved only for use by persons 16 years of age or more 
  4. On a commercial vessel, Level 70 devices must be used in accordance with the Policy - Accepting personal flotation devices (PFDs) instead of lifejackets required by the small vessel regulations

Lifejackets

CAN/CGSB-65.7-M88, Lifejackets, Inherently Buoyant Type

CAN/CGSB-65.7-2007, Life Jackets: (Class 2 lifejacket) 

Level 100

meeting:
ANSI/CAN/UL 12402, Part 6 and/or Part 4

  1. Inflatable devices and inherently buoyant flotation suit PFDs must be worn by a person in an open vessel or, if the vessel is not open, worn whenever the person is on deck or in the cockpit, and the vessel is underway;
  2. Inflatable devices cannot be used on a personal watercraft, nor on board a vessel operated in white-water; and
  3. inflatables devices are approved only for use by persons 16 years of age or more

CAN/CGSB-65-GP-14M, Life Jackets, Inherently Buoyant, Standard Type

CAN/CGSB-65.7-2007, Life Jackets: (Class 1 lifejacket)

Level 150

or

Level 275

meeting:
ANS/CAN/UL 12402, Part 6 & Part 4, and Annex 2

  1. Inflatable devices and inherently buoyant flotation suit PFDs must be worn by a person in an open vessel or, if the vessel is not open, worn whenever the person is on deck or in the cockpit, and the vessel is underway;
  2. Inflatable devices cannot be used on a personal watercraft, nor on board a vessel operated in white-water; and
  3. inflatables devices are approved only for use by persons 16 years of age or more

Annex 2

Special application PFDs: Canadian modifications to ANSI/CAN/UL 12402-6

Introduction

In addition to ANSI/CAN/UL 12402 Part 6 requirements, a special application PFD must also meet the basic requirements of the ANSI/CAN/UL 12402 or ISO 12402 subpart of the standard that is relevant to its performance level. For Part 4 (Level 100) or Part 5 (Levels 50 and 70), this is the ANSI/CAN/UL version of the standard. However, as there is no UL version of Part 2 (Level 275) or Part 3 (Level 150), ANSI/CAN/UL 12402 Part 6 still refers to the ISO versions of these subparts.

These ISO versions do not contain the Canadian/US national differences of the UL versions needed for them to meet Canadian regulatory requirements. Therefore, for Level 150 and Level 275 special application PFDs to be approved by Transport Canada, any references in ANSI/CAN/UL 12402 Part 6 to the ISO versions of these subparts for basic requirements are replaced by references to ANSI/CAN/UL 12402 Part 4, with the additional requirements set out in this Annex.

Level 150 and 275 Special application PFD requirements

Basic requirements

  1. For a Level 150 or 275 device, in 6.1.2 DV D1 and 7.1.2 of ANSI/CAN/UL 12402 Part 6, reference to “ISO 12402-2:2020 to ISO 12402-5:2020 is a reference to the basic requirements of Clauses 5 to 8 of ANSI/CAN/UL 12402-4, with the changes below.

Accessories

  1. 5.2.1DV.1 is replaced with the following: Accessories used on a Level 150 or Level 275 PFD must comply with Table A.
Table A
Accessory Mandatory (M) /Optional (O)
Emergency light O
Whistle M
Lifting loop M
Buddy line O
Retroreflective material M
Deck safety harness O
Overpressure relief valve O
Multi-chamber system O
Protective covers O
Sprayhood O
  1. 5.2.2DV.1 DE is replaced with the following: A Level 150 or Level 275 PFD must be provided with a lifting loop tested according to ANSI/CAN/UL 12402-9, 5.5.2.4.

Sprayhoods – Offshore sailing lifejackets

  1. For 7.2.2.1 of ANSI/CAN/UL 12402-6, an offshore sailing lifejacket must be fitted with a sprayhood and personal locator light holder in accordance with clause 5.2.4 of ANSI/CAN/UL 12402-4, rather than ISO 12402-8:2020. It must also be equipped with an emergency position-indicating light meeting the requirements of the LSA Code.

Minimum buoyancy

  1. 5.3.4.2DV DT is replaced with the following: Except as provided in 5.3.5DV.1 of ANSI/CAN/UL 12402-4, when tested in accordance with ANSI/CAN/UL 12402-9, 5.5.9, the total buoyancy provided by a Level 150 or Level 275 special application PFD must not be less than the applicable minimum buoyancy as specified in Table B.
Table B - Minimum buoyancy
User User's mass (kg) Level 150 minimum buoyancy (N) Level 275 minimum buoyancy (N)
Infant Equal to or less than 15 45 90
Child 15 to 25 60 120
Youth 25 to 40 75 140
Adult 40 to 60 110 200
60 to 70 130 230
More than 70 150 275

Marking

  1. For 6DV.3.1.1 b), instead of the graphic provided in Figure 6DV.1a, the graphic for Level 150 or Level 275, which appears in Figure 3 of clause 8.4 (shown below) must appear in the Selection and Warning Panel of the device label to indicate the device’s performance level.
    1. For Level 150 
    2. For Level 275 
  2. For 6DV.3.1.1, the cold environment icon for inflatable PFDs for cold environment required in 7.6.3 (d) of Part 6 to indicate compliance with clause 7.6 of Part 6, must be included on the device label in the Selection and Warnings Panel after the graphics required in 6DV.3.1.1 (b). The icon can appear elsewhere on the device if there is not enough space on the label.
  3. For 6DV.3.1.1, the additional marking requirements of clauses 6.2.3 (c) & (d), 6.4.3 (c) to (i), 7.2.3 (c), 7.3.3 (c) to (e) , 7.4.3 (c), 7.5.3 (a),(b) and (d) to (g), 7.6.3 (c), 7.7.4 (c) to (e), and 7.8.3 (c) to (h) of ANSI/CAN/UL 12402 Part 6 (to indicate additional warnings or limitations for special application devices) must appear as part of the Selection and Warnings Panel as part of (d) of 6DV.3.1.1.
    1. For 7.2.3 (c), the information and markings specified in standard ISO 12401 are to be provided in both English and French.
  4. For 6DV.3.2.1, the additional marking requirements of (a) and (b) of each of clause 6.2.3, 6.4.3, 7.2.3, 7.3.3, 7.4.3, 7.6.3, 7.7.4, and 7.8.3 of ANSI/CAN/UL 12402 Part 6 must appear as part of the Certification and Approval panel as follows:
    1. reference to both ANSI/CAN/UL 12402 Part 4 and Part 6 (as required in (b) of each of the above clauses) must appear in the Certification and Approval Panel below the USCG and TC approvals.
    2. Reference to both Parts of ANSI/CAN/UL 12402 may be combined as shown in example 1.
    3. The text required to indicate the special application of the device (as required in (a) of each of the above clauses) must appear below the referenced standards.
    4. For 6.2.3DV D1 and 7.4.3 (a), the French acronym “EIF” in the text required to indicate the special application of the device must be replaced with the acronym “VFI”.

Example 1

This is an example of a Certification and Approval panel as shown in Annex A “Sample Labels” of ANSI/CAN/UL 12402-4 incorporating the additional marking requirements of section 9 above.
  1. For 6DV.3.3.1, the additional marking requirements of 7.5.3.2 (c) of ANSI/CAN/UL 12402 Part 6 must appear as part of the ‘Care and Maintenance Panel’ as appropriate.
  2. For 7DV.2.1 (d), the additional user information required by 7.7.4 (f) to (k), and 7.8.3 (i) & (j) must be included in the owner’s manual in the “Instructions for Use” section.
 

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