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NBSAC Resolution 2009-83-01 US Coast Guard NBSAC October 2009

This resolution supports the development of a new program for life jacket design approval to enhance opportunities for innovation and reduce barriers. It highlights the adoption of ISO 12402, recognition of other labs, and the implementation of risk-based performance criteria.

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NBSAC Resolution 2009-83-01 US Coast Guard NBSAC October 2009

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  1. NBSAC Resolution2009-83-01US Coast Guard NBSAC October 2009 Marty Jackson CG-5214

  2. NBSAC Resolution (April 2009) • “…request the U.S. Coast Guard to develop a new program for life jacket design approval and follow up quality control to reduce barriers and enhance opportunities for life jacket innovation.”

  3. NBSAC Resolution (April 2009) • Supports Current Efforts • ISO 12402 Adoption • Innovation • Recognition of Other Labs • Separate Standards Administration

  4. NBSAC Resolution (April 2009) • Testing & Q/A Modifications • Working Group • Consolidated Standards • ISO 12402 50N Devices • Recognized Laboratories

  5. Testing/QA Modification • Flammability test requirements have been eased with CPSC fabric exemption • Risk based performance criteria is being incorporated • Less prescriptive design criteria • Greater flexibility in design • Q/A Inspection Frequency – 2002 Study • Recreational White Water Rescue PFDs

  6. Working Group Meetings • 27 January 2009 – CG-52/ PFDMA/NMMA • 24 February 2009 – CG-5/ PFDMA/NMMA • 22 March 2009 – ISO 12402 CG/PFD Mfrs • 5 May 2009 – CSTG Standards Dev. • 10 June 2009 – CG-54/ PFDMA/NMMA • 21 Sept 2009 – PFDMA -Webinar • 7 October 2009 – CG-5214/ PFDMA • 15 October 2009 – CSTG Standards Dev. • *6 December 2009 – ISO 12402 CG/PFD Mfrs. • +Numerous Teleconferences

  7. Consolidated Standard Task Group (CSTG) -- Participants • US representatives • Dr. Ayyub (UMD) • Mike Cunningham & • Chris James * (UL) • Marty Jackson *^(CG) • Ralph Steger * (Coleman) • Robin Scott * (Sport Dimension) • Dorothy Takashina (TLPC) • Wayne Walters (Kent) • Canadian representatives • Paul Potter * (Cord) • Ravi Shankar (TC) • Larry Spears (Helly- Hansen) • Sam Wehr * (Mustang) • * - Drafting Gp Mbrs • ^ - Added Sept ‘09

  8. Consolidated North American Standard General Plan - Project Milestones www.uscg.mil/hq/cg5/cg5214/ Draft for comment – May 2010 Standard for ballot – March 2012 Funding shared – Boating Safety Grant PFD Industry UL label fee

  9. Consolidated North American Standard Canadian – US Standard Adopt ISO 12402 PFD Standard Some National Deviations Risk based Performance Assessment Tools Standards Holder 9

  10. Recognized Laboratory • USCG prerequisites for PFD labs: • Actively engaged as “accepted” lab for testing CG-approved marine equipment • Have no other commercial interest in the manufacturer • Not rely on USCG approval work to remain in business • Request “recognition” for PFDs • USCG visit the lab • Demonstration of ability to perform required subject testing and production quality control

  11. Recognized Laboratory • In order to be “Recognized”, a lab must: • Meet the requirements for “acceptance” for the specified equipment; • Have an established factory inspection, listing and labeling program; • Use acceptable standards for minimum design and performance evaluation; and • Enter into a MOU with the CG to document how they will perform and report on those responsibilities • Final Step: Successful Comparison Testing • All labs for each subpart are listed on CGMIX: http://cgmix.uscg.mil/EQLabs/

  12. Way Ahead for PFDs Continue: • PFDMA/NMMA Dialogue • USCG Support of ISO TC 188/ WG 14 • ISO 12402 (PFDs 275N - 50N) • Recognized Laboratory Qualification Effort • Support Standards Maintenance – UL/ABYC

  13. Questions? Office of Design and Engineering Standards Lifesaving and Fire Safety Division CG-5214 Marty Jackson – 202-372-1391Martin.L.Jackson@uscg.mil

  14. Independent Laboratory • In order to be “Accepted”, the lab must: • Be regularly engaged in inspecting/testing same or similar equipment; • Have suitable facilities, personnel and equipment; • Have no other commercial interest in the manufacturer; and • Not rely on USCG approval work to remain in business. • All independent labs are listed on CGMIX: http://cgmix.uscg.mil/EQLabs/

  15. Consolidated N.American Std Work-plan (1) Specific Steps: 1. Review all the stakeholder inputs 2. Develop the goals 3. Complete draft plan 4. Identify the principles 5. Obtain written input on project work plan 6. Preliminary ranking of proposed requirements 7. Obtain stakeholder input on principles & ranking 8. Transition plan 9. Identify acceptable ISO 12402 parts 10.Submit ISO Comments

  16. Consolidated N.American Std Work-plan (2) 11.Finalize test methods for new parameters(new) 12. Rank proposed requirements (in workshop) (new) 13. Draft minimum deviations 14. Identify “IHC” Staff 15. Validation of Aggregate Performance Models(new) 16 Draft any new Part(s) (if ISO standard is not suitable) -- (Milestone 1) -- May 31, 2010 17. Project costs & funding 18. IHC decision 19. Balloting 20. Publish Std(s) -- (Milestone 2) -- Mar 2012

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