Lessons Learned – by Pat Carson
Annual Vessel Safety Check
Many yacht clubs have their annual safety day this time of year when we typically use our boats less often and instead are busy with upgrades and repairs. This year, Stockton Yacht Club’s Safety Day was on Feb. 19, a beautiful sunny and warm winter day. We had a total of 28 vessels participate in the courtesy vessel safety check or VSC, and all but one passed. This is the seventh year the club has conducted vessel inspections as a key part of safety day, and the results are evident as nearly all of the owners had a good understanding of the USCG requirements and had their vessels ready for the inspection. Adding to our day of safety, a small boat crew from Coast Guard Station Rio Vista visited. The crew wandered the docks and met with many of the boat owners that were busily getting ready for the VSC.
Details, Details, Details
Since there have been several changes and clarifications over the past several years, let’s take a detailed look at the USCG minimum required equipment that must be on board any time the vessel is away from the dock. As you read these requirements, mentally review your vessel’s safety equipment.
Display Of Numbers
A Federally documented vessel must display the vessel name and hailing port in one location. The letters must be at least four inches tall and clearly readable. Recreational vessels usually display the name and hailing port at the stern. However, it is acceptable to display these at both sides of the bow which is required for commercial vessels. In addition, the documentation number must be permanently affixed on some clearly visible integral structure of the vessel in block Arabic numerals, larger than three inches in height and be preceded by the letters “NO.” Commercial made documentation plates are available from many sources.
For state registered vessels, the CF numbers must be plain vertical block characters greater than three inches high and permanently attached to each side of the forward half of the vessel. The numbers must read from left to right and be of a contrasting color to the background. The validation sticker must be affixed within six inches of the registration number and there cannot be any other numbers or letters nearby.
State law requires boats and vessels registered in California to display a mussel sticker if they are operated in fresh waters. This includes inland waterways, rivers, lakes, reservoirs, wetlands and the Sacramento-San Joaquin Delta. Failure to properly display the sticker may result in denial of access or citation.
Registration Or Documentation
The USCG Certificate of Documentation is a national form of registration dating back to the 11th act of the first congress and serves as evidence of a vessel’s nationality for international purposes. For compliance with federal documentation requirements, the original document must be on board the vessel, must not have expired and be signed by the Director of the National Vessel Documentation Center. Recreational vessels are eligible for federal documentation if they are wholly owned by a citizen of the U.S. and measure at least five net tons. Remember that net tonnage is a measure of the vessel’s volume, not its weight. Most vessels over 25 feet in length will measure more than five net tons. If your vessel is state registered, the original registration must be kept on board.
Personal Flotation Devices
All recreational vessels must carry one wearable life jacket for each person on board. To be considered serviceable, all life jackets must be USCG approved with the label readable, in good condition, of appropriate size and type for the intended user and properly stowed and readily accessible. PFDs should not be stowed in the original plastic bag, locked in closed compartments or have other gear stowed on top of them.
USCG approved inflatable life jackets are authorized for persons 16 years and older. To be counted as a serviceable life jacket they must have a full CO2 cylinder with the status indicator green. With few exceptions, an inflatable flotation device must be worn when underway in order to be counted. There are a few newer designs that are rated as type III and do not need to be worn, so check carefully.
On a vessel that is underway, children under the age of 13 must wear an appropriate USCG approved life jacket at all times unless they are below deck or in an enclosed cabin. Children’s life jackets are approved for specific weight categories and must be properly sized for the intended wearer. Some water activities such as skiing or operating a personal watercraft require life jackets designed for that specific activity and have specific wear requirements.
Visit www.yachtsmanmagazine.com/articles/lesson_oct2015.html for more detailed information on personal flotation devices and read my Oct. 2015 Lessons Learned column.
Vessels longer than 16 feet, except canoes and kayaks, must also carry one Type IV throwable ring or cushion.
Throwable devices must be immediately available for use by anyone on board, on the main deck and within arm’s reach.
Visual Distress Signals
Vessels operating in U.S. coastal waters, the Great Lakes and U.S. Territorial seas, as well as waters connected directly, up to a point where the waterway is less than two nautical miles wide, must be equipped with USCG approved visual distress signals. Vessels operating in an area less than two miles wide are not required to carry visual distress signals. Recreational boats less than 16 feet in length, sailboats less than 26 feet in length that do not have mechanical propulsion and manually propelled boats are not required to carry daytime signals, but must carry night signals when operating between sunset and sunrise.
Vessels must have a minimum of three pyrotechnic visual distress signals that are USCG approved, in serviceable condition, readily accessible and within the expiration date. Approved pyrotechnic devices include red handheld or aerial day/night flares. Handheld or floating orange smoke devices are available for daytime use. Non-Pyrotechnic daytime visual distress signals must meet USCG requirements and include the orange flag with a black ball and black square.
The electric distress light is acceptable for night use only and must flash the international distress Morse code signal SOS.
A device that works great and is my personal favorite is the Weems & Plath C-1001 SOS Distress Light. It provides the advantage of a light that lasts 60 hours instead of the handheld flares that last just minutes. It floats and can be hoisted up a mast for greater visibility. You can change the three “C” batteries for a few dollars instead of purchasing flares every 42 months that cost tenfold.
If you do not plan to go outside the Golden Gate Bridge or operate your vessel after sunset and before sunrise, daytime visual distress signals are not necessary.
USCG approved marine type handheld fire extinguishers are required on boats where a fire hazard could exist. This includes vessels that have permanently installed fuel tanks, spaces that are capable of trapping fumes, closed compartments under thwarts and seats where portable fuel tanks may be stored, an enclosed living space or closed storage compartments in which combatable or flammable materials are stowed. If your boat is less than 26 feet in length, uses an outboard engine, fuel is in a portable fuel tank and there are no areas within the boat where fuel vapors can be trapped, the boat is not required to have a fire extinguisher.
New rules go into effect on April 20. If your fire extinguisher has a date of manufacture stamped on the bottle and is older than 12 years, it is considered expired and must be removed from service. Look for wording on the bottle stating, “This product must be removed from service within 12 years after date of manufacturing.” Date codes are stamped on the bottom of the cylinder and may be two-digit, four-digit or have additional information.
Vessels are required to carry a specific quantity of 5-B or 20-B UL-rated USCG approved extinguishers. If your vessel is older than model year 2017 you may carry a B-I or B-II rated fire extinguisher instead, but you must replace them with a 5-B or 20-B when they are no longer good and serviceable. All recreational vessels of model year 2018 and newer must carry 5-B or 20-B rated fire extinguishers that are date stamped. Vessels older than model year 2018 may carry either 5-B or 20-B rated fire extinguishers that are less than 12 years old, or B-I or B-II rated fire extinguishers that are in good and serviceable condition.
Although use of the mounting bracket is not required, it is recommended that the extinguishers be mounted in a readily accessible location. Look on the label for wording that says Marine Type USCG approved and has a USCG approval number as they will come with a mounting bracket from the manufacturer.
The number of required handheld portable fire extinguishers varies by vessel length. Less than 26 feet, one B-I/5-B, 26 to 40 feet, two B-I/5-B or one B-II/20-B and 40 to 65 feet, three B-I/5-B or two B-II/20-B. For vessels with a USCG Approved fixed fire extinguishing system installed in the engine room or machinery space, the number of handheld units can be reduced by one. Remember, these are the minimum requirement and the National Fire Protection Association recommends more and suggests best locations to mount them.
Vessels using gasoline for electrical generation, mechanical power or propulsion must be equipped with a ventilation system. A natural ventilation system is required for each compartment that has a gasoline engine, has an opening between a compartment that requires ventilation, a compartment that contains non-ignition protected electrical equipment or a vessel that uses a non-metallic fuel tank. A powered ventilation system is required for each compartment that has a permanently installed gasoline engine with remote starting capability, for example your gasoline powered generator or main engines. Vessels built before 1980 are not required to have powered ventilation systems.
Many diesel-powered vessels do not have a powered engine room ventilation system, nor is it required for these vessels. Diesel must be heated in order to evaporate and will not create an explosive concentration of vapor in the enclosed space of the engine room at room temperature. If your vessel has a blower, use it. If it doesn’t, consider adding one to err on the side of safety.
Backfire Flame Arrestor (Gasoline-Powered Vessels)
Vessels manufactured after April 25, 1940 with installed gasoline engines must be equipped with an acceptable means of backfire flame control. A backfire flame arrestor must be secured to the air intake with a flame tight connection and marked with a USCG approval number. Other methods of acceptable backfire flame control include an air/fuel induction system, typical of personal watercraft and velocity stacks. During the VSC, this device will be examined and must be clean and free of dirt and oil.
If you have not cleaned the backfire flame arrestor on your vessel in the last year or so, it will probably not pass muster. Checking it is simple. All you have to do is drag your finger across the fins. If it comes back with dirt or oil, then the arrestor must be removed and cleaned.
Sound Producing Device
Part D of the navigation rules, rules 32 through 37 describes the use of sound signals to be made under certain circumstances of meeting, crossing or overtaking another vessel. Recreational vessels are also required to use sound signals during periods of reduced visibility and while at anchor.
Annex III of the navigation rules describes the technical details of sound signal appliances. Vessels of different lengths require whistles of different intensity, range and frequency. Recently, there has been a regulatory change to the international rules, COLREGS, and the Coast Guard expects a forthcoming change to the inland rules that will harmonize the two sets of rules with regards to the sound signal requirements.
It is not necessary for the vessel to have a fixed electric or air horn; the handheld air horn is acceptable.
For more on sound signals and sound producing devices, you can visit www.yachtsmanmagazine.com/articles/ll_oct2011.html for my Oct. 2011 Lessons Learned column.
Recreational vessels are required to display proper navigation lights when operated between sunset and sunrise, and during periods of restricted visibility due to fog, rain, haze, etc. For power-driven vessels less than 20 meters (65 feet) in length, the navigation lights consist of red and green sidelights, a white stern light and white masthead (sometimes referred to as the steaming light). For a non-power-driven vessel, a sailboat for example, the forward white steaming light is not required unless the vessel is operating the auxiliary engine, and is therefore considered a power-driven vessel.
Did you know that a vessel under oars is not required to have navigation lights? Their only requirement is that they have an electric torch (flashlight) ready at hand, showing a white light that shall be exhibited in enough time to prevent a collision.
For complete lighting specifics, consult the navigation rules Part C, Rules 20 through 31.
For more on navigation lights, take a look at my June 2012 Lessons Learned column by checking out www.yachtsmanmagazine.com/articles/ll_june2012.html or refer to your copy of the navigation rules.
The Federal Water Pollution Control Act requires that all vessels with propulsion machinery have the capacity to retain oily bilge water on board and are equipped with a fixed or portable means to discharge these oily waters to a shoreside reception facility. Oil absorbent pads, buckets, heavy plastic bags, etc. are all suitable means that meet the requirement for retention on board. No person may drain oil or oily waste from any source into the bilges, and you must notify the USCG National Response Center if your vessel discharges oil or other hazardous material into the water. Placing the pollution placard on board your vessel at the entrance to the machinery space confirms your understanding of these requirements.
MARPOL Trash Placard
In Annex V of the MARitime POLlution 73/78, MARPOL prohibits throwing, discharging or depositing any refuse matter of any kind including trash, garbage and liquid pollutants in the waters of the United States. All boats 26 feet or more in length must have a written garbage placard prominently posted to remind you and your crew what can be thrown overboard and what cannot.
In addition to having the MarPol sticker affixed, all vessels greater than 12 meters (39 feet six inches) in length must have a written trash management plan. This can be as simple as a handwritten trash management plan, a sticker purchased at your local chandlery or a complicated plan worthy of a large ship.
Marine Sanitation Device
All recreational vessels with installed toilet facilities must have an operable marine sanitation device. Vessels under 65 feet in length can have a Type I, II or III device where the Type III is the common holding tank. A typical Type I Marine Sanitation system is the Raritan Purasan or Electrasan systems where they treat and then either hold or discharge the waste. The discharge of treated sewage is allowed within three miles of shore, except in designated no discharge zones. Many marinas are designated as no-discharge zones, and the berther must treat and hold the waste for proper disposal. Beyond the three nautical mile limit, untreated sewage may be discharged directly overboard.
When inside the three-mile limit, a marine sanitation device capable of discharging untreated sewage overboard must be configured such that no untreated sewage can be discharged. Closing and locking the overboard discharge thru hull seacock is a common method of meeting this requirement.
During the vessel safety check, we look to see that both the macerator pump overboard discharge thru hull seacock is closed, and either locked or the handle removed and confirm that the Y-Valve is in the hold position and will not discharge directly overboard. The fine for dumping raw untreated sewage inside the three-mile limit can be quite large.
The “rules of the road” or navigation rules define the roles and responsibilities of the vessel operator. The rules are divided into two parts, international and inland. The inland rules apply to all vessels operating shoreward of the demarcation line, and the international rules apply seaward of the demarcation line. The operator of a vessel greater than 12 meters (39 feet six inches) in length is required to have and maintain a written or electronic copy of the navigation rules on board while operating in U.S. waters. Unfortunately, the requirement does not require operators to read or understand the navigation rules, just that they have the book on board.
The state of California requires that a carbon monoxide warning label be placed both at the helm and at the swim ladder of the vessel warning of the dangers of CO poisoning. At www.yachtsmanmagazine.com/articles/lesson_aug2015.html you can find my Lessons Learned Aug. 2015 column for more on the dangers of carbon monoxide poisoning.
The courtesy vessel safety checks from the U.S. Power Squadron and the USCG Auxiliary are offered as a public service on a volunteer basis and without cost. To schedule a courtesy vessel safety check, you can contact either the U.S. Power Squadron at www.usps.org/national/vsc/, the USCG Aux at www.cgaux.org/vsc/, or if you are in the San Francisco Bay and Delta area drop me an email at email@example.com and I would be pleased to come to your boat and do the check. Thirty minutes could save your life and the life of your family.
After a morning of inspecting our berthers’ vessels for the required safety equipment, the USCG crew joined us for lunch and a highly informative question and answer session. The next time you look off your beam and see an orange boat with a blue light activated and on an apparent intercept course, there are no worries. Simply slow to bare steerageway and prepare to be boarded. The response boat may hail you on VHF Channel 16 and provide instructions, or they may just come up alongside. It is all about safety. The USCG wants you to be safe, and procuring the minimum safety equipment on board is a good first step and may prevent a future search and rescue.
As you are going through your equipment, please keep in mind that the equipment listed here is the minimum requirement. Having an extra type IV throwable perhaps with a line attached as is required by the Canadian Coast Guard, a few more fire extinguishers as recommended by the National Fire Protection Association or perhaps an engine room blower on your diesel-powered vessel will add to your safety at a minimal expense.
An engine kill switch is required for vessels under 26 feet with engines over three horsepower, but this is not inspected during the VSC.
As my fellow boaters prepare for their annual courtesy vessel safety checks I will sit back and enjoy a port and cigar. The courtesy VSC is designed to provide information to you and to assist with correcting any deficiencies found. If you have any good boarding stories to share, please email me at firstname.lastname@example.org. I love a good story.