USCG v ISO Personal Flotation Devices
We recently reviewed two very popular low-volume/profile PFDs that have international safety certifications and are considered safe for use in countries like Australia, New Zealand and South Africa. Both have been popular in the surf ski community and are becoming attractive to SUP paddlers who are looking for a better alternative to the USCG approved inflatable waist belt PFD which they don’t think is really safe.
We received some criticism for that. For supporting products that are not okayed by our very own Coast Guard. We clearly stated in each review that the products were not USCG approved and users should exercise their own discretion.
The discussion prompted us to do some research and try to help sort out what the differences are in the USCG and ISO regulations so folks can make informed decisions.
So here goes. It’s a long post. Sources for this post are hyperlinked.
What the USCG Says About PFDs
This is significant. This is directly from the USCG website:
“The perfect life preserver, lifejacket, or PFD has not yet been designed. All the designs in existence today have some limitations. For example, Type I PFDs (off-shore lifejackets) have the highest buoyancy of the inherently buoyant Types, but they are not considered comfortable enough to be worn continuously. Therefore, they are frequently not being used when accidents occur, and many boaters have died that could have been saved with just part of the buoyancy in this kind of PFD. Another example is the inflatable Type III PFDs. These recently approved PFDs provide the buoyancy of a Type I PFD and are comfortable to wear, but they lack the reliability and low maintenance characteristics, and cost, of inherently buoyant PFDs. Because each style has limitations, users are given a choice of PFDs to match to their particular boating activities.
“What about someone drowning while using the “wrong” type PFD? It is unlikely that any different Type of PFD would have prevented most of the drownings where a PFD was used. Consider this regarding PFD performance: (our emphasis added)
- About 51 people died in accidents where PFDs were used, but only in a few of those cases is there any indication that a higher performing PFD might have prevented the drowning. In the majority of cases, other contributing factors would have overcome the benefits of any PFD. The factors include: being trapped in an overturned boat, being held under a boulder or log by the strong currents of white water, removing the PFD for some reason (like swimming to shore), becoming hypothermic due to the duration of exposure in cold water, suffering other injuries that led to drowning, etc.
- One is much more likely to drown while boating due to not wearing a PFD than wearing one with inadequate performance for conditions which occur only occasionally, and only at places and times that most boaters know to avoid. “
ISO and USCG Type Designations
ISO is an independent, non-governmental international organization with a membership of 163 national standards bodies.
Through its members, it brings together experts to share knowledge and develop voluntary, consensus-based, market relevant International Standards that support innovation and provide solutions to global challenges.
In both the ISO and USCG regs, there is a classification of Type II for PFDs. They are both meant to be flotation products designed for recreational use in situations when rescue is expected within two hours, in near-shore scenarios.
US regulations require the Type II foam or kapok PFDs to provide 70 Newtons of flotation. A USCG Type II PFD will float the user face up automatically, usually with a collar. They are uncomfortable to wear long term.
ISO regulations require “not less than 50 N used in sheltered waters with help and rescue close at hand under such circumstances where more bulky or buoyant devices can impair the user’s activity.”
A USCG Type III PFD is what most kayakers wear. The definition of the Type III is: “For general boating or the specialized activity that is marked on the device such as water skiing, hunting, fishing, canoeing, kayaking and others. Good for calm, inland waters, or where there is a good chance for fast rescue. Designed so that wearing it will complement your boating activities.” The minimum Newton require is also 70, just like the more general boating Type II pfd, but it will NOT automatically float you face up.
By contrast, Type II Inflatable PFDs that are US approved must have 150 Newtons of floatation. A Type III inflatable must have 100 N of flotation.
What is a Newton?
No, not the fig kind. A Newton, named after Sir Issac, is the International System of Units (SI) derived unit of force. Therefore, a measurement of force. Without getting all sciency-whyency and getting too far into The Maths, where PFDs are concerned, Newtons are talking about the force of the body’s weight and the PFDs ability to support it out of the water. The higher the Newtons, the more you’ll be lifted.
- 70 N is equal to 15.5 pounds of buoyancy
- 50 N is equal to11.2 pounds of buoyancy
If you want to get all sciency-whyency about it, go here.
How Much Is Enough?
Thing is, all bodies are different. You know how some people will tell you that they just can’t float? While others have the opposite problem? For instance, I happen to have floaty feet. I learned this scuba diving. When I would do my safety stops at 15 feet to decompress after a deep dive, inevitably I would end up hanging upside down because my feet wanted to float. I ended up having to wear light ankle weights to balance everything out, least I was always swimming underwater at a angle!
My point is, all bodies act differently in the water, based on body composition, lung capacities and even what we are wearing at a given time. And this can change over time, too, as our bodies age. So, I might only need 50 Newtons of flotation, where it might take more to adequately float someone else.
Where it gets tricky is trying to equate actual body weight to the amount of Newtons needed to be adequately supported. There is really no way to say that a male weighing X amount of pounds needs at least X amount of floatation. Again, because every body is different. It’s kind of like bike sizes, or sizing between different brands of jeans. Or shoes. Nikes might fit your feet great, but Adidas not so much. You get the point.
So, there are guidelines. And that’s what both the USCG and ISO standards are based on.
On its website, the USCG says this about the amount of flotation average adults require:
“BUOYANCY: Most adults only need an extra seven to twelve pounds of buoyancy to keep their heads above water. A PFD can give that “extra lift,” and it’s made to keep you floating until help comes.”
- USCG Type III: 70 Newtons or 15.5 pounds of flotation
- Mocke Racer: 60 Newtons or 13.4 pounds of flotation.
- Vaikobi Ocean Racing: 50 Newtons or 11.2 pounds of flotation.
Both the USCG and Mocke PFDs then are well beyond that extra seven to 12 pounds of extra lift cited by the US Coast Guard and the Vaikobi comes close.
Note: Most Type IIIs do have more than 70 N of flotation, going above that minimum requirement. But most of that flotation is in the the bottom front panel which can affect self rescue on a SUP depending on body shapes.
Let’s face it, how many of us read these labels, and know how much flotation we are getting when we pull a PFD off the rack?
Here’s another nugget to chew on. You could buy a USCG approved PFD, thinking all is well, but because of your body composition you might just need one that is much more buoyant than that 70N standard. So how do you know if even a USCG approved piece of kit is still going to do the job?
The USCG tells consumers to be sure to look at the labels of PFDs and buy one sized for your height and weight. And if offers these fit guidelines:
- Try on your PFD to see if it fits comfortably snug. Then test it in shallow water to see how it handles.
- To check the buoyancy of your PFD in the water, relax your body and let your head tilt back. Make sure your PFD keeps your chin above water and you can breathe easily.
- Be aware: your PFD may not act the same in swift or rough water as in calm water. The clothes you wear and the items in your pockets may also change the way your PFD works.
- If your mouth is not well above the water, get a new PFD or one with more buoyancy.
- A PFD is designed not to ride-up on the body when in the water. But, when a wearer’s stomach is larger than the chest, ride-up may occur. Before use, test this PFD in the water to establish that excessive ride-up does not impair PFD performance.
Test it. That’s right. Check it out. If it does not keep your chin above water, allowing you to breath easily, then take it back and get one with more buoyancy. And make sure it is SNUG when you wear it. The shoulder straps should not float up. On dry land, have a buddy put two fingers under each strap and pull up. If the straps can come up to your ear lobes, MAKE IT TIGHTER.
For the record, both my Mocke and Vaikobi PFDs more than adequately meet the above USCG test. But that is for me. And I have floaty issues, remember? Everyone is different.
It Can’t Save You If You Don’t Wear It
Remember, while USCG regs require your PFD to meet its standards, they do not require you to actually WEAR it. You are only required to have one accessible.
The USCG also says this on its website:
“In terms of risk of drowning, the safest Personal Flotation Device (PFD) is the one you’re willing to wear!”
Things could be changing at USCG
In its current strategic plan The USCG’s National Recreational Boating Safety Program recommends adopting the ISO’s 50N standard, to allow for more variety in types of approved PFDs, applicable to a wide variety of activities, that take into affect comfort, range of motion and hence increase the likelihood of use.
In fact, that is the major difference in the current variation between the two sets of standards: USCG standards account only for buoyancy factor and not wearability and practicality. The ISO standard is somewhat less because it takes into account “such circumstances where more bulky or buoyant devices can impair the user’s activity” and attempts to foster wider use of PFDs by allowing them to be designed to be more wearable. And to give users more choice given the varying conditions they may be boating in. There are also variances in quality and measurement standards,that are tracked and certified by agencies like the Underwriter’s Laboratory, where things like tensile strength of straps and performance of the product are tested. You can read more about that here, in an informative piece on the NRS website. Other countries have similar testing agencies. For instance, European Union nations have CE seals of approval. Testing requirements can vary.
The ISO’s wide range does allow for some products to get in that won’t cut it, as evidenced by this study conducted by BoatUS, back in 2011. But then again if you need 100 N of flotation, neither will as USCG approved Type III with 70 N that you just pulled off the shelf at Dick’s because it was on sale.
Responses from Mocke and Vaikobi
Both companies were quick to answer our emails for information, from half a world away, in South Africa and Australia.
Dawid Mocke, who is one of the world’s foremost surf ski athletes and the designer of the PFD bearing his name, responded personally. He explained that initially his PFD was aimed at just the racing canoe/kayak/surf ski community where performance was a need. He correctly notes an important exemption in USCG regulations where RACING canoes are concerned. Look:
UNITED STATES COAST GUARD REGULATIONS:
Title 33, Code of Federal Regulation 175.17(3)(c) “Racing shells, rowing sculls, racing canoes and racing kayaks are exempted from the requirements for carriage of any Type PFD.
33 CFR 175.3 Definitions: “Racing shell, rowing scull, racing canoe, and racing kayak means a manually propelled vessel that is recognized by national or international racing associations for use in competitive racing and one in which all occupants row, scull, or paddle, with the exception of a coxswain, if one is provided, and is not designed to carry and does not carry any equipment not solely for competitive racing.
“Granted, it is broad, but at the time of us entering the market in the US, we were only focussed on this market,” Mocke explained. “Now that our brand is getting traction in the broader, more recreational market, we are intent on getting the right approvals.”
Mocke also notes that a new North American standard is expected to go into effect in the coming year.
These PFDs are not cheap. Anyone who is willing to invest approximately $150 or more for a PFD is looking for something that is well engineered, or as Mocke says ” is really intent on getting quality safety equipment for exactly the reason they would need it, but not at the expense of performance, both from the product or themselves.” You probably wouldn’t spend that much money on a PFD if you weren’t confident in its ability to do the job.
Similarly, Pat Langley, founder of Vaikobi told us that this also the reason behind the ISO certification only for his product. He too says that since the popularity of his vest among sup paddlers is growing, they are looking at seeking USCG certification. He pointed out that right now, as paddling has evolved and the sport and water craft involved develops, PFD regulations just don’t fit with the needs of the participants.
Mocke makes another good point:
“The bigger concern here should be paddlers who are merely ticking the relevant checkboxes and don’t really take it seriously. Granted, the chances of a personal accident are low, however it’s not about yourself, it’s about the culture that we are creating and enforcing through passive acceptance. Example: no-one in the white water community, no matter how “wild, free or reckless” they are, will dare go paddling without a helmet and pfd. Despite the freedom and excitement of white water, “safety” is embedded in the culture. How is open water downwind paddling any safer that white water down a river? But somehow the downwind culture allows for paddlers to be lax when it comes to safety. This allows less accomplished paddlers the liberty to go paddling in situations they clearly cannot handle or are prepared for, and then people die or need to be rescued. Yes, each person should be personally responsible, but we cannot ignore the role that “culture” plays in these kinds of situations. How will we ever progress the sport of downwind paddling, especially with authorities, if we can’t trust paddlers to be safety conscious and situationally aware?”
Let’s review. Here’s what the Coast Guard regs require:
- If you are paddling SUP or a non-sanctioned for racing canoe or kayak, current USCG regulations require your PFD to be USCG approved.
- Right now, those regulations require a Type II or III PDF to have at least 70 N of buoyancy.
- You must have the PFD accessible.
- Your PFD needs to fit you appropriately so that it will lift you chin out of the water. If it does not, even if it is USCG approved, it cannot help you.
A note on Inflatables
- You will be within USCG regs if you have an approved inflatable, you are wearing it facing front and it is armed with a Co2 cartridge.
- In order to be “street legal” with an inflatable PFD YOU MUST WEAR IT. If it’s under your bungees, you are out of compliance.
- If you choose this PFD, KNOW HOW IT WORKS. Test it. Try it on, See how hard/easy it will be to deploy. Practice, practice, practice.
- Always make sure it is in working order.
Another Note on Leashes
In all of the reported SUP related deaths in 2016 as reported by the USCG, the cause of the drowning was listed as “separation from the vessel.” Wearing a leash in the appropriate conditions (not in the surf zone and quick release in white water) goes part and parcel with wearing a PFD. No matter where you are paddling. Period.
And if you do not know how to swim or believe your swimming skills to be lacking, please, please, please get instruction.
None of this is foolproof. Even the USCG is re-evaluating all of this, as it explains here.
It is our individual responsibility as paddlers to take safety seriously. Do your own research. Test drive PFDs like you would a new board or a paddle. How does it float you? Can you easily and efficiently get back on your boardwith it on? Read the labels. Read the regs. Make informed decisions about what you choose to use on the water to keep yourself as safe as possible in whatever conditions/scenarios you paddle in. Accept the limitations and consequences involved in those decisions. It may or may not make sense to you to wear an ISO-only approved device that adequately floats you and fits properly, as opposed to a USCG-approved waist belt PFD that you might not be able to deploy in time. Do not assume that just because a PFD is USCG approved it will categorically work in any situation, and conversely do not assume that a high quality, ISO only approved flotation device is unsafe. As an instructor and someone who is deeply passionate about our sport and its many facets, and making sure people do it safely, I would much rather see someone in a pink Vaikobi because they think it’s comfy, they want hydration (another safety thing!!) or they just like the color than to see a someone paddling around with a USCG approved PFD under the bungees of their board.
But that’s just me. Get informed. Make your own choices. Be responsible.