NVIC 01-08: Shipboard inspection and testing of immersion suits

COMDTPUB P16700.4 NVIC 01-08 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-08 Subj: SHIPBOARD INSPECTION AND TESTING OF IMMERSION SUITS Ref: a. Title 46 of the Code of Federal Regulations (46 CFR) Parts 109, 131, and 199 b. International Maritime Organization (IMO), Maritime Safety Committee (MSC) Circulars 1047 and 1114

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — PURPOSE. This circular promulgates the recommendations of the International Maritime Organization (IMO), in Maritime Safety Committee (MSC) Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews.

PURPOSE. This circular promulgates the recommendations of the International Maritime Organization (IMO), in Maritime Safety Committee (MSC) Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews.

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — ACTION.

a. Officers in Charge, Marine Inspection (OCMIs) are encouraged to bring this circular to the attention of the marine industry within their areas of responsibility. This circular will be distributed by electronic means only and is available on the World Wide Web at http://www.uscg.mil/hq/g-m/nvic/index.htm. Internet release is authorized. b. Ship owners and operators, Coast Guard marine inspectors, classification societies acting on behalf of the Coast Guard, and other involved parties are encouraged to review the guidance contained in this Circular when evaluating the operational readiness of immersion suits in service.

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — DIRECTIVES AFFECTED. None.

DISTRIBUTION SDL No. 148

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — BACKGROUND. Research, long term operational experience, and data from repair stations have shown that the seams and closures of immersion suits experience deterioration over time. The rate and severity of deterioration may vary widely, depending upon the specific components and procedures employed in the manufacture of the suit, and the con

4. BACKGROUND. Research, long term operational experience, and data from repair stations have shown that the seams and closures of immersion suits experience deterioration over time. The rate and severity of deterioration may vary widely, depending upon the specific components and procedures employed in the manufacture of the suit, and the conditions under which the suit is stored. However, even under ideal conditions, the materials and adhesives used have a finite service life, and will inevitably experience reductions in strength, buoyancy, and/or watertightness with age. On an annual inspection of a U.S. flag vessel in September 2006, 36 out of 66 immersion suits failed due to separation around the inflation tubes. The suits were approximately 14 years old and the manufacturer had recommended their suits over 10 years old receive annual inflation testing, preferably at one of their service centers. If the manufacturer's recommendations are followed, defects may be discovered and repaired, rather than resulting in "no sail" deficiencies. On uninspected commercial fishing vessels, recent immersion suit repair station data reflects an average suit age of 18 years and a condemnation rate of over 40%. When carried out effectively, periodic inspections and tests can identify repairable suits as well as those beyond economical repair and ready for replacement.

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — DISCUSSION.

a. 46 CFR 199.190(e), 46 CFR 109.301(e) (MODUs), 46 CFR 131.565(a) (OSVs), and SOLAS regulation III/20.7 require monthly inspections of all life-saving appliances to ensure that their operational readiness is maintained in service. For uninspected commercial fishing industry vessels, 46 CFR 28.140 requires annual inspection, cleaning, and repair of immersion suits. To assist mariners in performing these inspections effectively for immersion suits, in 2002 the IMO approved Guidelines for monthly shipboard inspections of immersion suits by ships' crews as set out in MSC Circular 1047. These IMO guidelines have been re-formatted for easy use, but the substance of the recommendations remains unchanged. An inspection checklist based on the circular is provided as enclosure (1). b. Although the guidelines for shipboard inspections of immersion suits in enclosure (1) are very helpful in identifying obvious problems with a suit and ensuring its basic functioning, they do not adequately address deterioration of seams and closures (zippers, etc.) which may not be readily apparent by visual inspection. Such deterioration can best be detected by pressurization of the suit with air, and testing of the seams and closures for leaks with a soapy water solution. c. Recognizing that shipboard inspections of immersion suits carried out in accordance with MSC Circular 1047 and enclosure (1) may not be adequate to detect deterioration of seams and closures of the suits due to ageing of adhesives and materials, in May 2004 the IMO approved Guidelines for periodic testing of immersion suit seams and closures, as set out in MSC Circular 1114, which is provided in Enclosure (2).

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — IMPLEMENTATION

a. To ensure that shipboard inspections of immersion suits are carried out effectively, the inspection procedures in enclosure (1) are recommended. b. To ensure the adequate strength and watertightness of seams and closures of in-service immersion suits, it is recommended that each suit be subjected to an air pressure test as described in enclosure (2), at intervals not exceeding three years, or more frequently for suits over ten years of age (consult manufacturer's recommendations). c. Immersion suits which are found to be unsatisfactory based on the tests and inspections described above and that cannot be economically repaired must be removed from service and the Coast Guard approval markings removed.

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — DISCLAIMER. This guidance is not a substitute for applicable legal requirements, nor is it itself a rule. It is not intended to nor does it impose legally-binding requirements on any party. It represents the Coast Guard's current thinking on this topic and may assist industry, mariners, the general public, and the Coast Guard, as well as ot

7. DISCLAIMER. This guidance is not a substitute for applicable legal requirements, nor is it itself a rule. It is not intended to nor does it impose legally-binding requirements on any party. It represents the Coast Guard's current thinking on this topic and may assist industry, mariners, the general public, and the Coast Guard, as well as other federal and state regulators, in applying statutory and regulatory requirements. You can use an alternative approach for complying with these requirements if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach (you are not required to do so), you may contact LCDR Vince Gamma, Lifesaving & Fire Safety Division, COMDT (CG-5214), 2100 2nd St. SW Washington, DC 20593-0001, Ph: 202-372-1396 / Fax: 202-372-1924, Vincent.A.Gamma@uscg.mil who is responsible for implementing this guidance.

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — CHANGES. This NVIC will be posted on the web at http://www.uscg.mil/hq/g-m/nvic/. Changes to this NVIC will be issued as necessary. Questions or suggestions for improvements to this NVIC should be submitted in writing to Commandant (CG-521).

CHANGES. This NVIC will be posted on the web at http://www.uscg.mil/hq/g-m/nvic/. Changes to this NVIC will be issued as necessary. Questions or suggestions for improvements to this NVIC should be submitted in writing to Commandant (CG-521).

Promulgation of recommendations from the IMO in MSC Circulars 1047 and 1114, concerning periodic inspection and testing of immersion suits by ships' crews. — FORMS AND REPORTS. None.

BRIAN M. SALERNO Rear Admiral, U.S. Coast Guard Assistant Commandant for Marine Safety, Security and Stewardship Encl: (1) Checklist for shipboard inspections of immersion suits by ships' crews (2) Guidelines for periodic testing of immersion suit seams and closures