b'SAFETY MATTERSSAFETYChanges toFirst Aid Kit RequirementsERIC CHRISTENSEN // PVA DIRECTOR OF REGULATORY AFFAIRS & RISK MANAGEMENTA t long last, PVA staff can nowOct. 5, 2020, and solicited public com- nersoperatingvesselsincommercial reportthattherehavebeenment on the proposal during a 60-dayservice are required to have basic first-positive regulatory changes tocomment period. The comment peri- aid training. Any application of first the first aid kit requirements containedod closed on Dec. 4, 2020. The Coastaid should be given at the discretion in Subchapters K and T. According toGuard received 13 comment submis- of the licensed mariner and not at a the U.S. Coast Guard-PVA 2022 An- sions, including one from PVA.In alevel beyond the training or capability nualReport,first-aidkitsaccountedfinalrulepublishedNov.14,2022,of the mariner administering the first for over 770 deficiencies issued to do- the Coast Guard updated the type ofaid. Analgesics are common over-the-mestic passenger vessels between 2020approvalrequirementsfortheabovecounter(OTC)medicationsthatdo and 2022. Most of these requirementsmentioned nine types of survival craftnot require medical supervision, and wereissuedformissingorexpiredequipment and replaced them with thethe decision to take them is up to the itemsintheCoastGuard-approvedrequirementthatthemanufacturerpersonwhorequeststhem.Accord-first-aid kit.PVA members have forself-certifythattheequipmentcom- ingly, the Coast Guard has decided to year voiced concern that some of theplies with a consensus standard such asretain the requirement for analgesics contentsofaCoastGuard-approvedInternationalOrganizationforStan- in first-aid kits. So, PVA did not get first-aid kit were hard to get and not updardization(ISO),CodeLife-Savingeverythingsought,butthenewre-to date with current medical practices. Appliances (LSA Code), etc. quirements are better than the old.BACKGROUND PVA COMMENTS THE REVISED REGULATIONSMany of the current requirements forPVAgenerallysupportedtheCoastTheCoastGuardmodifiedthere-survivalcraftequipmentweredevel- Guardsproposedruleforfirst-aidquirementsforfirst-aidkitssothat oped in the 1950s and 1960s and havekits where Coast Guard type approv- all first-aid kits in survival craft must notbeensignificantlyupdatedsincealwouldbereplacedbycompliancemeetthestandardsoutlinedinISO they were published. After thoroughwithISO18813.TheISOstandard18813.Inadditiontoremovingthe review of these requirements, as well aseliminated ammonia inhalants; burnCoastGuardtestingrequirements Coast Guard enforcement procedures,preparations;eyedressingpacket;for the kits, this change modified the currentmaritimeindustrypractice,tourniquet, with forceps, scissors andrequired contents of first-aid kits by and the availability of new consensuspins; and a wire splint. Since the Coastremoving the requirements for some standards,theCoastGuardbelievedGuardwasallowingthedeletionitems,addingadditionalitems,or that the additional scrutiny providedofburnpreparationsfromanISOchangingthenumberofmandatory byCoastGuardtypeapprovaldoescompliant First-Aid Kit, PVA soughtitems. The change impacts both new not increase the safety of the followingto also eliminate analgesics (aspirin).andexistingvessels,includingsmall nine types of survival craft equipment:AspirinisoftensoldonboardPVApassenger vessels.bilge pumps, compasses, first-aid kits,membervesselsandinsomecases, fishing kits, hatchets, knives (includ- operators were concerned of any po- Parts 121 and 184 of Subchapters K ing jackknives), mirrors, sea anchors,tentiallegalissuesassociatedwithaand T, respectively, titled Vessel Con-and emergency drinking water. passenger having an allergic reaction. trolandMiscellaneousSystemsand Equipment have been updated to read TheCoastGuardissuedanoticeofInresponsetoPVAsconcern,theasfollows:121.710and184.710 proposedrulemaking(NPRM)onCoastGuardstatedLicensedmari- First-aid kits.FOGHORN 30'