Par 12 Page 11 including the requirements for USCG-approved PFDs. Requiring seaplanes on the water to comply with USCG equipment requirements in addition to the FAA equipment requirements would be an unnecessary burden on seaplane owners and operators. However, many states have statutes requiring PFDs to be carried on board vessels operating on any inland body of water for which the USCG has no jurisdiction. Navigable bodies of water may come under Federal, State, or local jurisdiction or, in a few cases, may be privately owned.
b. FAA Requirements. Section 91.205(b)(12) requires approved flotation gear for aircraft operated for-hire over water and beyond power-off gliding distance from shore. FAA approves life preservers under Technical Standard Order (TSO)-C13g, Life Preservers, and individual flotation devices under TSO-C72c, Individual Floatation Devices. In addition, § 91.509 specifies the requirements for survival equipment for overwater operations for large and turbine-powered multiengine airplanes.
(1) At one time, FAA-approved gear differed substantially from that required for navigable waterways under USCG rules. FAA-approved life preservers are inflatable designs as compared to the USCG’s inherently buoyant PFDs that may consist of solid, bulky material.
Such USCG PFDs are impractical for seaplanes and other aircraft because they may block passage through the relatively narrow exits available to pilots and passengers. In 1995, the USCG adopted structural and performance standards for inflatable PFDs used on recreational boats. These PFDs are intended for general boating activities by adults and on inland waters, or where there is a good chance of a fast rescue. However, USCG-approved inflatable PFDs are not for use by children younger than 16 years of age or by persons weighing less than 80 pounds, not recommended for nonswimmers or weak swimmers (unless worn inflated), and not for water sports like skiing or for personal water craft use. Therefore, the FAA recommends that seaplane operators who are not engaged in for-hire operations use the FAA’s TSO life preservers or individual PFDs.
(2) Life preservers approved under TSO-C13g contain fully inflatable compartments. The wearer inflates the compartments primarily by independent CO2 cartridges with an oral inflation tube as a backup. This flotation gear also contains a water-activated, self-illuminating signal light. The fact that pilots and passengers can easily don and wear inflatable life preservers (when not inflated) provides maximum effectiveness and features an uncluttered exterior surface that protects the working components and allows for unrestricted movement.
c. Buoyancy. The buoyancy in a flotation device must be distributed so that if the wearer is unconscious or disoriented in the water, the device will “self-right” the wearer (i.e., if the wearer is face down in the water, the distribution of the buoyant material in the device will “turn” the wearer face up). This is another important reason why pilots should demonstrate or supervise the proper donning of the device so that wearers will not put the device on improperly and defeat this self-righting ability. The TSO-C13g life preservers have excellent self-righting capabilities.
d. Flotation Gear Maintenance. Lifesaving equipment must be maintained in serviceable condition in accordance with the manufacturer’s recommendations. Any FAA-approved flotation gear used in operations for compensation or hire must be inspected at least every 12 months by persons authorized by 14 CFR part 43. This inspection would be included in the annual or
Par 12 Page 12 100-hour inspection for the aircraft or under any other inspection program that the operator is authorized to use.
e. Wearing of Flotation Gear During All Phases of Flight. When a standard marine life jacket or FAA-approved life preserver stored in a pouch is tucked unrestrained under a seat, it could be thrown or tossed from the seaplane with other debris in the event of an accident or capsizing. In this case, the flotation gear becomes ineffective for swimmer and nonswimmer alike. Furthermore, life jackets in sealed pouches can be awkward to remove and don in a flooded aircraft. When a survivor attempts to put on a jacket in the water, it may be difficult to find and fasten its straps and hooks. It would take considerable effort to accomplish the combined maneuver of pulling a life jacket over one’s head while in the water trying to stay afloat. If a life preserver is not worn before flight, it is practically impossible for a survivor with an injured arm, for example, to don the life preserver in time for it to be effective for survival.
Wearing an uninflated TSO-C13g life preserver at all times in the seaplane and inflating it only after exiting the seaplane would seem to be the best protection.
f. Types of PFDs. There are various types of inherently buoyant and inflatable, USCG-approved PFDs categorized by type and intended use. The USCG has indicated the advantages and disadvantages of each. To obtain information, go to the following web page:
https://www.dco.uscg.mil/CG-ENG-4/PFD/. If you do not have Internet access, contact the responsible FSDO, which can print the information out for you, or contact the USCG Auxiliary.
g. The USCG regulations allow for the approval of PFDs that inflate automatically when the inflation mechanism contacts water. Please keep the following in mind regarding USCG-approved inflatable PFDs:
(1) Type I and Type II inflatable PFDs have a higher minimum buoyancy than a Type III PFD. They will outperform a Type III PFD that does not exceed the USCG minimum requirements.
(2) Some automatics will allow the user to disarm the automatic portion of the inflation mechanism.
(3) If the user improperly disarms the automatic portion of the inflatable PFD, they might also disarm the manual portion.
(4) Wearing a PFD with the automatic portion armed would most certainly put passengers at risk of being trapped in the airplane or damaging the PFD, rendering it unusable.
(5) If the device is to be used in both a seaplane and a boat, then the device must be rearmed for boating.
h. Other Water Survival Equipment. Dive shops and marine equipment retailers offer many types of supplemental water survival equipment. Among these are buoyancy compensatory belts and small, compact alternate air source containers used by scuba divers as a backup to their regular air tanks. These containers were originally developed for military helicopter crews, can hold up to 4 minutes of air, and are relatively lightweight and easy to stow. Four minutes of breathable air could provide pilots and passengers with some extra time to don lifejackets and
Par 12 Page 13 exit an overturned seaplane that has flooded. Although these alternate air source containers may meet or exceed USCG requirements, they are not FAA-approved.
13. SUMMARY. The best time to know emergency procedures and the worst time to learn them is during an actual emergency. Inherently buoyant USCG-approved PFDs are usually impractical for most seaplanes and other aircraft because they may prevent people from exiting through doors or windows. The best protection is afforded when wearing inflatable life preservers. When wearing inflatable life preservers, pilots and passengers should always wait until clear of the seaplane before inflating. Finally, the best safety devices are useless without the proper preflight briefings and safety demonstrations.
Appendix 1 APPENDIX 1. SAMPLE PASSENGER PREFLIGHT BRIEFING CHECKLIST NOTE: This “checklist” is a guideline for pilots to use in conducting an oral preflight briefing of passengers. This list should not be used as a substitute for the briefing itself.
1. Smoking considerations: Where, when, and under what conditions.
2. Seatbelts/Shoulder harnesses: How to fasten, tighten, and unfasten; how to stow the loose end of the belt.
3. Seats: Operation forward and rearward; seat backs upright for takeoff and landing.
4. Exits: Location and operation (by demonstration) of each normal and, if applicable, emergency exit.
5. Carry-on items: Stowed properly and left on board during evacuation.
6. Situational awareness: Establish a frame of reference for left and right in relation to the aircraft exits; remind left and right are the same whether right side up or upside down. Bubbles always travel up.
7. Flotation gea r:
• Cushions: Type, location, use, and demonstration of use.
• PFDs: Type, location, use, donning, and simulated demonstration of inflation.
8. Fire extinguishers: Location and how to operate.
9. Survival equipment: Location and how to retrieve.
10. ELT or Emergency Position Indicating Radio Beacon: Location and how to turn on.
11. Pyrotechnic signaling device: Location and how to use.
12. Brace position: Demonstration.
13. Heat Escape Lessening Position: Demonstration.
14. Propeller cautions: No assistance in docking/launching by passengers unless requested by pilot; if passenger assistance is required, specific instructions on duties, placement, and caution about propellers.
15. Passengers needing assistance: Briefed individually on all above topics including who will be assisting the passenger to exit; if passenger is accompanied by an attendant, brief both.
Appendix 1 Be Safe — Wear Your PFD Most drownings occur way out at sea, right? Wrong! Fact is, the USCG reports that 9 out of 10 drownings occur in inland waters, most within a few feet of safety. Most of the victims owned PFDs, but they died without them. A wearable PFD can save your life—if you wear it.
If you or your passengers haven’t been wearing your PFD because of the way it makes you look or feel, there’s good news. Today’s PFDs fit better, look better, and allow easy movement.
A brightly colored PFD can increase your chances of rescue.
One more thing: Before you take off, make sure all on board are wearing PFDs. To work best, a PFD must be worn with all straps, zippers, and ties fastened. Tuck in any loose strap ends to avoid getting hung up.
When you don’t wear your PFD, the odds are against you. You’re taking a chance on your life.
Appendix 2 APPENDIX 2. INDEX Background Page
For-hire operations2
Definitions1
Escape/Egress7
Evacuation8
Expected Time of Survival Table10
Flotation Gear10
Buoyancy11
Comprehensive preflight briefing7
FAA requirements11
Maintenance11
Other water survival equipment12
TSO-C13g description11
USCG requirements10
Wearing of12
Heat Escape Lessening Position9
Hypothermia9
And flotation devices9
Effects10
Handling victims of10
Passenger Briefings
Considerations5
Passengers needing assistance6
PIC responsibilities4
Prelanding briefing6
Presentation4
Pretakeoff briefing, contents5
Propeller cautions6
Purpose of AC1
Related CFR Sections1
Related Reading Material1
Seaplane Preflight
Difference2
Inspecting floats and hulls2
Pumping out float compartments3
Riding low in the water2
Storage in float compartment3
Carrying external cargo4
Situational Awareness5
Statu
s of Seaplanes as Vessels2
Summary13
Survival Kit8
Use of Seatbelts and Shoulder Harnesses6
Water Survival8
Advisory Circular Feedback Form If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by contacting the General Aviation and Commercial Division at 9-AFS-800-Correspondence@faa.gov or the Flight Standards Directives Management Officer at 9-AWA-AFB-120-Directives@faa.gov.
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