To Wear or Not to Wear
by Paul Armstrong
Many seaplane pilots involved in water accidents are found with their life jackets still in the seatback (or baggage compartment!), unused. Why?
Last summer, I was reviewing the boating regulations in relation to the numerous new inflatable "constant-wear" life jackets that many people are using instead of the traditional life jackets or personal flotation devices (PFD) that have been in use for many years. I came to the conclusion that a jacket that is worn at all times has to be safer than the traditional yellow inflatable "Mae West" that has been in use since prior to WW II. The difference is the "Mae Wests" are now kept in a nice neat storage pouch instead of being worn and ready for instant use.
The reasons they are not worn are simple:
- They are uncomfortable to wear.
- They are surprisingly fragile, as they do not have a protective outside covering and are not designed for constant wear.
- They do not look good (read "cool"). This unfortunately is probably the biggest, although the least credible, reason for not wearing them-who says vanity can't be dangerous to your health!
So, what are the alternatives? Life preservers of inherently buoyant type (foam) that meet with the approval on the jacket of CGSB 65.11-M88 (adult) or CGSB 65.15-M88 (child) may be legally used in a seaplane, but are certainly not recommended. The buoyancy of the life jacket will pin you to the ceiling-which is now the floor in an overturned aircraft-and make egress difficult or impossible (not to mention the increased bulk getting through small doors or widows). They also aren't very comfortable to wear when strapped into an aircraft.
Turning to inflatable PFDs, the only ones that are legal for aircraft use must be labelled with a TSO C-13d, e, or f approval. The rules are identical for Canadian and U.S.-registered aircraft, which is not the same as boating life preservers, where, despite free trade, Canada does not accept U.S. Coast Guard approval.
So, what about the inflatable constant wear "horseshoe" vests that can be purchased at marine supply and other consumer goods retailers? Chances are they don't meet TSO C-13d, e, or f approval (they usually meet Canadian Coast Guard "CCG" boating approval only). They may look just about the same on the outside, but are different in the following major ways:
- They have one inflatable chamber instead of the two required in the aviation-approved jacket.
They have slightly less overall floatation than the aviation jacket
(35-lb buoyancy versus 37-lb for the aircraft jacket).
- They lack the whistle and the 8-hour water-activated light that the aviation jacket comes with.
- They don't have a fire resistant (NOMEX) outer cover or heavy nylon protective cover that constant-wear aviation jackets have.
Interestingly, another inconsistency between the Canadian boating and aviation regulations is that boating regulations do not allow inflatable life preservers to be used by children under 16 years of age, whereas aviation has no such restriction.
There are only two alternatives to meeting the requirements for a seaplane when a constant-wear type inflatable is desired. You can use a boating improved inflatable in addition to carrying the "Mae West" approved type on board, or you can use an aircraft TSO C13d, e, or f approved jacket. At present, the only constant wear type TSO C13f life jacket that is manufactured in Canada is the Mustang Survival model MD1127, although foreign inflatables with TSO C13d, e, or f approval are legal.
Fly safe and may you never have to pull the inflation lanyard!
The original version of this article was previously published in the COPA Flight magazine, and can be found on the Ontario Seaplane Association's Web site. It has been slightly edited for space. We felt the message was worth repeating in the Aviation Safety Letter. - Ed.