Non-pyrotechnic Distress Signal Lamp

Electrical and electronic topics for small boats
jimh
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Non-pyrotechnic Distress Signal Lamp

Postby jimh » Fri Apr 01, 2016 7:36 am

We have all been waiting a long time for a manufacturer to produce a non-pyrotechnic distress signal lamp to replace our expensive collection of expired and soon-to-expire flares and allow us to comply with the the USCG regulations for mandatory carriage of night distress signals. Has SIRIUS SIGNALS finally done it?

Image

SIRIUS SIGNALS has recently introduced their SOS DISTRESS LIGHT, and claim the following attributes:

--complies with all U.S. Coast Guard requirements for “Night Visual Distress Signals” as found in the Code of Federal Regulations: 46 CFR 161.013

--LED lamp flashes ONLY the SOS light sequence

--when combined with a daytime distress signal flag (included in package),this electric flare meets ALL USCG Federal Requirements for DAY and NIGHT use in lieu of traditional flares;

--floats with lens-up to optimize both the all-around horizontal and vertical light beams;

--no expiration or disposal concerns;

--operated by three C-cell alkaline batteries;

--made in U.S.A.

MSRP: $100 via on-line ordering

Will you be spending $40 on flares this season? Or $100 on the SIRIUS SOS LIGHT?

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brill
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Re: Non-pyrotechnic Distress Signal Lamp

Postby brill » Fri Apr 01, 2016 8:18 am

Thanks for the info. That certainly looks like a great option. I am considering buying one of these non-pyrotechnic distress signal lamps. I will probably keep a printout of eCFR 33 CFR 175.130 Visual Distress Signals Accepted, in the event that I am inspected and the inspector is looking specifically for pyrotechnic flares. I am less concerned with the USCG; but in Massachusetts the waters are also patrolled by Mass Environmental Police, State Police, and local Harbormasters.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby porthole » Fri Apr 01, 2016 8:20 pm

Remember for this device to qualify, you still need a daytime visual signal, unless you never go out at daytime.
The device sells with a daytime distress flag (orange flag with a black ball and square shapes)

When combined with a daytime distress signal flag (included in package),this electric flare meets ALL USCG Federal Requirements for DAY and NIGHT use in lieu of traditional flares
Thanks,
Duane
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jimh
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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Fri Apr 01, 2016 10:58 pm

I don't think pyrotechnic flares qualified as a daytime distress signal, either. Can we get an expert opinion on that?

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Re: Non-pyrotechnic Distress Signal Lamp

Postby porthole » Fri Apr 01, 2016 11:08 pm

jimh wrote:I don't think pyrotechnic flares qualified as a daytime distress signal, either. Can we get an expert opinion on that?



They do. The distress flag was only required if you did not have an approved signaling device, e.g. flare.

TABLE - Visual Distress Signal Requirements for Vessels
Thanks,
Duane
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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 9:41 am

Duane's cited table (linked above) is not quite authoritative. We have to turn to the Code of Federal Regulations to look for the actual regulation that endorses use of flares as day distress signals. Let's hunt this down. First we find that required distress signal carriage varies with the type of water and distance offshore.

[Oops--Duane correctly noted later I had cited the wrong section of the CFR, using one that applied to commercial boats, not recreational boats. To avoid confusion, I deleted this.--jimh]

Note that there are two conditions set out: day and night. This is where one finds the actual codified regulation that "3 approved flares" can constitute both the day visual distress signal and the night visual distress signal. The inference in the second mention of "3 approved flares" seem to me that they must be referring to the initial mention of the flares and their various approval series. So for hand held flares to qualify for either day or night, they must meet "approval series 160.121 or 160.021." Now we look at those specifications, found in 46 CFR Part 160 - LIFESAVING EQUIPMENT.

Here are excerpts from 46 CFR Part 160, Subpart 160.021 - Hand Red Flare Distress Signals regarding luminosity and chromaticity: "The average luminous intensity of a test specimen shall be not less than 500 candela." "The color of the burning signal must be vivid red as defined by sections 13 and 14 of the 'Color Names Dictionary.'"

Reading this section of the federal regulations is quite interesting. I recommend everyone take a look at 46 CFR 160.021-4 - Approval and production tests if they ever had any thoughts of why a flare qualified for use by these regulations costs so damn much compared to a highway flare.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 9:48 am

[Deleted some erroneous mentions of CFR that did not apply.]

If also occurs to me that if you are boarded by the USCG during DAYLIGHT, why would you have to demonstrate that you carried NIGHT distress signals? If you are boating during daylight hours, it appears to me that you only need to have distress signals that meet the daylight criterion. It cannot be reasonable for the USCG to infer that you might sometime be boating at night and must have those signals, too. If that were a reasonable inference, the USCG could then reasonably infer you might be more than 3-miles from the coastline and require you to carry a lot more visual distress signal gear. To make an analogy, could a highway police officer cite you for having a defective headlight on your vehicle if you were stopped during daylight? I don't recall ever being asked to demonstrate that my vehicle headlights worked during a daytime stop by a highway traffic officer.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 10:49 am

Re when a recreational boat is required to carry day or night signals, I found a A BOATER’S GUIDE TO THE FEDERAL REQUIREMENTS FOR RECREATIONAL BOATS that mentions this. Here is an excerpt:

Visual Distress Signals (33 CFR 175.101)

Vessels operating on U.S. coastal waters, the Great Lakes, and territorial seas, as well as those waters connected directly, up to a point where the waterway is less than two nautical miles wide, must be equipped with U .S . Coast Guard-approved visual distress signals (VDS)."

"The following vessels are not required to carry day signals, but must carry night signals when operating from sunset to sunrise:
--Recreational boats less than 16 feet in length .
--Boats participating in organized events, such as races, regattas, or marine parades .
--Open sailboats less than 26 feet in length that are not equipped with propulsion machinery.
--Manually propelled boats.


What's interesting is the mention that boats "...must carry night signals when operating from sunset to sunrise..." Does that mean they also have to carry night signals when operating from sunrise to sunset?

Here is a further conundrum:

Pistol-launched and hand-held parachute flares and meteors have many characteristics of a firearm and must be handled with extreme caution. In some states and Canada they may be considered a firearm and prohibited from use. Be sure to check with your state boating agency.


By federal regulations, you might need to carry parachute flares, but your state might prohibit them. Really? Whose authority governs in that case? The publication carries the imprint of the Department of Homeland Security and appears to be published by the USCG.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 10:59 am

OK--here is the definitive answer from federal regulations at 33 CFR 175.110

§ 175.110 Visual distress signals required.

(a) ...Devices suitable for day use and devices suitable for night use, or devices suitable for both day and night use, must be carried.


I think that means we are stuck with always carrying both day and night approved visual distress signals, even if we don't go boating at night.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby porthole » Sat Apr 02, 2016 12:33 pm

jimh wrote:Duane's cited table (linked above) is not quite authoritative. We have to turn to the Code of Federal Regulations to look for the actual regulation that endorses use of flares as day distress signals. Let's hunt this down. First we find that required distress signal carriage varies with the type of water and distance offshore.

According to the Code of Federal Regulations, in 46 CFR 28.145, DISTRESS SIGNALS,


Two comments:
1st, the USCG local boat operators are going to go by what is in the USCG guidelines, my link above is from a USCG.MIL URL
Expecting them to know and carry the CFR's with them is a bit much.

2nd, your link is for a Subchapter C vessel - un-inspected passenger vessel.


The vessel "Continuous Wave" is not an un-inspected passenger vessel - unless - Captain Jim H is carrying passengers for hire, no more then six passengers, and he has in his possession on board his USCG Merchant Mariner Document with at least the most basic endorsement, OUPV, "operator of Un-inspected Passenger Vessel"

Then, Jim would have to meet the CFR's for Subchapter C and the required safety gear on board, including all those flares.

[Yes--Duane is correct, the CFR I cited is not for recreational boats. Thanks for clarifying that.--jimh]
Last edited by porthole on Sat Apr 02, 2016 1:03 pm, edited 1 time in total.
Thanks,
Duane
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Re: Non-pyrotechnic Distress Signal Lamp

Postby porthole » Sat Apr 02, 2016 1:01 pm

jimh wrote:Now we look at those specifications, found in 46 CFR Part 160 - LIFESAVING EQUIPMENT


Again we are looking too deep these are commercial regulations. [Those sections are where you find the governing specifications for what constitutes accepted flares.--jimh]

If you backup a little on that link to chapter 1 you will see many of the various vessels that part of the CFR covers.

3 stand out as these are the type of vessels the recreational mariner will frequently see or come in contact with.
Chapter C OUPV
Chapter T Small passenger vessel
Chapter H Passenger vessels

[Yes, but it just happens that the regulations that specify how flares are to be accepted are in this section, and are referred to by other sections.]
Thanks,
Duane
2016 World Cat 230DC
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porthole
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Re: Non-pyrotechnic Distress Signal Lamp

Postby porthole » Sat Apr 02, 2016 1:17 pm

Thanks,
Duane
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jimh
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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 2:23 pm

Duane--You are right, I earlier cited some inappropriate regulations that were for commercial vessels. [But in the interest of keeping this more readable and on topic, I deleted all those lovely images of various commercial boats you posted. Please forgive me.]

Let me redo this in a more logical order. First, let's look at the applicability of 33 CFR Part 175, Subpart C - Visual Distress Signals

§ 175.101 Applicability.

This subpart applies to boats on the coastal waters of the United States and on the high seas beyond the territorial seas for boats owned in the United States.


Next we need to look at definitions of visual distress signal and coastal waters.

§ 175.105 Definitions.
(a) Visual distress signal means a device that is approved by the Commandant under 46 CFR Part 160 or certified by the manufacturer under 46 CFR Parts 160 and 161.
(b) Coastal waters means:
(1) The U.S. waters of the Great Lakes (Lake Erie, Huron, Michigan, Ontario, and Superior);
(2) The territorial seas of the United States; and
(3) Those waters directly connected to the Great Lakes and territorial seas (i.e., bays, sounds, harbors, rivers, inlets, etc.) where any entrance exceeds 2 nautical miles between opposite shorelines to the first point where the largest distance between shorelines narrows to 2 miles, as shown on the current edition of the appropriate National Ocean Service chart used for navigation. Shorelines of islands or points of land present within a waterway are considered when determining the distance between opposite shorelines.

Cf.: https://www.law.cornell.edu/cfr/text/33/175.105

Next we look at what is required for what boats. Note that most recreational boats are going to be covered by the definition of "a boat 16 feet or more in length" that is used in this section:

§ 175.110 Visual distress signals required

(a) No person may use a boat 16 feet or more in length, or any boat operating as an uninspected passenger vessel subject to the requirements of 46 CFR chapter I, subchapter C, unless visual distress signals selected from the list in § 175.130 or the alternatives in § 175.135, in the number required, are onboard. Devices suitable for day use and devices suitable for night use, or devices suitable for both day and night use, must be carried.

(b) Between sunset and sunrise, no person may use a boat less than 16 feet in length unless visual distress signals suitable for night use, selected from the list in § 175.130 or § 175.135, in the number required, are on board.


And I finally we find the list we are to select from:

§ 175.130 Visual distress signals accepted.
(a) Any of the following signals, when carried in the number required, can be used to meet the requirements of § 175.110:
(1) An electric distress light meeting the standards of 46 CFR 161.013. One is required to meet the night only requirement.
(2) An orange flag meeting the standards of 46 CFR 160.072. One is required to meet the day only requirement.
(3) Pyrotechnics meeting the standards noted in Table 175.130.


Cf.: https://www.law.cornell.edu/cfr/text/33/175.130

Reproducing TABLE 175.130 as an HTML table in-line here is difficult. Please look at in the CFR. But here is a plain text version of the information in table:

Table 175.130—Pyrotechnic Signal Devices

[Type: Day or Night Use: Number Required]

Hand Held Red Flare Distress Signals: Day and Night: 3-required (Must have manufacture date of 1 Oct. 1980 or later.)

Floating Orange Smoke Distress Signals; Day Only: 3-required

Parachute Red Flare Distress Signals: Day and Night: 3-required (These signals require use in combination with a suitable launching device approved under 46 CFR 160.028.)

Hand-Held Rocket-Propelled Parachute Red Flare Distress Signals: Day and Night: 3-required

Hand-Held Orange Smoke Distress Signals: Day Only: 3-required

Floating Orange Smoke Distress Signals: Day Only: 3-required (These devices may be either meteor or parachute assisted type. Some of these signals may require use in combination with a suitable launching device approved under 46 CFR 160.028._

Distress Signal for Boats, Red Aerial Pyrotechnic Flare: Day and Night: 3-required

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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 2:59 pm

To get back to some reality, yes, carrying three approved pyrotechnic signals is one way to comply and has been for a long time the only way to comply at night. But the whole point of this discussion is to avoid carrying pyrotechnics and use an electrical signal at night and a simple visual signal during the day. I think a lot of recreational boaters will choose that option.

Here is a good discussion from a few years ago on this topic:
http://continuouswave.com/ubb/Forum1/HTML/022044.html

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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sat Apr 02, 2016 4:04 pm

Now to get back to non-reality, it looks like if you are just an inland lake boater, that is, not on waters defined as coastal waters in the regulations cited above, there is no federal requirement to carry visual distress signals--unless your state mandates them.

Looking at Michigan, my state, it seems to defer to the federal definitions, and thus I presume I don't need visual distress signals if I am on an inland lake, say Mullet Lake.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby Oldslowandugly » Sat Apr 02, 2016 9:32 pm

So as a coastal boater with a 15 foot Sport I am not required to carry anything during the day but need night signals after sunset. If the SOS electric light satisfies that I will be a happy camper for sure.

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Re: Non-pyrotechnic Distress Signal Lamp

Postby porthole » Sat Apr 02, 2016 10:50 pm

When my current batch of flares expire this year, I will be replacing them with the electric version. Flares are a real pain to get rid of, especially some of the bigger SOLAS versions.
Thanks,
Duane
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Re: Non-pyrotechnic Distress Signal Lamp

Postby jimh » Sun Apr 03, 2016 8:17 am

For recreational boaters to replace flares with an electric signal lamp is actually being encouraged by some boating groups, including the USCG. Here is an excerpt from a USCG communication on this topic:

We're very aware of problems with disposal of expired pyrotechnic distress signals. They've been a concern of the National Boating Safety Advisory Council (NBSAC) as far back as 2002, with a formal presentation at the latest meeting (November 9-11, 2012) re-emphasizing the safety and environmental hazards of pyrotechnic distress signals currently available for recreational boaters. Very recently, the Radio Technical Committee for Maritime Services established a new subcommittee (RTCM SC132) to undertake the task of developing a standard for non-pyrotechnic electronic visual distress signals (eVDSD) such as LED and laser devices that have recently become available. This effort has the support of the Coast Guard, NBSAC, and electronic signal manufacturers, as well as interest from Canada and several European countries; and may possibly lead to approval of such devices as an alternative to pyrotechnic types in the future.


Source: David Hart as published in http://continuouswave.com/ubb/Forum1/HTML/022044.html

The SIRIUS SIGNALS visual distress signal lamp we are discussing here appears to be one of the first devices to be qualified with the USCG.

The RTCM SC132 committee reported the following update at the July 2015 meeting of the US GMDSS Task Force:

RTCM SC-132 on Visual Emergency Signaling Devices. This new Committee was chartered at the request of the Coast Guard to review devices that might be used to replace flares on vessels. In addition to safety factors, it has been reported that in 87% of reported flare sightings, no distressed vessel was found. The U.S. Coast Guard Research and Development Center is studying the most effective light characteristics for this purpose.

Source: as published in http://www.gmdssforum.net/index.php?topic=134.0

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Re: Non-pyrotechnic Distress Signal Lamp

Postby Oldslowandugly » Tue May 03, 2016 7:44 pm

I got it! Wow, this is a winner. I love it. So must a lot of folks because most vendors are out of stock. It is about $100 everywhere but I found it at Overton's and with a coupon it was $10 off with free shipping. They advise against looking directly at the flash and that is no joke. BRIGHT! EDIT: This is small enough to fit inside the old OLIN/ORION flare storage canister. I added some Styrofoam packing wrap so it won't bounce around. A set of distress whistles, a signaling mirror, and the day alert flag all fit nicely too. My canister is pretty old but West Marine still sells it for about $12.

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