Response to PWIA Request for Exemptions
from Recreational Boat Standards

USCG-1998-4734

Question:

1.  Should the Coast Guard formally recognize a definition of PWC?

Response:

Yes. But because there is a mandate for change in the design of PWC to include off-throttle steering and braking capabilities, the definition should not limit itself to the present design of a PWC. Since there is no other water-going vehicle like a PWC, the definition should be easy enough. Sub-categories of PWC may include those craft which are designed to carry more than one individual.

A simple definition is:

An inboard vessel less than 13 feet in length which uses an internal combustion engine powering a water jet pump as its primary source of propulsion, and is designed to be operated by a person or persons positioned on, rather than within the confines of the hull. The vessels are designed to carry from one to three persons and be operated by a person sitting, standing or kneeling on the vessel.1

So long as PWC remain vessels unlike traditional boats, with no sides to prevent falling overboard, the number of people who can be potentially injured by falling from the craft, or injured by exposure to collision with other craft or fixed objects because of no enclosure should not effect the basic definition of a PWC.

Other terms, such as jet skis, water scooters, and sport boats are not adequate, because the industry itself has, for the most part, adopted the term PWC in self-description.

Question:

2. Should the Coast Guard continue to require PWC manufacturers to petition the Coast Guard for exemptions to the manufacturing regulations for recreational boats?

Answer:

Yes. The PWIA should be required to petition for any exemptions to regulations for recreational boats because they are unlikely to self-police. Although the industry has recently expressed interest in safety, it is the same industry which pushed to develop a vehicle which began at only about 30 mph to a vehicle which will now exceed 60 mph, ignoring the Human Factor relative to off-throttle steering.

Question:

3.*  Should the Coast Guard develop a method other than the exemption process to require PWC manufacturers comply with Federal recreational boating safety laws?

Answer:

Yes. SAE standards along with regulations that address accidents associated with the specific design of PWC would be most desirable. Industry self-regulation has not been adequate in providing safety to PWC users.

* Since submission of this statement, the Coaliton has learned that the Coast Guard had to pull a report by a SAE member because of heavy industry bias, therefore we have retracted this statement, and ammended it to say we would prefer to see an unbiased entity set standards for the industry.

Question:

4.  The Coast Guard also grants exemptions for other categories of non-conventionally designed recreational boats. Some include airboats, hovercraft, submarines, drift boats, race boats, and mini bass boats. Should the Coast Guard develop a method other than the exemption process to require those non-conventionally designed boats to comply with Federal recreational boating safety laws?

Answer:

Yes. The Coast Guard should consider design, and accident statistics and data in the same way it has considered them relative to PWC when developing methods other than the exemption process for other non-conventional boats.

1. Phillip L. Brown and Jeffrey T. Embry

 

©2007 Coalition of Parents and Families for Personal Watercraft Safety.  All rights reserved.