Limit two-year servicing for life rafts

Summary#

This is a proposed change to the Life Saving Equipment Regulations by Transport Canada to limit when vessels can use a two-year servicing cycle for inflatable survival gear (like life rafts). Under the proposal, the two-year option would only be allowed for vessels that operate only in months where the local monthly historical average daily minimum air temperature is above 0°C. The change is aimed at reducing the risk that freeze–thaw damage will make inflatable equipment fail in an emergency.

What it does#

• Adds a new condition to qualify for the existing two-year servicing interval for inflatable survival equipment: the vessel must operate only during months when the monthly historical average daily minimum air temperature (from the weather station nearest the vessel, as compiled by the Department of the Environment) is greater than 0°C.
• Keeps the rest of the servicing rules in the Life Saving Equipment Regulations the same. The change would also apply to life rafts on vessels covered by the Fishing Vessel Safety Regulations and the Small Vessel Regulations because those rules reference the Life Saving Equipment Regulations.
• This is a proposed amendment (published in Canada Gazette, Part I). If finalized, it would come into force six months after publication in Canada Gazette, Part II. The analysis expects costs to begin in 2023.

Who's affected#

• Primarily small commercial fishing operators in the Atlantic and Quebec regions. There are about 15,000 fishing vessels in the Atlantic and 1,200 in Quebec; roughly 40% of those could be eligible for the two-year servicing rule in general (about 6,000 Atlantic and 480 Quebec), but the government estimates only about 20 vessels in the Atlantic and 2 in Quebec would actually be affected by losing the two-year option under the new temperature rule.
• Manufacturers, maintenance stations, and inspectors may notice small changes in servicing schedules, but the regulatory analysis focuses on vessel owners.
• The proposal notes uncertainty about vessels in some other regions (northern British Columbia or Ontario), but expects those numbers to be negligible.

Why it matters#

• Inflatable survival equipment can become stiff and more likely to be damaged when exposed to freezing and thawing. That raises the risk of punctures or failures when the equipment is needed in an emergency. The amendment aims to reduce that safety risk by keeping the two-year servicing option for only those vessels that truly operate in milder months.
• The government estimates the total incremental cost to affected fishing operators at about $74,845 over a 10-year period (present value). That breaks down to roughly $74,647 in extra servicing costs and $198 in extra record-keeping costs. Servicing is estimated at about $1,100 per service.
• For the small number of likely affected businesses (about 22), the analysis says the cost works out to roughly $4,000 per business over 10 years, or about $540 per year on average. The proposal keeps flexibility for vessels in mild climates while targeting a safety concern for those operating where freezing can occur.
• The analysis assumes the biggest safety benefit is preventing equipment failure and thus potential injury or loss of life at sea. The proposal was discussed with stakeholders at the Canadian Marine Advisory Council and, according to the analysis, no major concerns were raised.