As stated above, the purpose of this AC is to suggest that seaplane operators provide flotation gear for occupants any time a seaplane operates on or near water. The following paragraphs will discuss the various requirements of the FAA and the USCG for the types of flotation gear and the advantages and disadvantages of each. Operators must bear in mind that seaplane operations pose unique ingress/egress situations in which a noninflatable, USCG-approved PFD, because of its bulkiness, could restrict or impair exiting the seaplane.

a. USCG Requirements. The USCG requires PFDs for each occupant on all vessels, but this does not include seaplanes. 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. Although the USCG does not consider seaplanes on the water to be vessels, State or local requirements may not follow this example. Navigable bodies of water may come under Federal, State, or local jurisdiction or, in a few cases, may be privately owned.

b. FAA Requirements. FAR Sec. 91.205(b)(11) 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) C13E and individual flotation devices under TSO C726.

(1) FAA-approved gear differs from that required for navigable waterways under USCG rules. FAA-approved life preservers are inflatable designs as compared to the USCG's noninflatable 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.

(2) Life preservers approved under TSO C13E 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 C13E life preservers have excellent self-righting capabilities; however, many USCG PFDs do not.

d. Flotation Gear Maintenance. Lifesaving equipment must be maintained in serviceable condition as per the manufacturer's recommendations. Any FAA-approved flotation gear used in operations for compensation or hire must be inspected within the preceding 12 months by persons authorized by FAR Part 43. This inspection would be included in the annual or 100 hour inspection for the aircraft or under any other inspection program that the operator may 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 C13E life preserver at all times in the seaplane and inflating only after exiting the seaplane would seem to be the best protection.

f. Types of PFDs. The following are various noninflatable, USCG-approved PFDs, categorized by type and intended use. The USCG has indicated the advantages and disadvantages of each. This discussion is for informational purposes only and is not an endorsement of any specific type of PFD for seaplane operations.

(1) Type 1 PFD - Off-Shore Life Jacket


* Turns most unconscious wearers face-up in the water

* Most effective type in rough water

* Reversible; i.e., can be worn inside out

* Comes in two sizes to fit most adults and children

Intended Use

* Abandon ship life jackets for commercial vessels carrying passengers for hire


* Best for all waters, including open ocean, rough seas, remote water, or where rescue may be slow

* Best performing PFD in rough and calm waters

* Provides best chance of survival for unconscious wearer

* When worn, best device for nonswimmers


* Bulky and not easily stowed

* May be too uncomfortable for wear for extended periods

* May not hold up to extremes of some sizes, especially child sizes

(2) Type 2 PFD - Near-Shore Buoyant Vest


* Will turn some unconscious wearers face-up in the water

* Comes in most adult sizes and three child sizes: infant, small, and medium

* Compromise between Type 1 PFD performance and wearer comfort

Intended Use

* General boating activities


* Good for calm inland waters or where there is a good chance for a fast rescue

* More comfortable than a Type 1 PFD


* May be too uncomfortable after wearing for extended period of time

* Will not turn as many people face-up as a Type 1 PFD

* Allows wearer's face to be covered by waves in rough water

* Not intended for extended survival in rough water

(3) Type 3 PFD - Flotation Aid


* Provides a stable, face-up position in calm water for a wearer floating head up

Intended Use

* General boating or specialized activities such as water skiing, hunting, fishing, canoeing, kayaking, etc.


* Available in a wide variety of sizes for a good fit

* Good for calm inland waters or where there is a good chance of survival

* Designed so that wearing it will complement boating/water activities

* Should be comfortable to wear for extended periods

* Comes in a wide variety of designs to fit its use


* Wearer may have to tilt head back to avoid going face down

* Will not hold face of an unconscious person clear of the water

* In rough water, wearer's face may often be covered by waves

* Not for extended survival in rough water

(4) Type 4 PFD - Throwable Device


* Grasped and held by the user until rescued

* Used with a lanyard, a "person overboard" pole, a locator light, or a smoke signal

Intended Use

* For use on small boats in calm water or inland water with heavy boat traffic where help is always nearby

* For use on large boats as an extra device for persons overboard


* Provides enough buoyancy for users to hold their heads out of the water

* Can be thrown to someone in the water within 40 feet

* Can be used as a seat cushion or mounted on wall brackets for immediate availability

* Good back-up buoyancy when used with a wearable PFD


* Not for unconscious or exhausted persons

* Not for nonswimmers or children

* Not for rough water survival

g. Other Water Survival Equipment. Dive shops and marine equipment retailers offer many types of supplemental water survival equipment. Among these are buoyancy compensator belts and small, compact "spare air" containers used by scuba divers as a backup to their regular air tanks. These "spare air" containers can hold up to 4 minutes of air, and they are relatively lightweight and easy to stow. Four minutes of breathable air could provide pilots and passengers with some extra time to don life jackets and exit an overturned seaplane that has flooded. Although these "spare air" containers may meet or exceed USCG requirements, they are not FAA-approved.
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