USCG Nav Light Alert

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Mikem

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Dec 20, 2009
753
Hunter 466 Bremerton
I forward this alert from the USCG

United States Coast Guard
Inspections and Compliance Directorate
Marine Safety Alert 04-13
May 22, 2013
Washington, DC

Navigation Lights - Not!

The Coast Guard has recently become aware of the uninspected towing vessel industry using inappropriate navigation lights that fail to meet the criteria for use onboard any vessel; SEACHOICE Products LED Navigation Light, SCP #03201 shown below. Online research shows many outlets for the sale of this product. It is possible that this product may be in widespread use in the recreational boating industry as well.

The SEACHOICE Products and other catalogs advertise it as a "LED classic navigation light." Packaged individually, the item looks as shown on the left. The package indicates incorrect usage as a "masthead light." When web-searched the retrieved information presents it as a "masthead" or "navigation" light. Neither of these applications are correct and the fixture should not be used on any vessel in an effort to meet the navigation rules.

Masthead lighting requires an arc of 225 degrees visibility and stern lighting requires an arc 135 degrees visibility, for a total range of 360 degrees visibility. Depending on the type of vessel there are also light, color and range of visibility requirements.

The SEACHOICE product SCP 03201 has an arc of 180 degrees visibility and is not applicable to any requirement.

The Coast Guard strongly recommends that owners / operators of any vessel who installed this particular SEACHOICE product (#03201 only) as a masthead, stern or other type of navigation light to remove it and replace it with a proper light that meets the requirements for the vessel and application.


Recreational boaters who have questions should contact the Coast Guard Auxiliary. Commercial vessel owner / operators who have questions should contact the Coast Guard Sector or Marine Safety Unit.

Standards for color, intensity and arc of visibility can be found in Annex I of COLREGs or:
* 33CFR84.13 - Color specification of lights
* 33CFR84.15 - Intensity of lights
* 33CFR84.17 - Horizontal sectors
* 33CFR84.19 - Vertical sectors
*

Special thanks to Coast Guard Sector Detroit for identifying this issue.

This document is provided for informational purposes only and does not relieve any domestic or international safety, operational or material requirement. Developed by the Office of Investigations and Casualty Analysis, United States Coast Guard Headquarters, Washington, DC. Questions can be addressed to the sender.




*********





For more related casualty and safety information access http://marineinvestigations.us To subscribe email kenneth.w.olsen@uscg.mil



 
Feb 6, 1998
11,436
Canadian Sailcraft 36T Casco Bay, ME
This is why it is always best to buy nav lights that say USCG or ABYC A-16 on them. It means they have been tested to the applicable standards.

When buying navigation lights please be sure they are USCG or ABYC A-16 compliant. There are many companies who do the right thing and send their products to the labs for testing. There are also many unscrupulous companies who will steal your money and give younon-certified or flat out non-compliant navigation lights.

Note the USCG 2nm:




Trust me this "issue" does not stop with Seachoice there are MANY nav lights sold as such that DO NOT meet the standards. One of the most popular are the Davis anchor lights...

Also converting an existing incandescent nav light to LED renders it a non-certified nav light... Many owners have done this but the USCG is starting to wake up on this issue.
 
Aug 16, 2009
1,000
Hunter 1986 H31 California Yacht Marina, Chula Vista, CA
Maine, why does the conversion of a unit with the proper degree of visibility from incandescent to LED render the light non-compliant? Thought LEDs were supposed to be brighter and more reliable in addition to demanding less juice.
 
Feb 20, 2011
7,794
Island Packet 35 Tucson, AZ/San Carlos, MX
The fixture and lamp are certified as a unit, I believe. The CG doesn't certify lamps alone.
 
Nov 8, 2010
11,385
Beneteau First 36.7 & 260 Minneapolis MN & Bayfield WI
Its also important to note the the USGC's issue with this particular SEACHOICE lamp had nothing to do with the fact that it is LED based. It was the projection angle that is off, wrong, and dangerous. Personally I think all the Seachoise stuff is crap.

Regarding LED bulbs in existing fixtures. The USGC approves lights for SALE, not USE. The regs for use DO NOT say the light on your boat HAS to be USCG approved, just meet projection angle and visibility requirements. Its perfectly fine to add LED bulbs for existing fixtures if you are sure they will meet the visibility range requirements. You could use an old oil lamp if you wanted to, if it had the range.

Coast Guard regs for light operation.

http://www.navcen.uscg.gov/?pageName=navRulesContent#rule20
 
Mar 20, 2012
3,983
Cal 34-III, MacGregor 25 Salem, Oregon
Jackdaw is correct... its the angle of the beam that is the problem.

I agree with Maine Sail that many lights, (as well as some other boating items), are not all coast guard approved. but as long as they meet the minimum requirements as set forth by the coast Guard or other regulating law enforcement, it isnt a violation to use them.

the seachoice light that is being referred to in the article, was built for and intended to be used as a masthead light.... but it is a violation to use it on a boat due to not meeting the requirements, but you can use a lantern in its place and be well within the minimum requirements.... so, it doesnt take much to meet the minimum.
you can almost always have more than the requirements call for, but you always need to have at least the minimum....

im sure this will drive some to be searching for the CG approval on their equipment, which is not a bad thing at all, but I think rather than some people going into a frenzy and replacing everything on the boat that isnt stamped with a CG approval, they should check and see if it meets the minimum requirements, AND in ADDITION, give your local coast guard auxiliary a call so they can come and give you a FREE vessel inspection to see if you have missed anything. it doesnt matter if your boat is on the hard in your driveway or in the water at the marina. its a free service to help boaters be safer. and contrary to what some people think, they WONT fine you if they find you are out of compliance. they are helpful and friendly people and will give you recommendations on how to remedy the issue and make you a safer boater thru knowledge rather than citations and fines....:D
 
Jan 30, 2012
1,093
Nor'Sea 27 "Kiwanda" Portland/ Anacortes
Rule 21 (a) states that a "Masthead light" means a white light placed over the fore and aft centerline of the vessel showing an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel . . .

There is no "minimum compliance" aspect - and a garden variety lantern does not comply.

Charles
 
Nov 8, 2010
11,385
Beneteau First 36.7 & 260 Minneapolis MN & Bayfield WI
Rule 21 (a) states that a "Masthead light" means a white light placed over the fore and aft centerline of the vessel showing an unbroken light over an arc of the horizon of 225 degrees and so fixed as to show the light from right ahead to 22.5 degrees abaft the beam on either side of the vessel . . .

There is no "minimum compliance" aspect - and a garden variety lantern does not comply.

Charles
You're taking that a bit too literally... ;^) My point is that is you have enough light and limit where it projects to match the spec, you are OK.

At our last boarding I asked the CPO about LED bulbs in anchor lights.

He asked 'Does it shine in 360 degrees'? I said yes.
He asked 'Is it visible for 2 miles'? I said yes.
He said 'all good'.
 
Jan 30, 2012
1,093
Nor'Sea 27 "Kiwanda" Portland/ Anacortes
A lantern does not a masthead light make. I can't think of any way one could read Rule 21(a) in such a way as to permit a garden variety lantern to become a masthead light?
 
Nov 8, 2010
11,385
Beneteau First 36.7 & 260 Minneapolis MN & Bayfield WI
A lantern does not a masthead light make. I can't think of any way one could read Rule 21(a) in such a way as to permit a garden variety lantern to become a masthead light?
Charles, You're getting pedantic now. My point, clearly stated again, is that ANY LIGHT SOURCE that can be made to meet the range and projection angle requirements meets the USCG requirement 21 for lighting. Do you disagree?

Before the day of DC power on boats, ships use lanterns with wood blockers to limit light. If bright enough this method is still legal.
 
Feb 6, 1998
11,436
Canadian Sailcraft 36T Casco Bay, ME
Its also important to note the the USGC's issue with this particular SEACHOICE lamp had nothing to do with the fact that it is LED based. It was the projection angle that is off, wrong, and dangerous. Personally I think all the Seachoise stuff is crap.
I agree 100%. I suspect Sea Choice simply sources the cheapest stuff they can get their hands on.

Regarding LED bulbs in existing fixtures. The USGC approves lights for SALE, not USE.
The USCG does not "approve" anything. The Code of Federal Regulations (CFR) sets & defines the "requirements" for nav lights to meet to be considered a "navigation light". These parameters include color temp, distance, horizontal and vertical sectors. To be a "navigation light" the product needs to be able to pass third party testing by a lab like Imanna, who does this sort of certification.

it is also Federal law that any boat built, and fitted with navigation lights, must have USCG or ABYC A-16 "certified" navigation lights. If you own a boat built within the last 25+/- years it was required to be built to federal law regarding navigation lights.

The regs for use DO NOT say the light on your boat HAS to be USCG approved, just meet projection angle and visibility requirements. Its perfectly fine to add LED bulbs for existing fixtures if you are sure they will meet the visibility range requirements. You could use an old oil lamp if you wanted to, if it had the range.
Again it is not just rage requirements that make a navigation light a navigation light it is horizontal, vertical, color temp and range that make a light a "navigation light". It is all in the Code of Federal Regulations. Anything not meeting all those parameters is not technically a "navigation light" by the CFR definition of what a navigation light is required to do..

The reason "range" is stated so often in the COLREGS is because for different sized vessels they require different "ranges" of distance. They don't need to spell out color, horizontal or vertical sectors as much because most all nav lights have the same requirements other than "range"... You could have a 1nm light and a 2nm light but both lights would have to meet the same color, vertical and horizontal sectors thus the reason the regs talk mostly about range.

Considering there are many manufacturers who have failed this expensive testing, taking the design of a nav light into your own hands leaves you open for providing the proof it met the criteria.

You, as a used boat owner, are not required to have "certified" nav lights or install them unless you are a boat builder or re-seller/broker/dealer. If you buy a new boat in the US it will have certified nav lights or the builder/installer broke federal law. However you certainly can potentially open yourself up to liability in the event of a night time collision and the duty is on you to prove they met the requirements and that the accident was not caused by your "home baked" nav light failing to meet color, distance, horizontal or vertical sector requirements.. Th COLREGS do however mandate, by the words "SHALL COMPLY" as related to navigation lights and the CFR specifications.

One of my biggest peeves is improperly colored navigation lights from the use of LED bulbs behind red or green lenses, this issue affects all boaters. On numerous occasions I have had trouble identifying a navigation light that was the wrong color. On one occasion I was so frustrated I motored by in the dinghy afterwards and could see the AutoZone grade blue LED behind the lens... I suppose it better than he used a light rather than none but it made it awfully confusing on the water..

Honest manufacturers like Bebi and Imtra specifically warn about using "non certified" bulbs..

Bebi says this:

"If you have insurance and you are involved in a collision at night, your claim may be dis-allowed if you have a non-OEM light bulb, whether it is an LED, incandescent, halogen, or fluorescent, in the fixture, regardless of the real reason for the collision."


Having been involved in a night time death, best friends father, that involved a solid week of forensic navlight & navlight testimony, well before LED's, I am fairly confident that if my friends father had been using aftermarket LED's the drunk that killed him, by running him over, would have walked..

The defense lawyers left no stone unturned in their nav light investigation from voltage, to possible wiring faults to the flag possibly obstructing the stern light.... An LED that did not meet color, axis or other requirements would have made their job a slam dunk..


Perhaps the part in Rule 20 that states your nav lights SHALL COMPLY with Annex I was missed? This is what it means, by US Federal Law and the COLREGS to be considered a "navigation light"....

From 33 CFR 84:


Colors

� 84.13 Color specification of lights
(a) The chromaticity of all navigation lights shall conform to the following standards, which lie within the boundaries of the area of the diagram specified for each color by the International Commission on Illumination (CIE), in the "Colors of Light Signals", which is incorporated by reference. It is Publication CIE No. 2.2. (TC-1.6), 1975, and is available from the Illumination Engineering Society, 345 East 47th Street, New York, NY 10017. It is also available for inspection at the Office of the Federal Register, Room 8401, 1100 L Street N.W., Washington, D.C. 20408. This incorporation by reference was approved by the Director of the Federal Register.
(b) The boundaries of the area for each color are given by indicating the corner coordinates, which are as follows:
(1) White:
x 0.525 0.525 0.452 0.310 0.310 0.443
y 0.382 0.440 0.440 0.348 0.283 0.382
(2) Green:
x 0.028 0.009 0.300 0.203
y 0.385 0.723 0.511 0.356
(3) Red:
x 0.680 0.660 0.735 0.721
y 0.320 0.320 0.265 0.259
(4) Yellow:
x 0.612 0.618 0.575 0.575
y 0.382 0.382 0.425 0.406

Intensity

� 84.15 Intensity of lights
(a) The minimum luminous intensity of lights shall be calculated by using the formula:
l = 3.43 x 106 x T x D2 x K-D
where:
I is luminous intensity in candelas under service conditions, T is threshold factor 2 x 10-7 lux, D is range of visibility (luminous range) of the light in nautical miles, K is atmospheric transmissivity. For prescribed lights the value of K shall be 0.8, corresponding to a meteorological visibility of approximately 13 nautical miles.
(b) A selection of figures derived from the formula is given in Table 84.15(b).
Table 84.15(b)
Range of visibility (luminous Minimum
range) of light in nautical luminous intensity of light
miles in candelas tor K = 0.8
D I
1 0.9
2 4.3
3 12
4 27
5 52
6 94

Horizontal Sectors

� 84.17 Horizontal sectors
(a)
(1) In the forward direction, sidelights as fitted on the vessel shall show the minimum required intensities. The intensities shall decrease to reach practical cut-off between 1 and 3 degrees outside the prescribed sectors.
(2) For sternlights and masthead lights and at 22.5 degrees abaft the beam for sidelights, the minimum required intensities shall be maintained over the arc of the horizon up to 5 degrees within the limits of the sectors prescribed in Rule 21. From 5 degrees within the prescribed sectors the intensity may decrease by 50 percent up to the prescribed limits; it shall decrease steadily to reach practical cutoff at not more than 5 degrees outside the prescribed sectors. (b) All-round lights shall be so located as not to be obscured by masts, topmasts or structures within angular sectors of more than 6 degrees, except anchor lights prescribed in Rule 30, which need not be placed at an impracticable height above the hull, and the all-round white light described in Rule 23(d), which may not be obscured at all. (c) If it is impracticable to comply with paragraph (b) of this section by exhibiting only one all-round light, two all-round lights shall be used suitably positioned or screened to appear, as far as practicable, as one light at a minimum distance of one nautical mile.

NOTE to paragraph (c): Two unscreened all-round lights that are 1.28 meters appart or less will appear as one light to the naked eye at a distance of one nautical mile.


Vertical Sectors

� 84.19 Vertical sectors
(a) The vertical sectors of electric lights as fitted, with the exception of lights on sailing vessels underway and on unmanned barges, shall ensure that:
(1) At least the required minimum intensity is maintained at all angles from 5 degrees above to 5 degrees below the horizontal;
(2) At least 60 percent of the required minimum intensity is maintained from 7.5 degrees above to 7.5 degrees below the horizontal.
(b) In the case of sailing vessels underway the vertical sectors of electric lights as fitted shall ensure that:
(1) At least the required minimum intensity is maintained at all angles from 5 degrees above to 5 degrees below the horizontal;
(2) At least 50 percent of the required minimum intensity is maintained from 25 degrees above to 25 degrees below the horizontal.
(c) In the case of unmanned barges the minimum required intensity of electric lights as fitted shall be maintained on the horizontal.
(d) In the case of lights other than electric lights these specifications shall be met as closely as possible.




This is what USCG / ABYC A-16 navigation lights are tested to. Also likely what any good lawyer would be traipsing around a court room...


Consider this:


If you are involved in a night time collision, your fault or not, and you feel you can go up against Jim Sokolove or his buddies who would be prancing about a courtroom with the above CFR standards for nav lights than by all means go for it. If you are not sure the bulbs you put into the existing fixtures meets all those specifications then you might want to use caution.

I will say this again as I have many times before, it is NOT the USCG who will care. The lawyers will however care if and when you are involved in a nigh time accident. It is not the USCG you need to worry about it is the ambulance chasers who are looking for a case, any case, to show why their drunk defendant deserves to get off Scott free.

If you have read the above CFR for nav lights and still believe you can meet these horizontal, vertical, color spectrum and intensity parameters, with the bulbs you choose, than you're good to go...

To see where in the COLREGS lights are defined you need to look no fiurther than Rule 20:

USCG Nav Center said:
Rule 20 - Application
USCG Nav Center said:
(a) Rules in this part shall be complied with in all weathers.

(b) The Rules concerning lights shall be complied with from sunset to sunrise, and during such times no other lights shall be exhibited, except such lights which cannot be mistaken for the lights specified in these Rules or do not impair their visibility or distinctive character, or interfere with the keeping of a proper look-out.

(c) The lights prescribed by these Rules shall, if carried, also be exhibited from sunrise to sunset in restricted visibility and may be exhibited in all other circumstances when it is deemed necessary.

(d) The Rules concerning shapes shall be complied with by day.

(e) The lights and shapes specified in these Rules shall comply with the provisions of Annex I [to these Regulations | of these Rules].
Annex I takes you straight to the CFR definitions of a nav light as posted above... "SHALL COMPLY with the provisions of Annex I" is not worded lightly. This means YOUR nav lights MUST comply with the CFR specs above.. This is not a gray area...

Consider this scenario:

You are at anchor with your non certified, blueish colored LED anchor light that you saved big money on by purchasing it from an auto parts store. Joe six pack in his 32 foot Baja with 550 H.P. has been drinking all day and is blasting home when he plows into your boat and kills your child. Fast forward about two years to the trial where the lawyer for the defendant is blaming you, and convincing the jury that because you were a cheap skate, and circumvented the use of certified nav lights to save a few pennies (remember to the jury you are a rich boater anyway), you are the reason your child is dead because his drunk defendant could not see your anchor light...

A stretch? Possibly not. I sat through two days of this type of testimony during the trial of the defendant who killed my friends father. It was two days of nav light testimony only these were certified nav lights, and yes that was brought up, and the bulbs were examined by a forensics expert to determine if the bulb was on at time of impact. The case would have been made much easier if Kim's dad had simply installed aftermarket LED's as it would have given the lawyers food for fodder.

Again this is about your comfort level and I only wanted to give you guys some things to consider.

There are plenty of certified NAV lights on the market but only two or three certified for use in an already existing fixture. The only after market bulb that is certified, and has the testing certs to back it up, for use in existing fixtures, are made by Dr. LED but only for use in certain Aquasignal fixtures.
 
Feb 6, 1998
11,436
Canadian Sailcraft 36T Casco Bay, ME
Hamilton Marine feels so strongly about not being involved in the liability chain they have this sign hanging right next to the LED lights where you can't miss it:






And this is the back of a package of an IMTRA LED bulb.




Seems no one wants to accept the potential liability for installing aftermarket LED's not even the people making them or the people selling them. That says a lot to me....

I guess that; "The operator of vessel assumes all liability when using this product as a replacement for the original approved light source." means it is all on you to decide if using aftermarket LED's in existing fixtures is a worth while venture.
 
Nov 8, 2010
11,385
Beneteau First 36.7 & 260 Minneapolis MN & Bayfield WI
Maine,

Thanks a lot for taking the time to post all of that. I learned a lot. I think you are right, the risk of liability is hanging over a lot of heads in these cases. The nightmare scenario for many is to be dragged into litigation only because some small part along the chain is non-compliant.

But the comments of my Coastie still sit in my ears. I'm pretty sure he doesn't have a light spectrometer on-board to check lights. But maybe someone lawyer does. Its a crazy world we live in.
 
Feb 6, 1998
11,436
Canadian Sailcraft 36T Casco Bay, ME
But the comments of my Coastie still sit in my ears. I'm pretty sure he doesn't have a light spectrometer on-board to check lights. But maybe someone lawyer does. Its a crazy world we live in.
Your Coastie will likely never check for compliance of nav lights, just to see that they are working or there. That does not allow folks to skirt the law though and the law is still a law.

I think the simple and important facts are:

#1 It is required by law to have COLREGS compliant (not necessarily certified) navigation lights. Even as a "Joe boat owner" your nav lights must be compliant, "SHALL BE" is the language in the COLREGS. These requirements are outlined under Annex I which are the CFR specifications for nav lights.

#2
Your lights don't need to be "certified" but they still must meet all the criteria for a "certified" light. Without a certification how do you know you have actual nav lights or just pretty decorations?

#3 Baking your own bread, eg: home made nav lights/LED slapped into existing fixtures, really leaves only you open to the liability and to prove your lights met the CFR specifications for navigation lighting.

#4 Above all it is the LAW to have navigation lights that comply with the COLREGS...

#5 Factory made USCG/ABYC certified LED lights have come WAY down in price. If looking to do a conversion you may want to put the liability on the manufacture, not yourself...
 
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