Alaska Marine Safety

Education Association

June 10, 2009

Immersion Suit Exemption Available For Infants Aboard Commercial Fishing Vessels in Alaska

The U.S Coast Guard has required an appropriately sized immersion (survival) suit for each person onboard most commercial fishing vessels since the early 1990s. Casualty reports and studies well document that an appropriately fitting immersion suit increases chances of surviving a sinking at sea by a factor of 15, according to the National Institute for Occupational Safety & Health’s Alaska Pacific Regional Office.

Unfortunately, there have been no USCG-approved immersion suits on the market sized appropriately for infants since the late 1980s. Manufacturers do not offer infant-sized immersion suits primarily because of the limited market for them. The number of families who take infants on fishing vessels is fairly small and mostly restricted to coastal Alaska.

The U. S. Coast Guard is faced with a conundrum to either allow infants onboard fishing vessels without the hypothermia and drowning protection provided by immersion suits, or to not allow infants on commercial fishing vessels at all. Neither is a satisfactory situation.

Until a suitable solution is found, the USCG is temporarily granting an exemption to families fishing in Alaskan waters with infants onboard. An exemption letter must be obtained from the USCG, and a copy of the exemption letter must be available to any U.S. Coast Guard Boarding Officer who boards any vessel operating in Alaskan waters with an infant onboard. A letter grants an exemption only to the addressee (the person who applied for the exemption) for his or own child.

In order to get an exemption letter, the following steps must be followed:

• A U.S. Coast Guard-approved personal flotation device of an appropriate size must be carried aboard the fishing vessel for each infant.
• A letter requesting an exemption must be sent to:
  

  Commander, U.S. Coast Guard
  Commercial Fishing Safety Coordinator Ken Lawrenson
  17th Coast Guard District
  P.O. Box 25517 Juneau, AK 99802-5517

• The request letter must include the following:
• A specific request for an exemption from carrying an immersion suit for an infant
• A statement that said infant has not attained a height of 35 inches
• Confirmation that a PFD appropriately-sized for the infant is carried aboard the vessel

Finding a more permanent solution to this problem requires that the USCG know its extent. (How many infants are on fishing vessels?) Thus, it is very important that every family in this situation write to the U. S. Coast Guard for an exemption letter and thereby help document the size of issue.

While the Coast Guard in Alaska appreciates the traditional, small family-based commercial fisheries in Alaska, they encourage fishermen to reconsider taking infants aboard commercial fishing vessels. If parents do fish with very small children aboard, they must write and request an exemption letter to avoid legal problems. And meanwhile, AMSEA will be working with the U.S. Coast Guard toward an acceptable solution.

Download a letter to the Alaska fishing fleet regarding immersion suits for infants from 17th Coast Guard District Commercial Fishing Safety Coordinator Ken Lawrenson