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Public Comment Form National Principles to Guide in Assessing Risks to Determine Policy on the Compulsory Wearing of Personal Flotation Devices (PFDs) Discussion PaperTO: NMSC Secretariat Email: secretariat@nmsc.gov.au Fax: (02) 9247 5203 FROM: Name: Phil Jones Position: Chief Executive Officer Company: Yachting Australia Inc Address: Locked Bag 806, Milson’s Point, NSW 2061 Telephone: 02 8424 7400 Email: Phil.jones@yachting.org.authDate of Thursday, November 30 2006 submission Please provide your comments: Section or Page Comments/recommendation option no. Proposal 6 Yachting Australia supports the premise behind development of nationally agreed PFD usage regulations. There are many boaters who travel to other jurisdictions and YA consider that it would be beneficial and desirable to have a common basis from which States can derive their PFD wearing regulations. It may not be necessary for all States to have identical regulations for PFD wearing but it will be much easier for boaters to understand and comply with local regulations if such things as boat length/type and designated conditions of risk are common between States. The Issue 7 & 8 Yachting Australia supports the premise behind development of nationally agreed PFD usage regulations. There are many boaters who travel to other jurisdictions and YA consider that it would be beneficial and desirable to have a common basis from which States can derive their PFD ...

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Public Comment Form
National Principles to Guide in Assessing Risks to Determine Policy on the Compulsory Wearing of Personal Flotation Devices (PFDs)
TO:
FROM: Name: Company: Address: Telephone: Date of submission
Discussion Paper
NMSC SecretariatEmail:secretariat@nmsc.gov.auFax: (02)9247 5203 Phil JonesPosition: ChiefExecutive Officer Yachting Australia Inc Locked Bag 806, Milson’s Point, NSW 2061 02 8424 7400Email:Phil.jones@yachting.org.au th Thursday, November 302006
Please provide your comments:
Section or option Proposal
Page Comments/recommendation no. 6 YachtingAustralia supports the premise behind development of nationally agreed PFD usage regulations.
There are many boaters who travel to other jurisdictions and YA consider that it would be beneficial and desirable to have a common basis from which States can derive their PFD wearing regulations.
It may not be necessary for all States to have identical regulations for PFD wearing but it will be much easier for boaters to understand and comply with local regulations if such things as boat length/type and designated conditions of risk are common between States.
The Issue7 & 8Yachting Australia supports the premise behind development of nationally agreed PFD usage regulations. There are many boaters who travel to other jurisdictions and YA consider that it would be beneficial and desirable to have a common basis from which States can derive their PFD wearing
regulations.
It may not be necessary for all States to have identical regulations for PFD wearing but it will be much easier for boaters to understand and comply with local regulations if such things as boat length/type and designated conditions of risk are common between States. Scope of12 YachtingAustralia believes that all recreational boats, other Paper thanpowerboats of greater than 12 metres LOA, should be subject to graduated levels of mandatory wearing of PFDs provided that the chosen levels are appropriate to the type of boat, area of operation and usage type. Excluding powerboats over 12 metres LOA should be of minimal increase in risk but may even not be necessary depending upon the application of criteria. For instance boating alone could be shown to be a sensible time for a PFD to be worn on such boats whereas requiring dinner guests to wear one in smooth conditions at night on larger boats may not. Scope of12NMSC is to be complimented on the wording chosen and YA are Paper –hopeful that they will be assiduously followed, as in the extract Relationshipbelow: to risks“Any consideration of introducing compulsory actions should be assessed in terms of the relationship to risks. The risks associated with boating activities need to be assessed and compulsory PFD requirements should be introduced when voluntary behaviour strategies do not or are insufficient to mitigate the risks. Risk should be assessed as a product of likelihood and consequence of a drowning occurring. Risk factors should be informed where possible by marine incident statistics for the State (for incidents that could lead to drowning), the inherent qualities of boats, boating public behaviour patterns and other existing factors in place to mitigate risks.”Principle 113 Agree The nature of the activity
Principle 214 Agree
The area of operation Principle 314 Agree The environment Principle 415 Agree
Extra protection for inexperienced boaters Principle 515 Withinsailing boats, which constitute the majority of Yachting Australia membership, it is our experience that length of boat is Type and generally irrelevant and that the type and the level of its length of boat equipment is the factor concerned. In regard to Yachting Australia regulations for PFD wearing on sailing boats when racing apply as follows: Off the beach boats must wear PFD's Type 1, 2 or 3 or an equivalent and approved international standard whilst racing. Cat 5 "night" races must wear PFD's type 1or 2 whist racing YA SR 5.01.1(c), regardless of the size or type of boat. Cat 17 are not required by YA SR's to wear PFD's unless the Race Committee displays International Code Flag Y, regardless of the size or type of boat.
Yachting Australia also recommends that PFDs be worn at times of risk according to crews’ judgment, rather than the size or type of boat. Principle 616 Disagree Propensity to
take risks Are the listed16 Yes principles sufficient
Have all of16 Themain identifiable risks are covered. the risks been covered? Do you think16 Itmay not be necessary for all States to have identical national regulationsfor PFD wearing but it will be much easier for consistency boatersto understand and comply with local regulations if such on thethings as boat length/type and designated conditions of risk are compulsory commonbetween States. wearing of PFDs is necessary? Do you think17 Acombination of education and regulation is needed to change education recreationalboater behavior on the water with the emphasis on campaigns education.There is little point in trying mandate something that are sufficientcannot be enforced. Changing the culture is likely to be the to changeonly really successful way in the long run and this can only be recreational donethrough education. boater behaviour on the water?
When might it17 be unsafe to wear a PFD?
Yachting Australia position
The risks of when wearing a PFD might be “unsafe” need to be balanced against the appropriateness of wearing them in that situation. It is clearly inappropriate and unnecessary to have to wear a PFD when below decks and asleep. If the proximity to a winch, as in the example given, requires the operator to be on the foredeck in rough weather then the risk of going overboard becomes the determining factor.
All machinery should be sensibly guarded if a risk exists and operators clothing, including PFDs, should be such as to present a risk. In the development of specific sailboat related requirements, YA recommend that a targeted approach not only by length but also by type and usage be considered for national adoption. In particular the introduction of ‘Off the beach’ boats as a new
Further Attachments
category within NMSC regulations and the delineation of other yachts by with and without lifelines rather than by length.
Not only do these align with some YA requirements for racing but they may also have a sound basis for application as the types of boats more or less likely to have crew end up in the water.
It is essential that all States adopt regulations accepting PFDs to alternative standards as per the ATC/NMSC list. Available for your reference are the attached submissions received by Yachting Australia. Please refer to attached file PFD Public Comment  Submissions to Yachting Australia.zip