The short version
- 46 CFR 184.710 names no contents. It points at 46 CFR 199.175(b)(10), which points at ISO 18813:2006(E) paragraph 4.12.
- That ISO standard is Survival equipment for survival craft and rescue boats. The binding kit list sits inside a liferaft equipment specification.
- The equivalent kit option is available and most operators use it by default, which shifts the whole burden of proving equivalence onto the operator.
- 46 CFR 121.710 under Subchapter K is word for word identical, so nothing scales with passenger count.
- Active ingredients in medicinal products must conform to the over-the-counter monograph regime in 21 CFR part 330.
The requirement is three documents deep
An operator asks what has to be in the first aid kit on a small passenger vessel. The regulation that governs is short enough to read in fifteen seconds, and it answers a different question.
46 CFR 184.710, First-aid kits
“A vessel must carry either a first-aid kit that meets the requirements in 46 CFR 199.175(b)(10) or a kit with equivalent contents and instructions. For equivalent kits, the contents must be stowed in a suitable, watertight container that is marked ‘First-Aid Kit’. A first-aid kit must be easily visible and readily available to the crew.”[1]
No contents. It points somewhere else. Follow the pointer to 46 CFR 199.175(b)(10), a lifesaving regulation in Subchapter W, and it points somewhere else again: each first aid kit must meet the requirements in ISO 18813:2006(E) paragraph 4.12[2]. Follow that pointer and you leave the Code of Federal Regulations entirely.
| Step | Where you land | What it tells you |
|---|---|---|
| 1 | 46 CFR 184.710, Subchapter T | Carry a kit meeting 199.175(b)(10), or an equivalent. Container, marking, visibility[1] |
| 2 | 46 CFR 199.175(b)(10), Subchapter W | Meet ISO 18813:2006(E) paragraph 4.12. Burn preparations may be omitted if the kit is clearly marked as lacking them. Active ingredients must conform to 21 CFR part 330[2][11] |
| 3 | ISO 18813:2006(E) paragraph 4.12 | The actual contents. Not published in the CFR. Obtainable from ISO, Geneva[3] |
Three documents, two subchapters and one international standard, to answer a question about a box on a bulkhead. That structure is why the answers online stop at step one.
What the standard at the end of the chain actually is
46 CFR 199.05 identifies it precisely: ISO 18813:2006(E), Ships and marine technology, Survival equipment for survival craft and rescue boats, first edition, 1 April 2006, obtainable from the International Organization for Standardization in Geneva[3].
Read that title again. The binding contents list for a United States small passenger vessel first aid kit sits in a standard about equipment for liferafts and rescue boats. Paragraph 4.12 is a clause inside a survival craft equipment specification, written for a kit that goes into a liferaft. It is not a vessel medical chest standard and it was never intended to be one. Operators who assume it resembles the chest regimes described in requirements by flag state or the EU categories are assuming something the citation does not support.
Where the online answers go wrong
A live capture of the first page for this question in August 2026 showed the generated summary quoting 184.710 and 199.175(b)(10) correctly, and then abandoning the chain. Rather than naming ISO 18813, it filled the contents list from recreational boating sources, with a Facebook post by a state environmental police agency cited alongside them. The result reads like a compliance answer and is a leisure boating kit list. The page itself was half recreational: a boating magazine, an outboard engine manufacturer, a kit retailer, a document sharing site and Facebook.
The equivalent kit option, and what it costs you
184.710 offers a way out: a kit with equivalent contents and instructions[1]. Most operators take it, usually without noticing they have taken it. Buying a commercial marine first aid kit that is not certified to ISO 18813 is choosing the equivalence route by default.
The cost of that route is evidential, not financial. Equivalence is measured against a document you have not read, so if an inspector asks how the kit is equivalent, the answer has to come from you. There is no published list to point at. This is structurally the same position a towing operator occupies under a capability standard, and the opposite of the position a fishing vessel operator occupies under a contents list.
| Vessel class | Governing section | How the operator proves compliance |
|---|---|---|
| Commercial fishing | 46 CFR 28.210[10] | Match the published list. The rule carries the burden |
| Towing, Subchapter M | 46 CFR 140.435[9] | Show the kit achieves three named capabilities. The operator carries the burden |
| Small passenger, T and K | 46 CFR 184.710 and 121.710[1][4] | Match a purchased ISO standard, or argue equivalence to a document you have not read. The heaviest of the three |
Three United States vessel classes, three completely different drafting styles for the same idea. The towing version is set out in the Subchapter M rules and the fishing version in the 28.210 rules, with the wider federal picture for that fleet in the six federal obligations.
Subchapter K says the same thing, word for word
A vessel carrying more than 150 passengers falls under Subchapter K. 46 CFR 121.710 is textually identical to 184.710[4]. Not similar. Identical.
The practical consequence is that nothing in the first aid requirement scales with exposure. A six passenger charter running two hours from a marina and a 400 passenger dinner vessel carry the same regulatory obligation. Any gap between them has to be closed by the operator’s own judgement about passenger numbers, voyage length and distance from care, which is a planning exercise rather than a compliance one. The method for it is in planning by voyage length, and the decision framework once someone is unwell in the evacuation article.
What else Subchapter T puts on the operator
The kit is the visible requirement. Part 185 subpart B carries a full casualty and records regime that most operators meet only after an incident.
| Section | What it obliges | Where operators get caught |
|---|---|---|
| 185.202 Notice of casualty |
Immediate notice, restating the federal injury trigger word for word[5] | It carries the phrase “professional medical treatment beyond first aid” and the unfit for routine duties limb, neither of which is defined anywhere in 46 CFR[5] |
| 185.206 Written report |
The written marine casualty report[12] | Treated as the same duty as the notice. It is a second, separate obligation |
| 185.212 Chemical testing |
Mandatory testing after a serious marine incident[6] | The clocks start at the incident, not at the decision. A death makes the classification automatic |
| 185.280 Official logbook |
For foreign voyages, entries for each illness or injury and the medical treatment given, and each death on board with the cause[7] | Assumed to be clinical paperwork. It is a logbook duty with the master’s name on it |
| 185.420 Crew training |
Crew training requirements[8] | The only place a first aid competence obligation can live, because 184.710 creates none |
The first row is the one that matters most and the one nobody reads twice. What that phrase means, and where its definition actually lives, is the subject of the beyond first aid article. The clocks behind the third row, and what makes a death automatic, are in the death on board procedure.
Building a kit an inspector reads rather than argues with
Four steps, and the first one is the only one that is genuinely awkward.
- Decide which route you are on and write it down. ISO certified kit, or equivalence. Most operators are on the second route without having chosen it.
- If you are claiming equivalence, obtain the standard. It is a purchase from ISO[3]. Claiming equivalence to a document nobody in the company has seen is the weakest position available and it is the common one.
- Check the medicines against 21 CFR part 330. Active ingredients must conform to the over-the-counter monograph regime[2][11]. Nothing prescription belongs in a kit built to this rule, and anything scheduled brings a separate regime, starting with the schedules and recordkeeping aboard a vessel.
- Mark, stow and site it as the section says. Watertight container marked First-Aid Kit for an equivalent kit, easily visible, readily available to the crew[1]. Three findings that write themselves if any is missed.
Step two is where operators balk, and it is the step that converts an argument into a document. If you would rather have the kit specified and the equivalence argument written for you, that is chest management and maritime medical consulting. Where it fits in a whole programme is the six decisions, and what an inspection of that programme looks like is a compliance audit. Every other article on this subject is indexed in the guidance library, and the physician who reviews them is on the about page.
Common questions
What does 46 CFR 184.710 actually require?
A kit meeting 46 CFR 199.175(b)(10), or a kit with equivalent contents and instructions. An equivalent kit must be stowed in a suitable watertight container marked “First-Aid Kit”, and any kit must be easily visible and readily available to the crew. That is the whole section. The chain it starts is explained above, and the towing vessel version is in the Subchapter M rules.
What is in the kit, then?
Neither CFR section says. 199.175(b)(10) requires the kit to meet ISO 18813:2006(E) paragraph 4.12, a standard incorporated by reference and obtainable only from ISO in Geneva. The contents list a United States operator is bound by is not in the Code of Federal Regulations and is not free to read. Building a defensible list is the same exercise described in how to stock a chest.
Can we just build our own kit instead?
Yes, and most operators do. 184.710 permits a kit with equivalent contents and instructions. The catch is that equivalence is measured against a standard you have not read, so the burden of demonstrating it sits entirely with you. That is the same evidential position towing operators are in under a capability standard, compared in the table above and in the 28.210 rules.
Does Subchapter K say something different?
No. 46 CFR 121.710 is word for word identical to 184.710, so a vessel carrying more than 150 passengers faces the same requirement as a six-pack charter. Nothing scales with passenger count. Where that leaves risk planning is covered in planning by voyage length.
Is the ISO standard even about medical kits?
Not primarily. 46 CFR 199.05 identifies it as ISO 18813:2006(E), Ships and marine technology, Survival equipment for survival craft and rescue boats. Paragraph 4.12 is the first aid kit clause inside a survival craft equipment standard. That is worth knowing before assuming it describes a vessel medical chest, which it does not. The chest concept and where it comes from is in requirements by flag state.
What else does Subchapter T put on an operator, medically?
Subpart B of part 185 carries a full casualty regime: notice of casualty at 185.202, written report at 185.206, mandatory chemical testing after a serious marine incident at 185.212, and official logbook entries for foreign voyages at 185.280. The injury threshold that triggers the first of those is explained in the beyond first aid article.
Do the medicines in the kit have to be anything in particular?
199.175(b)(10)(ii) requires the active ingredients in medicinal products to conform to the over-the-counter drug regulations in 21 CFR part 330. That is a hard ceiling: nothing prescription belongs in a kit built to this rule, and anything scheduled brings DEA obligations of its own, starting with the schedules.
