The short version
- 46 CFR 153.930 bans operating a tankship carrying Table 1 cargo unless the MFAG antidotes for that cargo are aboard.
- That makes an IMO guide binding United States law for this fleet. Search results for the guide are PDF mirrors and library catalogues.
- 46 CFR 153.214 counts SCBA refill cartridges, then paragraph (c) reads in full: First aid equipment.
- Antidotes are pharmaceuticals. Where any is scheduled, 21 CFR 1301.25 attaches.
- A self propelled ship needs the emergency shower operating at all times, not only during transfer.
A United States regulation makes an IMO guide legally binding
Most maritime medical guidance is guidance. The WHO ship medicine chest guide is guidance. The withdrawn ILO recommendation was guidance. One document is different, and almost nobody in the industry knows it.
46 CFR 153.930, Cargo antidotes, complete text
“No person may operate a tankship that carries a cargo listed in Table 1 unless the tankship has on board the antidotes described for the cargo in the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, published by IMO.”[1]
Read the drafting. It is a prohibition, not a duty. The vessel may not operate. There is no phase in, no exception, no de minimis quantity.
And the standard it points at is the IMO Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, an international publication that a US federal regulation has turned into binding law for this fleet.[2]
The guide ranks. The rule that makes it binding does not
Search the MFAG in September 2026 and page one returns the IMO product page, a Barbados flag administration PDF, a Stanford University library catalogue entry, an Indian training site, a compliance blog, a Ukrainian PDF mirror and a document sharing site.
That is the classic document hunting shape recorded on this project: people looking for a free copy of a file.[3] Not one result on that page tells a United States operator that 46 CFR 153.930 makes carrying the antidotes a condition of operating the ship.
The same defect ran through the medicine chest contents question, where Google served a withdrawn ILO instrument, and through the EU category system, where European law answered an American question. Flag state chest rules shows the substitution running the other way.
The section that specifies breathing air to the cartridge, then says two words about medicine
46 CFR 153.214 is where the contrast becomes uncomfortable. It lists personnel emergency and safety equipment for each self propelled ship, and it is extraordinarily precise.[4]
| Item | What 153.214 specifies | Precision |
|---|---|---|
| Stretchers | Two stretchers or wire baskets, complete with equipment for lifting an injured person from a pumproom or a cargo tank[4] | Quantity and use case |
| Breathing apparatus | Three 30 minute self contained sets of the pressure demand type, MSHA and NIOSH approved or approved by the flag administration, with five refill tanks or cartridges of 30 minutes capacity each[4] | Quantity, duration, type, approval body, refill count |
| Protective clothing | Three sets of overalls or large apron, boots, long sleeved gloves and goggles, each made of materials resistant to the Table 1 cargoes endorsed on the certificate[4] | Quantity, garment list, material compatibility tied to the endorsement |
| Lifeline | Three steel cored lifelines with harness[4] | Quantity and construction |
| Lamp | Three explosion proof lamps[4] | Quantity and rating |
| First aid equipment | “First aid equipment.” Paragraph (c), in full[4] | Nothing. Two words |
A regulation that counts SCBA refill cartridges says first aid equipment and stops. The kit is undefined, unquantified and unstandardised, on a vessel carrying cargoes that require named antidotes.
That is the gap our ship medical chest management service exists to close, A tanker crew on a long voyage is also the population furthest from help, which is the argument in planning by time to definitive care. The same drafting pattern appears in 46 CFR 28.210 on fishing vessels and in 46 CFR 197.314 on dive spreads.
Antidotes are drugs, and that changes who has to be involved
The word antidote does the heavy lifting in 153.930, and operators treat it as a stores problem. It is not.
MFAG antidotes are pharmaceuticals. Depending on the cargoes endorsed on the certificate, an antidote set can include prescription only medicines that require a lawful route to acquire, a place to store, a shelf life to manage and a person authorised to give them.
Check the schedule before you check the shelf
Where any antidote or supporting drug is a controlled substance, the vessel is no longer only inside 46 CFR 153. It is inside 21 CFR 1301.25, which requires either a DEA registered medical officer employed by the owner or operator, or the master requisition route.[5] Read the 21 CFR 1301.25 walkthrough and the two route comparison before ordering anything.
The rest of the chain follows: recordkeeping aboard, the two annual reports, and disposal when an antidote expires unused, which on a tankship is the normal outcome rather than the exception. A DEA inspectionwill ask for the paperwork on every one of those steps, and the schedules articledecides which shelf they sit on.
The shower rule is stricter than the industry assumes
46 CFR 153.216 splits by propulsion, and the split is the part that catches people.[6]
| Vessel | Availability required | Specification |
|---|---|---|
| Non self propelled ship | Fixed or portable, operating during cargo transfer[6] | Operates in any ambient temperature; water between 0 and 40 degrees Celsius, roughly 32 to 104 Fahrenheit; on the weatherdeck; marked EMERGENCY SHOWER and visible from the deck work areas[6][7] |
| Self propelled ship | Operating at all times[6] | Same four conditions[6] |
At all times means at all times, not during transfer and not in port. A shower isolated for winter, valved off during a yard period or blocked by stores does not meet it, and the temperature window is a real engineering constraint in both Alaska and the Gulf.
Goggles and protective clothing carry their own sections at 153.932 and 153.933.[8][9] Operators running Alaskan waters know the ambient temperature problem from other equipment already. Waste from a decontamination event has its own chain, set out in three separate federal titles.
Everything turns on Table 1, and Table 1 is on your certificate
Section 153.930 does not apply to every tankship. It applies to a tankship carrying a cargo listed in Table 1.[1] The antidote requirement is therefore cargo specific, and it moves when the endorsement moves.
Three consequences follow and each one is a documentation exercise rather than an engineering one.
- The antidote set is defined by the certificate endorsement, not by the trade. Adding a cargo to the Certificate of Inspection can add an antidote requirement on the same day.[1]
- Protective clothing is tied to the same list. 153.214(b)(2) requires materials resistant to the Table 1 cargoes endorsed on the certificate, so a certificate change can invalidate the gear as well.[4]
- Nobody automatically tells the medical side. A cargo endorsement is a commercial and technical decision. The antidote consequence sits downstream of a decision the medical programme does not see.
Closing that loop is a governance question, and the owner and DPA split decides who owns it. Our maritime medical consulting line writes the trigger into the management system so a cargo change raises a medical action.
Where the tanker fleet sits against the classes we have already mapped
Set 153.930 beside the other US medical rules and the tanker fleet turns out to be the most demanding and the least discussed.
| Class | Medical rule | Named contents? |
|---|---|---|
| Chemical tankship 46 CFR 153 |
Antidotes per the MFAG, as a condition of operating[1] | Yes, by cargo. The only US class with a named medicinal requirement |
| Commercial fishing, part 28 | First aid equipment and a medicine chest[10] | No contents list |
| Small passenger, Subchapter T | First aid kits | Points at a standard, not a drug list |
| Sailing school, Subchapter R | One approved first aid kit | No, one sentence |
The full kit comparison by class sets the rest out. Hospital space is a separate trigger that a tanker can meet at the same time. If an exposure becomes an injury, the reporting threshold attaches as well.
Seven checks before the next loading
- Pull the Table 1 cargoes endorsed on your certificate and list them. That list is the scope of 153.930.[1]
- Map each cargo to its MFAG antidote and write the mapping down. The regulation assumes you have done this; it does not do it for you.[1][2]
- Identify which antidotes are prescription or scheduled and route those through 21 CFR 1301.25 before purchase.[5]
- Put antidote expiry on the same clock as the chest, because an expired antidote is a missing antidote for the purpose of a prohibition.
- Test the emergency shower against all four conditions in 153.216(c), including the temperature window and the weatherdeck marking.[6]
- Define paragraph (c). Write your own first aid equipment specification, because the regulation will not.[4]
- Add a cargo endorsement change to the medical trigger list so the antidote set is reviewed when the certificate moves.
Discovery Health MD is led by Ann Jarris MD, MBA, FACEP, a board certified emergency physician. Mapping cargoes to antidotes, separating the scheduled ones, and writing the specification the CFR omits is exactly the work. Programme frame in the six decisions, audited the way an inspector checks. Fleets that change flagshould note that 46 CFR 153.930 attaches to the US certificate, so it moves with the flag. Speak to the team.
Common questions
Does a US chemical tanker have to carry antidotes?
Yes, and it is drafted as a prohibition. 46 CFR 153.930 states that no person may operate a tankship that carries a cargo listed in Table 1 unless the tankship has on board the antidotes described for the cargo in the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, published by IMO[1]. There is no phase in and no de minimis quantity. The scope is set by the Table 1 cargoes endorsed on your certificate, so it moves when the endorsement moves.
Is the IMO Medical First Aid Guide legally binding in the United States?
For this fleet, yes. 46 CFR 153.930 incorporates the MFAG by making carriage of its prescribed antidotes a condition of operating a tankship carrying Table 1 cargo[1][2]. That is unusual: most maritime medical documents, including the WHO ship medicine chest guide, are guidance with no legal force. Search results for the MFAG return PDF mirrors and library catalogues and none of them mentions the US rule that makes it binding.
What first aid equipment does 46 CFR 153.214 require?
It does not say. Paragraph (c) of 46 CFR 153.214 reads, in full, ‘First aid equipment'[4]. The same section specifies three 30-minute pressure demand self contained breathing sets with five refill cartridges each, three sets of overalls or apron, boots, long sleeved gloves and goggles resistant to the endorsed Table 1 cargoes, three steel cored lifelines with harness, three explosion proof lamps, and two stretchers with lifting equipment[4]. The kit is the only undefined item. Our MedChest service writes the specification the CFR omits.
Are MFAG antidotes controlled substances?
Some can be, depending on the cargoes endorsed. Antidotes are pharmaceuticals, not stores, and an antidote set can include prescription only medicines. Where any antidote or supporting drug is scheduled, the vessel is also inside 21 CFR 1301.25, which requires either a DEA registered medical officer employed by the owner or operator, or the master requisition route[5]. Read the 21 CFR 1301.25 walkthrough before ordering anything.
When must the emergency shower on a chemical tanker be operating?
It depends on propulsion. Under 46 CFR 153.216, a non self propelled ship needs a fixed or portable shower and eyewash fountain operating during cargo transfer, while a self propelled ship needs one operating at all times[6]. Both must operate in any ambient temperature, dispense water between 0 and 40 degrees Celsius, sit on the weatherdeck, and be marked EMERGENCY SHOWER so the marking is visible from the deck work areas[6][7]. A shower isolated for winter does not meet it.
Does adding a cargo to the certificate change the medical requirement?
Yes, on the same day. 46 CFR 153.930 applies to a tankship carrying a cargo listed in Table 1, so the antidote set is cargo specific[1]. 46 CFR 153.214(b)(2) compounds it by requiring protective clothing made of materials resistant to the Table 1 cargoes endorsed on the certificate[4]. A cargo endorsement is a commercial decision that the medical programme usually never sees, which is the loop our consulting engagement closes.
How does the tanker rule compare to other US vessel classes?
It is the strictest medical requirement in Title 46. Chemical tankships must carry named antidotes matched to cargo as a condition of operating[1]. Commercial fishing vessels under 46 CFR 28.210 get a medicine chest with no contents list[10], small passenger vessels get first aid kits pointing at a standard, and sailing school vessels get one sentence. No other US class has a named medicinal requirement. See the kit comparison by vessel class.
