The short version
- 46 CFR 154.1400 to 154.1440 is a Safety Equipment group of eight sections. Six touch the medical programme.
- 154.1435 requires the MFAG copy. 154.1440 separately requires the antidotes prescribed in it.
- 154.1440 keys on the cargoes being carried, so the antidote set moves voyage to voyage.
- 154.1420 requires equipment to lift an injured person from a cargo tank, hold or void space.
- Cold injury and asphyxiation are the likely casualties, and neither has an antidote.
Eight consecutive sections, and six of them are medical
Buried in the design and equipment subpart of the liquefied gas carrier rules is a subject group headed Safety Equipment. It runs from 154.1400 to 154.1440, and the density of medical content in it is unmatched anywhere else in Title 46.[1]
| Section | Requirement | Medical or safety |
|---|---|---|
| 154.1400 | Safety equipment, all vessels[2] | The gateway section |
| 154.1405 | Respiratory protection[3] | Safety, with direct clinical consequence |
| 154.1410 | Decontamination shower, when Table 4 references the section[4] | Medical |
| 154.1415 | Air compressor[5] | Supports the respiratory sets |
| 154.1420 | Two stretchers or wire baskets, and equipment for lifting an injured person from a cargo tank, hold or void space[6] | Medical |
| 154.1430 | Equipment locker[7] | Storage discipline |
| 154.1435 | A copy of the IMO Medical First Aid Guide[8] | Medical |
| 154.1440 | The antidotes prescribed in the MFAG for the cargoes being carried[9] | Medical |
Six of the eight touch the medical programme directly. No other United States vessel class concentrates medical obligation like this, and no operator guidance exists for any of it.
Compare the emptiness elsewhere: Subchapter L has no medical provision at all, and Subchapter M is routinely answered with the wrong subchapter.
The guide and the antidotes are two separate duties
This is the drafting detail that decides whether a vessel passes or fails, and it is invisible unless the two sections are read together.
Both sections, complete text
154.1435 Medical first aid guide. “Each vessel must have a copy of the IMO Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, printed by IMO, London, U.K.”[8]
154.1440 Antidotes. “Each vessel must have the antidotes prescribed in the IMO Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, printed by IMO, London, U.K. for the cargoes being carried.”[9]
Carrying the book does not satisfy the antidote rule, and carrying the antidotes does not satisfy the book rule. They are separate sections with separate duties, and a vessel can fail either independently.
Note also the closing words of 154.1440: for the cargoes being carried.[9] The antidote set is not fixed to the vessel. It follows the cargo, so it changes with the voyage rather than with the certificate.
The chemical tanker rule is written differently, and the difference matters
Subchapter O covers both fleets, and both point at the same IMO guide. The drafting is not the same, and neither is the trigger.
| Point of difference | Chemical tankship, 46 CFR 153.930 | Gas carrier, 46 CFR 154.1435 and 154.1440 |
|---|---|---|
| Legal form | A prohibition. No person may operate the tankship unless the antidotes are aboard[10] | A duty. Each vessel must have[9] |
| Trigger | Carrying a cargo listed in Table 1[10] | The cargoes being carried, with the decontamination shower keyed to Table 4[9][4] |
| The guide itself | Referenced inside the antidote section[10] | Its own separate section, 154.1435[8] |
| Stretchers | Two, with lifting equipment for a pumproom or cargo tank | Two, with lifting equipment for a cargo tank, hold or void space[6] |
A fleet operating both types cannot run one procedure. Our article on the chemical tanker rule works through 153.930 and the two word first aid clause in 153.214 in full. Fleets that change flag inherit whichever set the new certificate carries.
What search returns for this fleet
A live capture in September 2026 for the medical requirements of a US liquefied gas carrier returns the eCFR index for part 154, govinfo PDF reprints of the subchapter, the IMO product page for the MFAG, a flag administration PDF of the guide, a library catalogue entry and a document sharing mirror.
The MFAG results are pure document hunting, the shape recorded on this project as unwinnable and commercially worthless when it is the target.[11] Here it is not the target, it is the evidence: everyone is looking for the file and nobody is explaining the two sections that make carrying it and stocking from it compulsory.
The pattern repeats across the classes we have mapped, from mobile offshore drilling units to research vessels to uninspected vessels. In every case the statute ranks and nothing translates it.
The hazard profile the antidote list does not cover
An antidote answers a poisoning. A gas carrier casualty is frequently not a poisoning.
The cargoes in this trade are carried refrigerated, under pressure, or both, and part 154 is explicit about the temperature range, running design cases down to minus 165 degrees Celsius.[12] The clinical picture that follows a release includes cold injury and asphyxiation in an oxygen displaced space, neither of which has an antidote.
Read 154.1420 as the tell
The regulation requires equipment for lifting an injured person from a cargo tank, hold or void space.[6] That is a confined space rescue specification written into a medical equipment section. The drafters expected the casualty to be unconscious, inside a tank, in an atmosphere nobody can breathe. Plan the medical response around that sentence.
If the casualty needs to leave the vessel, the medevac decision is next, and the reporting threshold decides what is owed afterwards.
Air breathing equipment carries its own operating section at 154.1852 and protective clothing at 154.1840.[13][14] Neither is a medical section, and both decide whether a medical response is possible at all.
Where the gas fleet sits against every other US class
Only two United States vessel classes are required to carry named medicines matched to what is in the tanks. Both are in Subchapter O.
| Class | Named medicines required? | What the rule actually names |
|---|---|---|
| Liquefied gas carrier 46 CFR 154 |
Yes[9] | MFAG antidotes for the cargoes being carried, plus the guide itself as a separate duty[8] |
| Chemical tankshipsee the part 153 review | Yes[10] | MFAG antidotes for Table 1 cargo, as a condition of operating |
| Commercial fishingsee the part 28 review | No | A medicine chest with no contents list |
| Small passenger, Subchapter T | No | First aid kits pointing at a standard |
| Sailing school, Subchapter R | No | One approved kit, one sentence |
The full kit comparison by class sets the rest out, and hospital space is a separate trigger a gas carrier can meet at the same time.
Antidotes are pharmaceuticals, with everything that follows
Operators treat 154.1440 as a stores line. It is a pharmacy line.
An MFAG antidote set matched to the cargoes carried can include prescription only medicines with acquisition, storage, shelf life and administration questions attached. Where any of them is scheduled, 21 CFR 1301.25 applies and the vessel needs either a DEA registered medical officer employed by the owner or operator, or the master requisition route.[15]
Read the 21 CFR 1301.25 walkthrough, then the two route comparison, then the record set. Expiry is the recurring cost: an antidote carried for years and never used still has to be replaced, and disposal of the scheduled fraction runs through 21 CFR part 1317.
That whole lifecycle is what our ship medical chest management service runs on a schedule, using the method in how to stock a ship medicine chest and audited the way an inspector checks a programme.
Seven checks for a gas carrier programme
- Confirm a current MFAG copy is aboard. 154.1435 is its own section and a missing book is its own finding.[8]
- Rebuild the antidote list against the cargoes actually being carried, not the vessel type. 154.1440 keys on the voyage.[9]
- Separate the prescription and scheduled antidotes and route them through 21 CFR 1301.25 before purchase.[15]
- Check the decontamination shower against Table 4 for the cargoes endorsed.[4]
- Verify two stretchers and the tank extraction equipment, and rehearse the lift from a void space.[6]
- Tie the equipment locker inventory to the antidote expiry list so one inspection covers both.[7]
- Write the cold injury and asphyxiation response, because no antidote covers either.
Discovery Health MD is led by Ann Jarris MD, MBA, FACEP, a board certified emergency physician. Matching cargoes to antidotes, separating the scheduled ones and writing the response for the injuries the antidote list does not cover is the work. Programme frame in the six decisions, distance sizing in time to definitive care, and the governance question in who is responsible. Our consulting line covers all three. Speak to the team.
Common questions
What medical equipment must a US liquefied gas carrier carry?
More than any other US vessel class. The Safety Equipment group in 46 CFR part 154 runs 154.1400 to 154.1440 and six of its eight sections touch the medical programme: respiratory protection, a decontamination shower, an air compressor, two stretchers with tank extraction equipment, an equipment locker, a copy of the IMO Medical First Aid Guide, and the antidotes prescribed in it[1][6][8][9]. No operator guidance exists for any of it, which is what our MedChest service supplies.
Is carrying the MFAG enough to comply?
No. 46 CFR 154.1435 and 154.1440 are separate sections creating separate duties. 154.1435 requires a copy of the IMO Medical First Aid Guide aboard[8]. 154.1440 separately requires the antidotes prescribed in that guide for the cargoes being carried[9]. Carrying the book does not satisfy the antidote rule and carrying the antidotes does not satisfy the book rule. A vessel can fail either one independently.
Does the antidote set change with the voyage?
Yes. 46 CFR 154.1440 requires the antidotes prescribed in the MFAG for the cargoes being carried[9]. It keys on the actual cargo, not on the vessel type or the certificate, so the required set moves voyage to voyage. That differs from the chemical tanker rule at 46 CFR 153.930, which keys on a cargo listed in Table 1[10]. A fleet running both types cannot use one procedure.
How does the gas carrier rule differ from the chemical tanker rule?
Four ways. Legal form: 153.930 is a prohibition, no person may operate unless the antidotes are aboard, while 154.1440 is a duty, each vessel must have[9][10]. Trigger: Table 1 cargo versus the cargoes being carried. The guide: referenced inside the tanker antidote section, but given its own section at 154.1435 for gas carriers[8]. Stretcher scope: pumproom or cargo tank versus cargo tank, hold or void space[6].
Are the antidotes controlled substances?
Some can be, depending on the cargoes. An MFAG antidote set is pharmaceuticals rather than stores, and can include prescription only medicines. Where any is scheduled, 21 CFR 1301.25 applies and the vessel needs either a DEA registered medical officer employed by the owner or operator, or the master requisition route[15]. Expiry is the recurring cost, and disposal of the scheduled fraction runs through 21 CFR part 1317. Read the 21 CFR 1301.25 walkthrough.
What does 46 CFR 154.1420 actually require?
Two stretchers or wire baskets, and equipment for lifting an injured person from a cargo tank, hold or void space[6]. Read the second half carefully: that is a confined space rescue specification written into a medical equipment section. The drafters expected an unconscious casualty inside a tank in an atmosphere nobody can breathe. A gas carrier medical response should be planned around that sentence rather than around the antidote list.
Do antidotes cover the main gas carrier injuries?
No, and this is the gap operators miss. Part 154 cargoes are carried refrigerated, under pressure, or both, with design cases running to minus 165 degrees Celsius[12]. The clinical picture after a release includes cold injury and asphyxiation in an oxygen displaced space, and neither has an antidote. Air breathing equipment at 154.1852 and protective clothing at 154.1840 decide whether a response is possible at all[13][14]. Our consulting line writes that response.
