The short version
- 46 CFR 28.270 requires drills and instruction for every individual on board, at least once each month, covering ten named contingencies[1].
- Drills must be run as if the emergency were real, with everyone taking part, emergency equipment broken out and used, alarms tested and immersion suits donned[1].
- Only a person trained in the proper procedures may run them. They do not have to be the master or even a crew member[1].
- The ten contingencies contain no medical drill. Recovering a person from the water is there; treating them afterwards is not[1].
Which vessels this rule actually binds
28.270 sits in subpart C of 46 CFR part 28, which applies to documented vessels that operate beyond the Boundary Lines, vessels carrying more than 16 individuals on board, and fish tender vessels in the Aleutian trade[2]. A small inshore boat inside the line is not covered by this section, though the rest of part 28 still applies[8].
Check which set of rules your vessel falls under before you build a drill schedule. Our commercial fishing vessel medical requirements guide maps part 28 by vessel type.
The ten contingencies, verbatim
The master or individual in charge must ensure each person aboard is familiar with their duties and response to at least these[1].
| # | Contingency, 46 CFR 28.270(a)[1] | What a real drill looks like |
|---|---|---|
| 1 | Abandoning the vessel | Muster, count, survival craft assignment |
| 2 | Fighting a fire in different locations on board | Engine room and galley, not one station |
| 3 | Recovering an individual from the water | Timed, with the actual recovery device |
| 4 | Minimizing the effects of unintentional flooding | Pumps run, plugs and patches located |
| 5 | Launching survival craft, recovering lifeboats and rescue boats | Hydrostatic release and painter checked |
| 6 | Donning immersion suits and other wearable PFDs | Against a stopwatch, in the dark |
| 7 | Donning a fireman’s outfit and SCBA, if carried | Air bottle pressure logged |
| 8 | Making a voice radio distress call and using visual signals | Script read from the posted instructions |
| 9 | Activating the general alarm | Heard from every space, including the bunk |
| 10 | Reporting inoperative alarm and fire detection systems | A named person and a written route |
How often, and how real
At least once each month, for each individual on board[1]. Instruction may be given with the drill or at another time and place, but paragraph (b) is strict about the drill itself: conducted as if there were an actual emergency, with participation by all individuals aboard, emergency equipment broken out and used, all alarm and detection systems tested, protective clothing donned and immersion suits donned if carried[1].
The videotape trap
Paragraph (d) allows video instruction on the ten contingencies, followed by a discussion led by someone familiar with them. It satisfies the instruction requirement only. It does not satisfy the drill requirement in paragraph (b) or the safety orientation in paragraph (e)[1]. A fleet that shows a video and logs it as a drill is non-compliant.
Who is allowed to run the drill
No individual may conduct the drills or give the instruction unless trained in the proper procedures for it[1]. The note to the section makes the flexibility explicit: the person need not be the master, the individual in charge, or even a member of the crew[1].
46 CFR 28.275 sets how a Fishing Vessel Safety Instructor is accepted: a detailed curriculum tied to the ten contingencies, or a letter certifying use of the national Personal Survival and Emergency Drills Course, submitted to the cognizant OCMI, plus experience or a Coast Guard licence. The OCMI issues a letter of acceptance valid for 5 years, and instructors issue documents to drill conductors on completion[4].
| Role | What the rule requires | Where it is written |
|---|---|---|
| Drill conductor | Trained in the proper procedures; need not be crew | 28.270(c) and note[1] |
| Fishing Vessel Safety Instructor | Curriculum tied to the 10 contingencies, OCMI letter, valid 5 years | 28.275[4] |
| First aid and CPR certificate holders | 1 each above 2 aboard, 2 each above 16, 4 each above 49 | 28.210[5] |
The safety orientation everybody forgets
A new hand who joined after the last drill cannot wait for the next one. Paragraph (e) requires a safety orientation for each individual aboard who has not had the instruction and has not taken part in the drills, before the vessel may be operated[1]. The orientation must explain the emergency instructions required by 28.265 and cover the same ten evolutions[1].
28.265 is the posting rule: emergency instructions in conspicuous locations, identifying survival craft stations and assignments, the fire, emergency and abandon ship signals, immersion suit locations with illustrated donning instructions, and a scripted distress call[3]. That script includes a line most crews skip in rehearsal: give the number of individuals aboard and the nature of any injuries[3].
The medical gap in the ten contingencies
Read the list again. Fire, flooding, abandon ship, recovery from the water, suits, radio, alarms. There is no drill for treating a crush injury, controlling bleeding, running CPR on a recovered casualty or handing a case to a shore physician. The rule stops at pulling the person out of the water[1].
The data says that is where people die. In 204 fatal falls overboard from 2000 to 2016, 22 casualties were recovered from the water and none were successfully resuscitated[6]. NIOSH separately recommends monthly man-overboard drills, rescue slings rather than life rings, and re-boarding ladders[7].
Add three medical evolutions to the monthly drill
- Recovery to treatment handover. Continue drill 3 past the rail: airway, CPR, hypothermia handling. See cold water immersion survival.
- Chest break-out under time. Can the certified crew member find haemorrhage control and analgesia in the dark? See ship medical chest management.
- The physician call. Rehearse the radio script with injuries included[3], then the decision in when to medevac a seafarer.
None of this conflicts with the rule. 28.270 sets a floor of ten contingencies, and it says “at least”[1].
Records: what the rule says, and what an examiner expects
28.270 sets no logbook requirement of its own[1]. That is not a reason to skip the record. A dockside examiner, an insurer after a claim, or a plaintiff’s lawyer will ask what was drilled, when, and who took part, and an undated recollection is worth nothing.
- Date, vessel, position or berth, and every person aboard who took part.
- Which of the ten contingencies were covered, and the equipment actually broken out.
- Time taken to don immersion suits, and to recover the dummy from the water.
- The drill conductor’s name and their training basis[1][4].
- Any safety orientation given to a new hand, and the date[1].
- Defects found, and the date each was cleared.
Fishing vessels are not required to keep the official logbook that certain merchant vessels keep, but the discipline transfers. See official logbook medical entries for how medical events are recorded on vessels that do.
What to do this month
Put the ten contingencies on one page, add the three medical evolutions above, name a trained drill conductor, and hold the first real drill before the next trip. Discovery Health MD writes the medical half: chests under MedChest, scheduled drugs and DEA paperwork under controlled substances management, and drill protocols under maritime medical consulting. Ask a physician to review your drill card.
Common questions
How often must a commercial fishing vessel hold drills?
At least once each month, for each individual on board, under 46 CFR 28.270(a)[1].
What drills are required on a fishing vessel?
Ten contingencies: abandoning the vessel, fighting fires in different locations, recovering an individual from the water, minimizing flooding, launching survival craft and recovering boats, donning immersion suits and PFDs, donning a fireman’s outfit and SCBA if carried, making a voice radio distress call and using visual signals, activating the general alarm, and reporting inoperative alarm and fire detection systems[1].
Who can conduct fishing vessel drills?
Anyone trained in the proper procedures. The note to 28.270 states the person need not be the master, the individual in charge, or a crew member[1]. Accepted instructors are covered by 28.275, whose OCMI letters run for 5 years[4].
Does watching a safety video count as a drill?
No. Video plus a led discussion satisfies the instruction requirement only. It does not satisfy the drill in paragraph (b) or the safety orientation in paragraph (e)[1].
Does a new crew member need anything before the vessel sails?
Yes. A safety orientation before the vessel may be operated, covering the emergency instructions of 28.265 and the same ten evolutions[1][3].
Which vessels does 46 CFR 28.270 apply to?
Subpart C vessels: documented vessels operating beyond the Boundary Lines, vessels with more than 16 individuals on board, and fish tender vessels in the Aleutian trade[2].
Is a medical or first aid drill required?
Not by 28.270. The ten contingencies stop at recovering a person from the water[1]. First aid and CPR appear separately in 28.210, which requires certificate holders and a medicine chest but no drill[5]. Adding a medical evolution is a decision each operator makes.
Must drills be logged?
28.270 imposes no recordkeeping requirement[1]. Examiners, insurers and lawyers still expect a dated record showing who took part and what was used.
