The short version
- 33 CFR 149.323 requires an industrial first aid kit sized to the maximum number of persons on the port, not the normal crew.
- The kit must sit in a designated medical treatment room or under the custody of the person in charge.
- It must be accompanied by HHS Publication (PHS) 84-2024, the 1984 edition, although a 2003 edition of the same title exists.
- Manned means one person in an accommodation space for more than 30 consecutive days in a rolling 12 months.
- The litter must be capable of hoisting an injured person, not merely carrying one.
A federal rule still tells you to buy a 1984 government pamphlet
Most outdated maritime medical guidance is outdated by custom. This one is outdated in the binding text, and it has not been touched since 2017.
33 CFR 149.323(c), what must accompany the kit
“The operator must ensure that each first aid kit is accompanied by a copy of either the Department of Health and Human Services Publication No. (PHS) 84-2024, ‘The Ship’s Medicine Chest and Medical Aid at Sea,’ available from the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402, or the ‘American Red Cross First Aid and Safety Handbook,’ available from Little Brown and Company, 3 Center Plaza, Boston, MA 02018.”[1]
Read the publication number. 84-2024 is the 1984 edition. A later edition of the same title was issued in 2003 and is the one the industry actually uses.[2] The regulation names the older one and gives a mail-order address for a print office.
This is the third live pointer defect we have documented in US medical rules, alongside the sailing school kit pointing at a deleted subpart and Google serving a withdrawn ILO instrument for chest contents. The pattern is consistent: medical cross-references are the last thing anyone updates.
Manned means thirty days, and it is not what operators assume
Part 149 sits under the Deepwater Port Act, 33 U.S.C. 1504, which is a different authority from the one behind the vessel rules in Title 46.[8] Everything in this subpart hangs on one definition, and it is a duration test rather than a headcount.
33 CFR 149.301(a)
“Each deepwater port on which at least one person occupies an accommodation space for more than 30 consecutive days in any successive 12-month period must comply with the requirements for lifesaving equipment in this subpart.”[3]
One person. Thirty-one consecutive days. Once in a rolling year. That is enough to pull the port into the manned regime, and with it the first aid kit, the litter and the medical treatment room language.
A port that runs day crews for eleven months and then leaves one technician aboard through a month-long commissioning has changed category. Nothing about the headcount looks different, and the compliance position has moved.
Three duties in one short section
33 CFR 149.323 is six lines long and creates three separate obligations that are usually treated as one.[1]
| Paragraph | The duty | How it is failed |
|---|---|---|
| 149.323(a) | An industrial first aid kit, approved by an appropriate organisation such as the American Red Cross, sized for the maximum number of persons on the port[1] | Sizing to the normal crew instead of the maximum POB |
| 149.323(b) | Kept in a space designated as a medical treatment room, or, if there is none, under the custody of the person in charge[1] | No designated space and no named custodian |
| 149.323(c) | Accompanied by the named publication[1] | No book beside the kit at all |
The comparison across US classes is set out in the kit requirements by vessel class, and the survival craft kit runs on an entirely separate ISO standard. Paragraph (a) is the one with financial consequence. Sizing runs on maximum persons on board, so a port that peaks at 60 during a turnaround needs a kit for 60, not for the 14 who are normally there.
Paragraph (b) is quietly the most interesting. It contemplates a medical treatment room without requiring one, then supplies a fallback. Compare the hospital space trigger on vessels, which is mandatory above a crew threshold, and 46 CFR 108.209 on MODUs, which requires the facility outright.
The litter requirement says hoist, and that word does work
33 CFR 149.324 requires each manned deepwater port to have at least one Stokes or other suitable litter, capable of safely hoisting an injured person, readily accessible in an emergency.[4]
Hoisting, not carrying. On a structure where the casualty may have to come up from a lower deck or leave by helicopter, a flat carry litter does not meet the wording. The same distinction appears in 46 CFR 154.1420, which requires equipment for lifting an injured person out of a cargo tank, hold or void space.
Where a casualty has to be reported afterwards, the reporting threshold and the record you keep both attach. Two US rules, two different structures, the same underlying clinical problem: the casualty is below you and the exit is above.
Next door, on the OCS, there is almost nothing
Fixed and floating facilities on the Outer Continental Shelf sit under 33 CFR subchapter N. Read its parts and the medical content is close to absent.[5]
| Regime | First aid provision | Casualty handling |
|---|---|---|
| Deepwater port, manned 33 CFR part 149 |
Yes. Industrial kit sized to maximum POB, plus a named publication[1] | Yes. Hoist-capable litter[4] |
| OCS facility 33 CFR subchapter N |
No first aid section. The nearest provision is eyewash equipment at 33 CFR 142.48[6] | Not specified in the subchapter |
| MODU 46 CFR Subchapter I-A |
Facility rather than equipment[7] | Hospital space above a threshold |
Three offshore structures, three unrelated answers. An operator running all three writes three procedures or, more commonly, writes one and quietly fails two. That is the argument for a single programme with class-specific annexes, owned ashore by the DPA rather than by each installation.
Nobody is coming quickly, which is the point
A deepwater port is by definition offshore, so the medical planning question is not what the kit contains but how long the casualty waits. Planning by time to definitive care is the honest frame, and the medevac decision is the one the person in charge will actually have to make.
If the injury crosses the line into treatment beyond first aid and unfitness for duty, a floating OCS facility is inside the serious marine incident regime and the two hour chemical testing clock starts. A first aid kit and a litter do not answer that.
Our ship medical chest management service sizes and dates the kit against maximum persons on board. Our maritime medical consulting line handles the part the regulation does not reach: who decides, who is called, and how the casualty leaves.
Six checks for a manned deepwater port
- Test the 30 day question honestly across the last rolling 12 months, including commissioning and turnaround periods.[3]
- Size the kit to maximum persons on board, not to the normal complement.[1]
- Designate the medical treatment room, or name the custodian in writing. The regulation accepts either, not neither.[1]
- Put a copy of the publication beside the kit and record which edition you carry, because the cited number is the 1984 one.[1][2]
- Check the litter can hoist, not just carry, and that it is reachable without unlocking a store.[4]
- Write the offshore escalation, because nothing in part 149 tells you who to call.
Discovery Health MD is led by Ann Jarris MD, MBA, FACEP, a board certified emergency physician. Sizing an industrial kit to peak POB, choosing which edition of a superseded publication to carry, and writing the offshore escalation the CFR omits is the work. Audited the way an inspector checks. Speak to the team.
Common questions
What first aid kit does a manned deepwater port need?
An industrial kit sized to the maximum number of persons aboard. 33 CFR 149.323(a) requires each manned deepwater port to have an industrial first aid kit, approved by an appropriate organisation such as the American Red Cross, for the maximum number of persons on the deepwater port[1]. Sizing to the normal complement rather than the peak is the usual failure, because a turnaround can multiply persons on board several times over.
What counts as a manned deepwater port?
A duration test, not a headcount. 33 CFR 149.301(a) applies the manned requirements to each deepwater port on which at least one person occupies an accommodation space for more than 30 consecutive days in any successive 12-month period[3]. One person for thirty-one consecutive days once in a rolling year is enough. A port that leaves a single technician aboard through a month-long commissioning has changed category without changing its staffing model.
Does a deepwater port need a medical treatment room?
It is contemplated but not compelled. 33 CFR 149.323(b) requires the first aid kit to be maintained in a space designated as a medical treatment room or, if there is no medical treatment room, under the custody of the person in charge[1]. The regulation accepts either arrangement, but not neither, so a port without a designated space needs a named custodian on paper. Compare the hospital space trigger on vessels and 46 CFR 108.209 on MODUs, which requires the facility outright[7].
Which book has to be kept with the kit?
One of two named titles, and the citation is dated. 33 CFR 149.323(c) requires the kit to be accompanied by either HHS Publication No. (PHS) 84-2024, The Ship’s Medicine Chest and Medical Aid at Sea, or the American Red Cross First Aid and Safety Handbook[1]. The publication number identifies the 1984 edition, while a later edition of the same title was issued in 2003[2]. Carry a copy, and record which edition you hold.
What are the litter requirements on a deepwater port?
One litter, and it must hoist. 33 CFR 149.324 requires each manned deepwater port to have at least one Stokes or other suitable litter, capable of safely hoisting an injured person, and it must be readily accessible in an emergency[4]. Hoisting is the operative word: a flat carry litter does not satisfy it on a structure where the casualty leaves upward. The same problem is addressed on liquefied gas carriers by 46 CFR 154.1420.
Do OCS facilities have a first aid requirement?
Not in the way operators expect. 33 CFR subchapter N, which governs Outer Continental Shelf activities, contains no first aid or medical services section; the nearest provision is the eyewash equipment requirement at 33 CFR 142.48[5][6]. Deepwater ports under part 149 and MODUs under 46 CFR Subchapter I-A each have their own, different answer. An operator running all three structures needs class-specific annexes rather than one procedure.
Does the serious marine incident testing rule reach an offshore facility?
Yes, for floating OCS facilities and MODUs. 46 CFR subpart 4.06 applies to vessels in commercial service, floating OCS facilities and MODUs, and an injury requiring professional medical treatment beyond first aid that also renders the person unfit for routine duties makes the event a serious marine incident. Alcohol testing then has a two hour clock. A first aid kit and a litter do not address that duty, which is why the offshore escalation has to be written separately.
