The short version
- 46 CFR 199.175(b)(10) sets the survival craft first aid kit by ISO 18813:2006(E) paragraph 4.12.
- Medicinal active ingredients are limited to over-the-counter drugs under 21 CFR part 330, so no prescription medicine belongs in a lifeboat kit.
- Table 1 counts the first aid kit per craft and the seasickness kit per person. Crews reverse that ratio.
- 46 CFR 169.725 still requires a kit built to subpart 160.041, which was removed and reserved in 2022.
- Part 199 excludes five vessel classes by name, and each of them has a thinner medical rule.
The kit in your lifeboat is specified by a standard you have to buy
Most US medical equipment rules name nothing. This one names a document, and the document is not free.
46 CFR 199.175(b)(10), First-aid kit, complete text
“Each first-aid kit must meet the requirements in ISO 18813:2006(E) paragraph 4.12 (incorporated by reference, see § 199.05).”[1]
Two subparagraphs follow. A kit is acceptable without the burn preparations if the omission is clearly marked on the kit itself, and the active ingredients in medicinal products must conform to the over-the-counter drug regulations in 21 CFR part 330.[1][2]
Read that second clause slowly. The contents of a survival craft kit are limited to OTC actives. No prescription medicine belongs in a lifeboat kit, which is a different rule from the one governing the ship’s chest.
The binding contents list sits behind a Swiss paywall
46 CFR 199.05 incorporates ISO 18813:2006(E), Ships and marine technology, Survival equipment for survival craft and rescue boats, first edition 1 April 2006, and directs anyone who wants a copy to ISO in Vernier, Geneva.[3]
So the legally binding contents of a US lifeboat first aid kit are set by a twenty-year-old international standard that a US operator must purchase from a Swiss organisation. That is the same structure as the chemical tanker antidote rule, where 46 CFR 153.930 makes an IMO publication binding, and the gas carrier rule, where 46 CFR 154.1435 does it again.
Three separate US medical requirements now point outside the CFR for their content. No page on the open web collects them.
One class still points at a subpart that no longer exists
This is the finding an operator can check in ninety seconds, and it has been sitting in the CFR since December 2022.
The Coast Guard final rule USCG-2020-0107, effective 14 December 2022, removed Coast Guard type approval for nine equipment categories and replaced it with manufacturer self-certification to consensus standards. In the process it removed and reserved 46 CFR subpart 160.041, the old approved first aid kit standard.[4][5]
| Rule | What it points at today | Does the target exist? |
|---|---|---|
| 46 CFR 199.175(b)(10) Inspected vessels, survival craft |
ISO 18813:2006(E) paragraph 4.12[1] | Yes. Purchasable from ISO |
| 46 CFR 184.710 Subchapter T |
46 CFR 199.175(b)(10), or a kit with equivalent contents[6] | Yes. Updated by the 2022 rule |
| 46 CFR 121.710 Subchapter K |
46 CFR 199.175(b)(10), or a kit with equivalent contents[7] | Yes. Updated by the 2022 rule |
| 46 CFR 169.725 Subchapter R |
“an approved first aid kit, constructed and fitted in accordance with subpart 160.041 of this chapter”[8] | No. Subpart 160.041 is Removed and Reserved[9] |
Subchapter T and Subchapter K were re-pointed at the ISO kit. Sailing school vessels were not. 46 CFR 169.725 still requires a kit built to a subpart that contains no text.[8][9]
What this means in practice
A sailing school vessel cannot literally comply with 169.725 as written, because the construction standard it names has been deleted. The defensible position is to carry a kit meeting 46 CFR 199.175(b)(10), document the reasoning, and keep the record. That is a written decision, not a purchase.
Part 199 does not reach five classes, and each of those is weaker
46 CFR 199.01 applies part 199 to all inspected US vessels, then excludes five classes by name: offshore supply vessels under Subchapter L, mobile offshore drilling units under Subchapter I-A, towing vessels under Subchapter M, small passenger vessels under Subchapters K and T, and sailing school vessels under part 169.[10]
That exclusion list reads like an index to the weakest medical rules in Title 46. Subchapter L has no medical provision at all. Subchapter I-A gives a facility, not equipment. Subchapter M is routinely answered with the wrong subchapter, and uninspected vessels sit outside the inspection regime entirely.
The pattern our kit comparison by class documents holds here too: the more specific the rule, the fewer vessels it reaches.
Table 1 has 41 items, and only two of them are medical
Table 1 to 46 CFR 199.175 sets quantities across six columns: lifeboat, rigid liferaft and rescue boat, split between international and short international voyages.[1]
| Item | Quantity basis | Standard behind it |
|---|---|---|
| Item 10, first aid kit | 1 per craft, in every one of the six columns[1] | ISO 18813:2006(E) 4.12, OTC actives only |
| Item 29, seasickness kit | Units per person, on four of the six columns[1] | Specified in the CFR itself, not by ISO |
| Items 22 and 40, provisions and water | Per person | Rations and litres, not medical |
The seasickness kit is the one medical item Congress and the Coast Guard were willing to write out in full. Each kit must be in a waterproof package and include one waterproof seasickness bag, anti-seasickness medication sufficient for one person for 48 hours, and instructions for using the medication.[1] Each kit should be stowed within reach of the seat it belongs to.
A boat certified for 40 people therefore needs 40 seasickness kits and one first aid kit. Crews consistently get that ratio backwards at the chandler.
The lifeboat kit is not the ship’s medicine chest
These are two different legal objects and they answer to two different standards.
The survival craft kit is limited to OTC actives under 21 CFR part 330.[1][2] The ship’s chest is not, which is why chest stocking runs through prescription decisions and scheduled drugs at all. If your chest carries anything scheduled, 21 CFR 1301.25 attaches to the vessel and the recordkeeping duty starts.
Our ship medical chest management service treats them as two inventories on two clocks, because they expire independently and are inspected by different people. Fleets that change flag inherit a new chest standard while the survival craft kit, tied to the US certificate, stays where it is.
Nothing in the rule mentions expiry, which is the real failure mode
Search the section for a shelf life provision and there is none. The grandfather clause at 199.175(c) says only that Coast Guard approved equipment aboard before 14 December 2022 may remain aboard as long as it remains in good and serviceable condition.[1]
Good and serviceable is doing heavy lifting there. A kit with in-date bandages and expired medication is not serviceable in any medical sense, and a boarding officer opening a sealed kit is the moment that gets discovered.
- Sealed kits still expire. The seal proves nobody has raided it, not that the contents are in date.
- Anti-seasickness medication is the shortest clock aboard and it sits in a boat nobody opens between drills.
- Per-person items scale with the certificate. Change the certificated capacity and the seasickness kit count changes with it.
Building that into a single expiry register is the same discipline as an audit walkthrough, and it belongs in the programme setup rather than in a chandler’s order.
Six checks before the next drill
- Confirm which rule reaches your vessel. Inspected and not on the 199.01 exclusion list means part 199 applies directly.[10]
- Count kits against Table 1, per craft for the first aid kit and per person for the seasickness kit.[1]
- Check the burn preparation marking. A kit without burn preparations is legal only if the omission is marked on the kit.[1]
- Audit for prescription items. Anything beyond OTC actives does not belong in a survival craft kit.[2]
- Put every kit on the chest expiry register, including the boats, and date the seals.
- If you operate a sailing school vessel, write the 169.725 decision down before an inspector asks how you complied with a reserved subpart.[8][9]
Discovery Health MD is led by Ann Jarris MD, MBA, FACEP, a board certified emergency physician. Separating the survival craft kit from the ship’s chest, and writing a defensible position where the CFR points at nothing, is exactly the work our maritime medical consulting line does. Speak to the team.
Common questions
What first aid kit must a lifeboat carry on a US vessel?
One that meets ISO 18813:2006(E) paragraph 4.12. 46 CFR 199.175(b)(10) states that each first-aid kit must meet the requirements in ISO 18813:2006(E) paragraph 4.12, incorporated by reference at 46 CFR 199.05[1][3]. A kit is acceptable without the burn preparations only if that omission is clearly marked on the kit itself, and the active ingredients in medicinal products must conform to the over-the-counter drug regulations in 21 CFR part 330[1][2]. Table 1 to the section requires one kit per craft.
Can a lifeboat first aid kit contain prescription medicine?
No. 46 CFR 199.175(b)(10)(ii) requires that the active ingredients in medicinal products conform to the over-the-counter drug regulations set out in 21 CFR part 330[1][2]. That limits a survival craft kit to OTC actives. Prescription and scheduled medicines belong in the ship’s medicine chest, which answers to a different standard and, where anything is scheduled, to 21 CFR 1301.25.
How many seasickness kits does a survival craft need?
One per person, not one per boat. Table 1 to 46 CFR 199.175 lists the seasickness kit as item 29 with the quantity basis units per person, while the first aid kit at item 10 is one per craft[1]. Each seasickness kit must be in a waterproof package and include one waterproof seasickness bag, anti-seasickness medication sufficient for one person for 48 hours, and instructions for using the medication[1]. A boat certificated for 40 needs 40 seasickness kits.
Is 46 CFR subpart 160.041 still in force?
No. Coast Guard final rule USCG-2020-0107, effective 14 December 2022, removed and reserved subpart 160.041 along with eight other type approval subparts, replacing Coast Guard approval with manufacturer self-certification to consensus standards[4][5]. The eCFR now shows subpart 160.041 as reserved with no text[9]. Any rule still pointing at it is pointing at nothing.
Does 46 CFR 169.725 still work for sailing school vessels?
It names a standard that no longer exists. 46 CFR 169.725 states that each vessel must carry an approved first aid kit constructed and fitted in accordance with subpart 160.041 of this chapter, and subpart 160.041 was removed and reserved in 2022[8][9]. Subchapter T at 46 CFR 184.710 and Subchapter K at 46 CFR 121.710 were both re-pointed at 46 CFR 199.175(b)(10) by the same rule[6][7]. The sailing school pointer was not updated.
Which vessels does 46 CFR part 199 apply to?
All inspected US vessels except five named classes. 46 CFR 199.01 excludes offshore supply vessels under Subchapter L, mobile offshore drilling units under Subchapter I-A, towing vessels under Subchapter M, small passenger vessels under Subchapters K and T, and sailing school vessels under part 169[10]. Each excluded class has its own lifesaving rules, and in medical terms each of them is thinner than part 199. See our comparison of kit requirements by vessel class.
Do survival craft first aid kits expire?
The regulation does not set a shelf life, which is why they are missed. 46 CFR 199.175(c) allows Coast Guard approved equipment aboard before 14 December 2022 to remain aboard as long as it remains in good and serviceable condition[1], and medication past its date is not serviceable. Anti-seasickness medication has the shortest clock aboard and sits in a boat that is rarely opened between drills. Put every survival craft kit on the same expiry register as the ship’s medicine chest.
