The short version
- There is no single Coast Guard first aid kit rule. The requirement lives in the subchapter that governs your vessel service.
- Fishing, 46 CFR 28.210: a contents list. Towing, 46 CFR 140.435: a capability standard. Small passenger, 46 CFR 184.710 and 121.710: a double incorporation by reference ending in a purchased ISO standard.
- What changes between them is not the contents but who carries the burden of proof at an inspection.
- Passenger count does not change the passenger rule, and tonnage appears in none of the three. Only towing scales, and it scales with route.
- Some classes have no rule at all. Part 131 for offshore supply vessels contains no first aid section, which is a heavier position than a bad rule, not a lighter one.
There is no single rule, and that is the whole problem
Ask what the Coast Guard requires in a commercial vessel first aid kit and you will get an answer. It will be confident, it will quote a regulation, and for most of the fleet it will be wrong, because it will quote the regulation for somebody else’s vessel.
A live capture of the first page for this question in August 2026 showed the generated summary answering it using 46 CFR 184.710 alone, the small passenger vessel rule. Programmatic checks on the full text returned false for 28.210, false for 140.435, false for 121.710, false for Subchapter M, false for the word fishing and false for the word towing. The contents list it offered was sourced in part to the Department of Justice Canada. Three of the nine ranking results were first aid kit vendors, one was Canadian legislation and one was a Facebook post.
So the answer an American fishing captain or towboat operator receives is drawn from a subchapter that does not apply to their vessel, padded with foreign law and product pages. The correction is not a better contents list. It is the recognition that the requirement is written three different ways for three different fleets.
Three classes, three ways of writing the same idea
| Vessel class | Section and drafting style | What the rule actually names |
|---|---|---|
| Commercial fishing Subchapter C, part 28 |
46 CFR 28.210 Contents list[1] |
Items, plus a first aid training obligation. Scope is set by the applicability rule at 28.200[11] |
| Towing Subchapter M, part 140 |
46 CFR 140.435 Capability standard[2] |
An industrial first aid cabinet or kit sized to crew and operating conditions, plus three route triggered capabilities: blood pressure, splinting, large wound dressing[2] |
| Small passenger Subchapter T and K |
46 CFR 184.710 and 121.710 Double incorporation by reference[3][4] |
A kit meeting 199.175(b)(10), which requires ISO 18813:2006(E) paragraph 4.12, a purchased standard[5][6] |
Read the middle column rather than the right one. The fishing rule tells you what to buy. The towing rule tells you what the kit must be able to do. The passenger rule tells you which document to go and read next, and that document is not published in the Code of Federal Regulations.
Notice also what does not vary the answer. Passenger count does not: 121.710 under Subchapter K is textually identical to 184.710, so a vessel carrying four hundred people faces the same wording as one carrying six[4]. Tonnage does not appear in any of the three. Only the towing rule scales with anything at all, and it scales with route rather than with size[2].
What actually changes is who has to prove it
The interesting difference between the three is not the contents. It is where the burden of proof sits when somebody opens the cabinet and asks a question.
| Class | How you satisfy it | What you have to be able to produce |
|---|---|---|
| Fishing | Match the published list[1] | The kit. The rule carries the burden, so an inventory is close to a complete answer |
| Towing | Show the kit achieves three named capabilities[2] | A written mapping from each capability to named items, plus the route determination that decided the tier |
| Small passenger | Match a purchased ISO standard, or argue equivalence to it[3][5] | Either an ISO certified kit, or an equivalence argument against a document you have to buy before you can read it |
That progression is worth sitting with, because it runs opposite to intuition. The least regulated looking rule, two sentences for towing vessels, produces more paperwork than the detailed one. And the passenger rule, which looks like the simplest of the three because it is a single cross reference, is the heaviest of all. Each of the three is walked through in full in the fishing article, the towing article and the passenger article.
The classes with no rule at all
The third thing nobody says out loud is that the obligation is not universal. Part 131, the operating regulations for offshore supply vessels under Subchapter L, runs to nine subparts covering markings, emergencies, survival craft, tests and drills, logs, work vests and fire equipment markings. It contains no first aid section and no medical equipment section[7].
What a missing rule does not mean
A class with no kit section is not a class with no medical obligation. Casualty reporting still applies, crew safety duties still apply, and charterers and underwriters still ask. What changes is that no regulator has written the standard for you, so the standard is whatever you can defend. That is a heavier position than any of the three above, not a lighter one, because there is not even a wrong answer to point at.
Related duties survive the gap. Towing vessels carry a health and safety records obligation at 140.505[9], which also creates a crewmember access right examined in crew medical records, and small passenger vessels carry a casualty notice duty at 185.202[10] that restates the federal injury trigger. The threshold inside that trigger is explained in the beyond first aid article, and what happens when the worst case arrives in the death on board procedure.
Working out which one applies to you
The subchapter follows the service the vessel is in, not the hull. Four questions settle it for almost every operator, and they should be answered per hull rather than per fleet.
- What service is the vessel certificated for? Fishing industry, towing, passenger, offshore supply. This is the subchapter, and it is on the certificate.
- Does the vessel operate in more than one service? A hull that fishes seasonally and tows the rest of the year can sit under two subchapters across a year, and the kit has to satisfy the stricter one at all times.
- What route is it certificated for? This only changes the towing answer, where oceans, coastwise and Great Lakes trigger the second tier[2], but it changes the practical answer everywhere, because distance to definitive care is a planning input. The method is in planning by voyage length.
- Does anything else reach the vessel? A flag, a class society, a port state or a charter clause can impose a heavier contents driven regime on top, compared in requirements by flag state.
What to do with the answer
The output of this exercise is a single page per hull, and it is worth more at an inspection than the kit itself.
- Name the governing section on the page. One citation. It ends the argument about which rule applies before it starts.
- Write the evidence in the form that section demands. An inventory for a contents list, a capability mapping for a capability standard, an equivalence argument for an incorporation by reference.
- Handle the medicines separately. Anything in the passenger kit has to conform to the over-the-counter monograph regime in 21 CFR part 330[12], and anything scheduled brings a different regime entirely, starting with the schedules.
- Assign expiry and restock to a named person. None of the three sections mentions expiry, which is exactly why it is the finding that recurs. Method in how to stock a chest.
- Decide who is called when the kit is not enough. No section addresses it, so the operator supplies it. Framework in the evacuation article.
Step one takes ten minutes per hull and it is the step almost nobody has done. If you want that mapping produced across a mixed fleet, with the kit specified and the evidence written for each class, that is maritime medical consulting and chest management. The whole library is indexed in the guidance library, and the physician who reviews it is on the about page.
Common questions
Is there one Coast Guard first aid kit rule for all commercial vessels?
No, and assuming there is one is the most common error on this subject. The requirement lives in the subchapter that governs your vessel class, and the three main ones are written in three different ways. The towing rule is in Subchapter M, the fishing rule in 46 CFR 28.210, and the passenger rule in Subchapter T.
Which rule applies to my vessel?
The subchapter follows the vessel service, not the size alone. Commercial fishing industry vessels fall under Subchapter C part 28, towing vessels under Subchapter M, small passenger vessels under Subchapter T or K depending on passenger numbers. A vessel in more than one service can carry more than one obligation, which is one of the six questions in programme setup.
Do all commercial vessels have a first aid kit requirement?
No. Some classes have none. Part 131, the operating rules for offshore supply vessels under Subchapter L, contains no first aid or medical equipment section at all. That does not make a kit optional in practice, because casualty reporting, crew safety and charterer expectations still apply. It means the standard is yours to set, and the reasoning belongs in writing. That is the subject of a compliance audit.
Why does it matter how the rule is written?
Because it decides who has to prove compliance. A contents list is satisfied by matching it. A capability standard is satisfied by a documented argument. An incorporation by reference is satisfied by a standard you have to buy. Three vessels in the same harbour can face three completely different evidential positions, which is set out in the table above.
Does the passenger vessel rule really point at an ISO standard?
It does. 46 CFR 184.710 points at 199.175(b)(10), which requires the kit to meet ISO 18813:2006(E) paragraph 4.12. 46 CFR 199.05 identifies that standard as Survival equipment for survival craft and rescue boats, obtainable from ISO in Geneva. The full chain is walked through in the Subchapter T article.
Who inspects the kit?
It depends on the class and, for towing vessels, on a choice already made. 46 CFR 136.130 gives two routes to a Certificate of Inspection, the Coast Guard option and the TSMS option, so a third party auditor may see the kit before any government inspector does. Fishing vessels face a different examination regime, covered in the six federal obligations.
What about vessels that operate internationally?
A United States vessel trading internationally can inherit a second, heavier obligation from a flag, a class society, a port state or a charter clause. Those regimes are contents driven and are compared in requirements by flag state, with what a port state control officer actually checks in the inspection checklist.
