Amend Small Vessel Regulations to Allow for The Use of Electronic LED Beacons As Flares
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As boaters regulated under the Small Vessel Regulations, SOR/2010-91 pursuant to the Canada Shipping Act, 2001, SC 2001, c 26 and being required in certain circumstances to keep and maintain "Pyrotechnic" devices, otherwise known as hand launched or pistol flares, WE THE UNDERSIGNED request that the above noted regulation be amended to enable small craft operators to comply with the regulations by maintaining on board, as an alternative, digital LED beacons or Electronic non-pyrotechnic devices for the following and other reasons:
1. Safety concerns:
A. Pyrotechnic flares have expiry dates and may in some cases fail to operate properly.
B. Pyrotechnic flares may fail due to moisture conditions prevalent on boats.
C. Pyrotechnic flares may increase the risk of a catastrophic incident in the event of a malfunction, misdirection and/or fuel leak.
D. Pyrotechnic flares may accidentally be operated incorrectly by children causing serious injury. In contrast, non-pyrotechnic devices can be operated by children without any issues of safety.
E. Pyrotechnic flares are prohibited from being used in non-emergency situations, thereby precluding practice in the proper techniques of operation. Emergency situations are stressful and are not the proper time to be reading a manual which may also be illegible in the dark. Digital LED Beacons on the other hand may be familiarized as regards their operation in an indoor environment.
A. Pyrotechnic devices need to be replaced and have a statutory shelf life of 4 years. Consequently they need to be repurchased regularly. Some locations sell at reduced prices as expiration dates approach.
B. Pyrotechnic devices are a source of Small Vessel Regulation enforcement violations to small vessel operators who may inadvertently have expired flares in their possession. The process of vessel inspections for "expiry dates" on pyrotechnical devices is a frivolous and unnecessary area of regulatory enforcement.
3. Disposal and Environmental Concerns ;
Pyrotechnic devices need to be properly disposed of after expiry causing environmental/landfill burdens.
Pyrotechnic flares have a very short burn period ,from a few seconds to a maximum of 2 minutes on parachute flares, compared to 60 hours of strobe SOS pattern flashing on electronic, FLOATING flares.
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