Jim;
Dennis is right in pointing out that you can use any light you chose on your boat – so long as it meets the INTERNATIONAL requirements for color, arc, and visibility that are encompassed in the COLREGS and the CFR that he referenced. Now if you ARE using a candle in a Pringles can, you might have a problem after a collision … and it seems pretty likely that you will get to know more than your share of Coasties. But if you use good quality bulbs from reputable sources, you won’t have a problem. That said, Aquasignal is, strictly speaking, correct when they say that their fixtures are no longer “certified” if you use someone else’s bulbs. But that’s a big whoop and totally irrelevant to an individual boater. The performance, testing, and labeling requirements for certification are spelled out in 33CFR, Chapter 1, Subchapter S, Part 183, Subpart M. Among other things, the regulations contain the following passage: § 183.801 Applicability. This subpart applies to recreational <https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=f35484dfcb0c265deca1ef21656e7496&term_occur=1&term_src=Title:33:Chapter:I:Subchapter:S:Part:183:Subpart:M:183.801> vessel manufacturers, distributors, and <https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=5256fe34d71d8f3898c91294b214c70f&term_occur=1&term_src=Title:33:Chapter:I:Subchapter:S:Part:183:Subpart:M:183.801> dealers installing such equipment in new recreational <https://www.law.cornell.edu/definitions/index.php?width=840&height=800&iframe=true&def_id=f35484dfcb0c265deca1ef21656e7496&term_occur=2&term_src=Title:33:Chapter:I:Subchapter:S:Part:183:Subpart:M:183.801> vessels constructed after November 1, 2002. So unless you are building recreational boats for sale in the US (lights for commercial vessels are covered by a different CFR) the requirement for certified lights does not apply to you. Rick Brass Washington, NC From: CnC-List [mailto:cnc-list-boun...@cnc-list.com] On Behalf Of Dennis C. via CnC-List Sent: Friday, August 11, 2017 5:18 PM To: CnClist <cnc-list@cnc-list.com> Cc: Dennis C. <capt...@gmail.com> Subject: Re: Stus-List changing stern light & converting nav lights to LEDs? Jim, I spent 30 years in the regulatory field. There's always some fine points to compliance. There's differences between regulation, enforcement policy, equipment certifications, etc. There is the occasional Coastie that will try to jam an enforcement policy up your nose but in the end, the regulations are what rule. AquaSignal has gotten their light fixtures, with bulbs, "certified" to USCG standards. Aquasignal gets their fixtures "certified" to assure their customers that the fixture meets the regulatory requirements for color, arc, visibility distance, etc. Whoopee. Now, consider the actual regulations that apply to your boat. Federal light requirements for vessels can be found in 33 CFR 83.20-31. This regulation states the colors, arcs, and visibility distances for vessels. I think that is the regulation that applies. I don't think it says anywhere that you have to use a "certified" fixture only that the light meet the requirements for color, arc, visibility distance, etc. If you change the bulb in a "certified" fixture, it may no longer be "certified" but may well meet the regulation and your boat will be in compliance. So, in my opinion, you can use a candle in a Pringles can as long as it meets the requirements for color, arc, visibility distance, etc. I wouldn't expect a Coastie to argue with you if your lights look anywhere close to bright and are the correct color and arc. Dennis C. Touche' 35-1 #83 Mandeville, LA On Fri, Aug 11, 2017 at 3:02 PM, Jim Reinardy via CnC-List <cnc-list@cnc-list.com <mailto:cnc-list@cnc-list.com> > wrote: I agree about Marinebeam, I have used them for other lights on my boat, always with good results. Aqua Signal throws up a lot of smoke and noise about losing certifications by replacing the bulbs in their fixtures, is this a real concern or just them trying to get me to spend more with them? http://www.aquasignal.com.au/aftermarket-led-replacement-bulbs/
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