Uninspected Passenger Vessel (UPV) Requirements

Discover the essentials for operating UPVs legally. Know about documentation, communication gear, and safety measures.

12 mins read・Jan 23, 2023
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You might assume because of the name that an Uninspected Passenger Vessel (UPV) doesn’t have any legal requirements in the United States. It’s true that an Uninspected Passenger Vessel doesn’t need to meet the same requirements as an Inspected Vessel. But, there are still legal requirements and guidelines for Uninspected Passenger Vessels.

This article will give you a brief overview of those requirements.

People on a small boat.

What is a Uninspected Passenger Vessel?

An Uninspected Passenger Vessel is a commercial vessel carrying six or fewer paying passengers, and weighing a maximum of 100 GRT. Uninspected Passenger Vessels are required to be under the direction of an USCG OUPV licensed captain.

Uninspected Passenger Vessel Documentation

A Uninspected Passenger Vessel of at least 5 net tons that engages in domestic or coastwise trade must have a Certificate of Documentation (COD). The vessel’s name must be clearly marked on a visible exterior part of the port and starboard bow and the stern. The COD for commercial vessels needs to be renewed annually.

Uninspected Passenger Vessels under 5 net tons need to be State registered and numbered. This endorsement/certificate varies from state to state, so you’ll need to check with your state.

Communication equipment

Applies to: Uninspected Passenger Vessels over 20 meters (65.6 ft) in length.

Uninspected Passenger Vessels of 20 meters and over must have at least one VHF-FM radio onboard and must be capable of transmitting and receiving on channel 22A (157.1 MHz).

When transiting any waters within a vessel traffic service (VTS) area, a second VHF-FM radio must also be onboard. Radio devices on Uninspected Passenger Vessels need to be licensed by the Federal Communications Commission (FCC). This license is valid for 10 years. When you apply, you should have a copy of FCC Form 605 as a temporary permit.

Uninspected Passenger Vessels 20+ meters in length must have a radio operator who holds a restricted radiotelephone operator permit or higher class license. Radio operator permits and licenses issued on or after 03/25/2008 are valid for the life of the holder.

Charts and Nautical Publications

As appropriate for the intended voyage, all Uninspected Passenger Vessels must carry adequate and up-to-date:  

  • Paper charts of appropriate scale to make safe navigation possible
  • “U.S. Coast Pilot” or similar publication  
  • Coast Guard light list
  • Tide tables
  • Current tables, or a river current publication issued by the U.S. Army Corps of Engineers or river authority.

As an alternative, you may substitute extracts or copies from the publication above. This information must be applicable to the area transited.

Electronic Charts and Publications Equivalency

Electronic navigational charts and e-publications are acceptable equivalents for the required Charts and Nautical Publications listed above. (NVIC 01-16 should be reviewed).

Navigation Lights and Sound Signals

Applies to: All Uninspected Passenger Vessels at anchor or underway from sunset to sunrise, or in areas of low visibility.

Inland Rules:

The operator of each Uninspected Passenger Vessel 12 meters (39.4 ft) long or more, operating in Inland Waters and Canadian Waters of the Great Lakes, needs to carry a copy of the Inland Navigation Rules.

Navigation Lights

Each Uninspected Passenger Vessel underway, greater than 12 meters (39.4 ft) require the following lights:

  • Red and green sidelights (port and starboard sides respectively) showing light from right ahead across an unbroken arc of 112.5° across the horizon.
  • One white masthead light showing light from right ahead across an unbroken arc of 225 degrees (112.5° on either side of center line) across the horizon.
  • If the Uninspected Passenger Vessel is 50 meters (164 ft) or greater in length, an additional masthead light abaft of and higher than the first masthead lights is required.
  • One white stern light placed on Uninspected Passenger Vessel's centerline showing light astern across an unbroken arc of 135° across the horizon.

Note: Uninspected Passenger Vessels 20 meters (65.6 ft) or greater in length may not place all of their masthead lights aft of their sidelights. UPVs less than 12 meters (39.4 ft) may substitute one all-around white light for the white masthead and stern lights.

Sound Signals

  • Uninspected Passenger Vessels less than 12 meters (39.4 ft) in length must have a means of making an efficient sound signal.
  • Uninspected Passenger Vessels of 12 to 20 meters (39.4-65.6 ft) in length must have a whistle and bell of at least 200mm (7.9 in) in diameter. Note: The bell isn’t required under the International Rules, but is required if the vessel operates in any area where the Inland Rules apply.
  • Uninspected Passenger Vessels of 20 meters (65.6 ft) or more in length must have a whistle and bell of at least 300mm (11.8 in) in diameter: Bells shall be of corrosion-resistant material and designed to give a clear tone. The bell doesn’t need to be mounted, but must be on board and accessible.
Vessel length audibility range table.

Garbage Pollution Prevention

Applies to: All Uninspected Passenger Vessels

General Requirements: No person may dispose of garbage into U.S. navigable waters and tributaries.

Garbage Placards: Applies to Uninspected Passenger Vessels over 26 feet in length.

Uninspected Passenger Vessels need to display at least one garbage placard. The placard must be at least 9”x4”, made of durable material, and with letters at least 1/8" high. The placard must be displayed in prominent locations so that crew and passengers can read them and notify the reader of the following:

  • Discharge of plastic or garbage mixed with plastic into any waters is prohibited.
  • Discharge of garbage is prohibited in U.S. navigable waters and in all other waters within three nautical miles (NM) of the nearest land.
  • Discharge of dunnage, lining, and packing material that floats is prohibited within 25 NM of the nearest land.
  • Other unground garbage may be discharged beyond 12 NM from the nearest land.
  • Other garbage ground to less than one inch may be discharged beyond three NM of the nearest land.
  • Violators are liable for civil penalties up to $25,000, criminal fines up to $500,000, and imprisonment for up to six years per violation.

The discharge of all garbage into the Great Lakes or their connecting or tributary waters is prohibited.

Lifesaving Equipment

Applies to: All Uninspected Passenger Vessels

All Uninspected Passenger Vessels must have at least one CG approved TYPE I PFD of a suitable size for each person on board. Kapok and fibrous glass life preservers without plastic covered pad inserts are unacceptable.

Commercial hybrid PFDs may be substituted for life preservers if:

  • It's worn when the Uninspected Passenger Vessel is underway and the intended wearer is not within an enclosed space.
  • It's used according to the PFD instructions and the owner's manual.
  • It's labeled for use aboard commercial vessels.

Each required life preserver intended to be worn must have approved Type I retroreflective material (often flexible tape with an adhesive backing) with at least 200 sq. cm. (31 sq. in.) of material on the front, at least 200 sq. cm. on the back, and, if reversible, at least 200 sq. cm. on each reversible side. The material attached on each side must be divided equally between the upper quadrants of the side and as close as possible to the shoulder area of the PFD.

Note: Additional Type II or Type III PFDs may be carried, however, they must be stowed separately and can’t be used to substitute any required Type I PFDs (i.e. one Type I for each person).

On Ocean, Coastwise, or Great Lake voyages, each required life preserver and buoyant device or vest must have a working CG approved PFD light attached to the front shoulder area.

Ring Life Buoy

Uninspected Passenger Vessels 26 feet or longer must have at least one CG approved orange or white throwable ring life buoy with a minimum outside diameter of 20 inches. Note: If on an international voyage, the ring life buoy must be orange.

Emergency Position Indicating Radio Beacon (EPIRB)

Uninspected Passenger Vessels are not required to carry EPIRBs. Although they’re not required, Uninspected Passenger Vessels are encouraged to install a float-free, automatically activated, Category 1, 406 MHz EPIRB.

Visual Distress Signals (VDS)

All Uninspected Passenger Vessels must carry three day and three night visual distress signals (VDS) while operating on Coastal Waters, Great Lakes, and Oceans. All VDS must be current (unexpired).

Any combination of signal devices, when carried in the number required, can be used to meet both day and night requirements.

For example, carrying two hand held red flares and one parachute red flare meets the day and night requirements. Three handheld orange smoke with one electric distress light meet both day and night requirements.

When a visual distress signal carried to meet these requirements requires a launcher to activate, then an approved launcher must be carried.

Distress signal devices illustration.

Miscellaneous Regulations

  • Lifesaving equipment required to be worn must be readily accessible.
  • Equipment designed to be thrown must be immediately available.
  • The lifesaving equipment must be CG approved and in serviceable condition. Although not required, if you carry an inflatable survival craft/life raft, it should be in serviceable condition with a current servicing/inspection date.

Fire Fighting Equipment

Applies to: All Uninspected Passenger Vessels

  • All hand fire extinguishers, semi portable, and fixed fire extinguishing systems shall be USCG approved or Underwriters Laboratory (UL) listed for marine use and marked as such.
  • All required portable and semi-portable fire extinguishing systems are "B" type and suitable for extinguishing fires involving flammable liquids, grease, etc.
  • All Uninspected Passenger Vessels of 65 feet in length and smaller require the minimum fire extinguishers outlined in the table below:
Fire extinguisher requirements table.

When a fixed fire-extinguishing system is installed, it must be a type approved or accepted by the Lifesaving and Fire Safety Division, commandant (CG-5214) or the Commanding Officer, U.S. Coast Guard Marine Safety Center. If the system is a carbon dioxide type, then it must be designed and installed in accordance with 46 CFR 76.15.

Fire Prevention and Suppression


  • Uninspected Passenger Vessels with permanently installed gasoline engines that aren’t open to the atmosphere must be ventilated by an exhaust blower system.
  • Each intake duct for an exhaust blower must extend to the lower one-third of the compartment, and above the normal level of accumulated bilge water.
  • Each vessel that’s required to have an exhaust blower system needs a label as close to the engine ignition switch as practicable, which says:


Natural Ventilation

Uninspected Passenger Vessels must have “natural ventilation” which means an airflow through the following compartments:

  • Any compartment that contains a permanently installed gasoline engine.
  • Any compartment that has openings between it and another compartment that requires ventilation.
  • Any compartment that contains a permanently installed fuel tank and an electrical component that is not ignition protected.
  • Any compartment that contains a non-metallic fuel tank. Natural ventilation systems must consist of supply intake ducts or openings, as well as exhaust ducts or openings.
  • Natural ventilations systems must have a supply intake opening located on the exterior surface of the Uninspected Passenger Vessel, or to another ventilated compartment, or compartment open to the atmosphere.
  • Natural ventilation systems’ exhaust ducts or openings must originate in the lower one-third of the compartment. Each supply duct and exhaust duct must originate above the normal accumulation of bilge water.
  • The minimum internal cross-sectional area of each supply intake and each exhaust duct must be determined in accordance with 33 CFR 183.610(d), but in any case the minimum cross-sectional area of each duct must exceed 3 square inches.

Heating, Lighting, & Cooking Systems

Uninspected Passenger Vessels can only use the following fuel sources for heating, lighting, and cooking systems:

  • Alcohol - solid (containers must be properly secured to a fixed base).
  • Alcohol - liquid, combustible (must have a catch pan at least ¾” deep secured inside the frame of the stove, and a ¾” upward flange around the edge of the protection pan underneath the stove).
  • Fuel oil - #1, #2, or #3 (must have a catch pan at least ¾” deep secured inside the frame of the stove, or a ¾” upward flange around the edge of the protection pan underneath the stove).
  • Kerosene - (same guidelines as for fuel oil systems).
  • Wood - (systems fitted after August 9, 1989 must be installed in accordance with guidelines of Chapter 6 of NFPA 302).
  • Charcoal - (same guidelines as for wood-burning systems).
  • Liquefied Petroleum Gas (LPG) – for cooking systems only; additional requirements apply; see following page.
  • Compressed Natural Gas (CNG) – For cooking systems only; additional requirements apply.

Safety Orientation

Applies to: All Uninspected Passenger Vessels

Before getting underway, operators of Uninspected Passenger Vessels must ensure public announcements, placards, or both are provided to passengers that address the following topics:

  • Stowage locations of life preservers.
  • Proper method of donning and adjusting life preservers carried aboard the vessel.
  • The type and location of all life-saving devices carried on the vessel.
  • The location of the Emergency Checklist.

Passenger Counts

All Uninspected Passenger Vessels must keep a correct count of all passengers received and delivered each day. The master, owner, charterer, managing operator, or person in charge of the vessel is responsible for this.

Emergency Instructions

Operators of Uninspected Passenger Vessels must ensure that an emergency checklist is posted in an obvious and accessible place on the vessel.

The emergency checklist must include the following minimum information:

1. Measures to be considered for rough weather or for crossing hazardous bars

  • All water/weather tight hatches, doors, and air ports closed to prevent taking water aboard.
  • Bilges kept dry to prevent loss of stability.
  • Passengers seated and evenly distributed.
  • All passengers wearing life preservers during rough seas or bar crossings.
  • International distress call and call to the Coast Guard over radio (if equipped) made if assistance is needed.

2. Measures to be considered in the event of man overboard:

  • Ring buoy thrown as close to person-in-the-water (PIW) as possible;
  • Lookout posted to keep PIW in sight.
  • Crew member, wearing life preserver and tending line standing by to enter the water to assist in recovery, if necessary;
  • Coast Guard and all nearby vessels notified by radiotelephone;
  • Search continued until after radiotelephone consultation with the Coast Guard (if possible).

3. Measures to be considered in the event of a fire at sea:

  • Cut off air supply to the fire by closing hatches, ports, doors, and ventilators, etc.
  • Portable fire extinguishers discharged at the base of the flames of flammable liquid or grease fires, or water applied to fires of combustible solids.
  • If fire is in machinery spaces, fuel supply and ventilation shut off, and any installed fixed firefighting system discharged.
  • Vessel maneuvered to minimize the effect of wind on the fire.
  • Coast Guard and all vessels in the vicinity notified by radiotelephone (if so equipped) of the fire, and location of the vessel.
  • Passengers moved away from the fire, wearing life preservers.

Marine Sanitation Devices

Applies to: All Uninspected Passenger Vessels with installed toilets.

General Requirements: Type I, II, or III Marine Sanitation Devices (MSD) are required. They include any equipment for installation on board a vessel that is designed to receive, retain, treat, or discharge sewage, and any process to treat such sewage.

Type I MSD means a device that produces an effluence (discharge) having a fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible solids.

Type II MSD means a device that produces an effluence having a fecal coliform bacteria count not greater than 200 per 100 milliliters and suspended solids not greater than 150 milligrams per liter.  

Type III MSD means a device that is designed to prevent the overboard discharge of treated or untreated sewage or waste derived from sewage. Holding tanks can be discharged over the side no closer than three nautical miles from land.

Oil Pollution prevention

Applies to: All Uninspected Passenger Vessels operating on the navigable waters of the U.S.

No person may intentionally drain oil or hazardous materials from any source into the bilge. No person may operate a U.S. non-oceangoing Uninspected Passenger Vessel in U.S. navigable waters unless it can retain on board all oily mixtures and is equipped to discharge the oily mixtures to a reception facility.

Bilge Slops Retention Oceangoing Uninspected Passenger Vessels shall have the capacity to retain all oily mixtures on board and be equipped to discharge these to a reception facility, or be equipped with a Coast Guard approved oily-water separator. An oily residue tank is not required on these UPVs.

Non-oceangoing Uninspected Passenger Vessels may not be operated in U.S. navigable waters, unless they can retain on board all oily mixtures, and are equipped to discharge these oily mixtures to a reception facility. UPVs may retain oily mixtures in the bilges; an oily residue (sludge) tank is not required.

Optional items

Federal Law or Regulations don’t require the following items. However these can contribute significantly to the safety of the passengers and crew aboard the Uninspected Passenger Vessel.

Safety Training Program

A Uninspected Passenger Vessel should have a safety-training program for all crew members on emergency procedures and safety equipment use. This program ought to include record keeping showing that drills and training are conducted regularly.

The following emergencies should be covered in the training:

  • Fire
  • Flooding
  • Man overboard
  • Abandon Ship
  • Emergency Distress Communications (MAYDAY)
  • CPR and First Aid

Bilge Pump and Alarm

A Uninspected Passenger Vessel should have a properly installed bilge pump and bilge alarm. Note: Some vessels are designed without a bilge, or have suitable reserve buoyancy to float the vessel in a totally swamped condition, and will not need the bilge pump and alarm.

Backup Emergency Communications

A Uninspected Passenger Vessel should have some emergency communications capability that doesn’t depend on the normal onboard power system, and is located away from the normal power source for the vessel. A radio powered by a separate battery, a handheld VHF FM radio with 5+ watts of power, or a portable satellite phone can be used.

You can review the full Uninspected Passenger Vessel Guidebook here.

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About the author

Sam Mckay
Sam Mckay
NOAA Corps Veteran

Sam Mckay is a NOAA Corps Veteran working on his PhD in Nuclear Fusion

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