APPROVAL GUIDANCE & INFORMATION:
U.S. Coast Guard regulations require the installation of U.S. Coast Guard approved fixed gaseous extinguishing systems on certain U.S. registered inspected vessels and permit the substitution of an approved system for one of the required approved portable fire extinguisher on pleasure craft.
In order to obtain a certificate of approval (i.e. type approval), compliance with the following criteria is required. These criteria determine the equivalency of new clean agent systems to the carbon dioxide systems currently specified in the various vessel regulations, and to the halon systems previously approved as equivalent to carbon dioxide systems. This updates and supplements the test program outlined in our Notice of Proposed Rulemaking published in the Federal Register on Wednesday, January 9, 1991, pages 829 through 836, to enable inclusion of clean agent replacements for halons.
1) Approvals are issued only for complete systems made up of specific components and utilizing specific extinguishing agents. Approval is not issued for individual system components, such as individual hardware or extinguishing agents. The Coast Guard does not test materials or systems for approval but rather specifies the required test methods and minimum performance criteria for approval. Product testing must be performed by a Coast Guard Accepted Independent Laboratory.
2) The extinguishing agent must be acceptable to the U.S. Environmental Protection Agency (EPA) under the Significant New Alternatives Policy (SNAP list) without restrictions that limit its use in marine applications.
3) The agent must be recognized as a fire extinguishing medium by NFPA Standard #2001 on Clean Agent Fire Extinguishing Systems.
4) Systems must be listed and labeled for marine use by an independent testing laboratory accepted by the Coast Guard under 46 CFR 159.010. Laboratories currently so accepted are FM and UL. All tests must be conducted under the control of the laboratory. To be acceptable, the laboratory must apply and be accepted in accordance with 46CFR 159.010 prior to conducting any tests. A laboratory must demonstrate independence and technical expertise in the evaluation of the fire suppression systems in accordance with the latter regulation.
5) Systems must be intended for installation in spaces that are normally unoccupied, and that personnel can leave within 10 seconds after the system is actuated.
6) Systems are approved based on fire tests in simulated compartments of pre-determined size, and are not designed individually for each engine compartment.
7) The primary system actuator must be automatic if the agent cylinder is installed in the protected space.
8) Systems must have discharge indicators for installation at each helmsman’s position.
9) System components must meet UL 2166 “Standard for Halocarbon clean agent Extinguishing System Units.”
10) System must be intended for the protection against Class B hazards (flammable liquids) in machinery and bilge spaces, and Class C hazards (non-shock hazard when applied to energized electrical equipment).
11) Systems intended for installation in small passenger vessel (46 CFR Subchapters T and K) must have manual (mechanical) back-up actuators, audible alarms, and automatic engine and ventilation shutdown upon system discharge. The engine shutdown feature must have a mechanism to quickly restart the engine(s).
12) Systems using fusible elements for actuation are limited to installation in spaces not exceeding 2000 cubic feet. Systems for larger unoccupied spaces or any spaces intended for human occupancy must be specifically designed for each space protected, i. e. engineered, and must provide personnel safeguards such as limits on the agent concentration, discharge delays, and pre-discharge alarms.
13) Systems for fishing industry vessels are limited to spaces not exceeding a volume of 1200 cubic feet.
14) The volume of the compartment protected must be the gross volume: the length times the width times the depth of the compartment. The volume of installed equipment such as engine blocks and fuel tanks may not be deducted, unless the boat manufacturer provides a factory installed placard that states the volume of the installed tanks and engine blocks.
15) Systems must be self-contained, i.e. not require an external source of power such as the boat’s electrical system for activation.
16) Systems must be intended for installation in engine compartments where natural ventilation does not exceed one air change per minute. If mechanical ventilation is provided or if the natural ventilation is expected to be greater, a system tested under the higher air flow conditions must be installed.
17) Systems containing a charge of nitrogen in addition to the extinguishing agent must have a listed pressure gage. This gage is not a substitute for the required discharge indicator.
18) Systems intended for installation in volumes of 1000 cubic feet and larger must have a manual back-up actuator.
19) The system must be tested by the independent lab as follows:
a. Discharge tests per section 23 of UL2166.
b. Valve leakage tests per section 24 of UL2166.
c. Hydrostatic tests per section 25 of UL2166.
d. 30-day elevated temperature test per section 26 of UL2166.
e. Temperature cycling test per section 27 of UL2166.
f. Salt-spray corrosion tests per section 28 of UL2166.
g. 500 cycle operation tests per section 29 of UL2166.
h. One-Year leakage test per section 32 of UL 2166.
i. Mounting device test per section 33 of UL2166.
j. Manual actuator test per section 41 of UL 2166.
k. Tests of pressure gages and indicators per sections 44 through 49 UL2166.
l. Tests of elastomeric parts per section 51 of UL 2166.
m. Pressure relief test per section 53 of UL2166.
n. Nameplate exposure, adhesion and abrasion tests per sections 54 through 56 of UL2199.
o. Marine tests per Supplement SA of UL 2166, including salt-spray corrosion, vibration resistance, and shock resistance tests.
20) Fire tests must be conducted in accordance with UL 2166. For systems without piping the fire tests of section 36 of UL 2166 must be conducted. The test must be repeated at the system manufacturer’s design concentration and under conditions of one air change per minute for the test enclosure.
21) For the latter the test compartment must be ventilated at one air change per minute. Systems not incorporating an automatic engine shutdown feature must have placards for attaching to each helmsman’s position stating that the engine(s), generator, and any powered ventilation must be manually shutdown upon system activation.
22) Each system must have an owner’s instruction manual containing installation and maintenance instructions. Systems for pleasure craft are generally intended to be installed by the boat owner. Systems for inspected vessels are more complex since they require engine shutdowns, and are to be installed by system distributors or marine electricians. The owners manual must be specific to marine applications and must include the following:
a. Maximum gross volume limitations and maximum engine room/bilge dimensions.
b. Storage temperature range.
c. Coast Guard approval number.
d. Rated temperature of fusible link actuator.
e. Whether cylinders are refillable or nonrefillable.
g. Instructions on the safe disposal of the extinguishing agent.
h. Instructions on the periodic hydrostatic testing requirements for the agent cylinder if
i. A statement that only one system may be installed in each protected volume, unless each system is individually rated to protect the space.
j. General maintenance instructions.
Please submit the following information in the Submittal Package:
- A cover letter requesting Coast Guard Type Approval of the equipment.
- A test report from the independent laboratory showing compliance of the product or equipment with UL2166.
- Evidence that an acceptable follow-up factory inspection program is in place in each factory location. This could be demonstrated by providing an original copy of the contract for a follow-up program between the manufacturer and the Accepted Independent Laboratory. The follow-up program must show that no unauthorized changes can be made to the equipment without proper review and approval by the Accepted Independent Laboratory.
- An installation and maintenance manual as per paragraph number 23 of this section.