FIRE DETECTION SYSTEM CERTIFICATION ON SOLAS VESSELS
Q: When is fire detection system certification per 46 CFR 27.203(g) required on an uninspected towing vessel (UTV) that holds a valid SOLAS certificate(s)?
Ans: SOLAS fire safety requirements, standards and oversight are equal to or higher than that required in 46 CFR Subchapter C. A UTV that maintains a valid SOLAS certificate certifying the vessel complies with SOLAS fire safety requirements is deemed to be in compliance the fire detection system requirements contained in 46 CFR 27.203.
Per the preamble to the interim rule which required fire detection systems on board UTVs: "The goal of the proposed rule was to ensure that a dedicated, reliable system would be installed aboard towing vessels, to provide early warning of fires." - see 64 FR 56257. At a minimum, all UTVs are required to have their fire detection system certified at least once to ensure they meet the above goal. A key point to keep in mind is, while 46 CFR 27.203(g) does require fire detection systems to be certified it is silent on the form of the certification - i.e. a letter, notation on a system plan, etc.
A UTV that only operates on domestic routes or, operates on an international route but does not maintain SOLAS certificate(s) covering SOLAS fire safety systems, would be required to have the fire detection system certified in accordance with 46 CFR 27.203(g). Fire detection system certification completed in accordance with 46 CFR 27.203(g) remains valid (no expiration) as long as the system is maintained as originally configured for certification. A fire detection system would need to be recertified if the system is modified, repaired with other than "replacement in kind" parts or the system is replaced entirely.
A UTV that operates on an international route may have to comply with SOLAS fire safety requirements, Fire Safety System Code requirements and maintain SOLAS certificates. The fire detection system on any towing vessel that maintains a SOLAS certificate must be Coast Guard approved under 46 CFR 162.002. Unlike the domestic vessels, UL listed systems are not accepted as alternatives to Coast Guard type approved systems under SOLAS. The Coast Guard or an authorized classification society (i.e. ABS) certifies a vessel meets SOLAS fire safety systems requirements by issuing a SOLAS certificate - i.e. Cargo Ship Safety Equipment Certificate. A SOLAS certificate is issued to a vessel after the Coast Guard or an authorized classification society has done an inspection of the associated system(s) and found them to be in working order and in compliance with international requirements. The vessel is also subject to annual compliance surveys between the initial issuance and renewals of the SOLAS certificate to ensure those systems covered by the SOLAS certificates are properly maintained.
FUEL SHUT-OFF VALVE REMOTE OPERATOR
Q: What type of remote operator is acceptable for the fuel shut-off valves installed on uninspected towing vessels?
Ans: The preamble to the Final Rule (see 65 FR 52043) dated 28 August, 2000 requiring fuel shut-off valve(s) on uninspected towing vessels stated the intent of the regulation was "...to require a means to stop the main supply of fuel to the engine room during a fire."
Per 46 CFR 27.207 remote fuel shut-off valve(s) are required on all fuel lines that supply an engine or generator. The valve(s) must be fitted with a remote operator to allow the crew to close the valve from a safe location in the event of an engine room fire. The regulations specify that the fuel shut-off valve(s) must be located near the source of supply such as at the day tank or fuel distribution manifold. The remote valve operator must be located outside the space were the valve is installed. The remote operator for the valve must be capable of functioning if there is a fire in the engine room. Fuel shut-off valves that can be remotely operated by reach rods, pull cables, electric, hydraulic, pneumatic or other means are acceptable as long as they can reasonably be expected to work during a fire in the space. In some cases system components such as wiring or flexible connections may require shielding or other means to ensure the valves remote operator will remain operational during a fire in the space. If a powered (electric, pneumatic, hydraulic, etc.) operator is employed there must be a means to remotely close the valve even in a deadship condition.
FIRE HOSES AND NOZZLES
Q: What fire hoses meet the definition of "lined commercial fire hose" and are appropriate for use on uninspected towing vessels?
Ans. In 46 CFR 27.301(d) and (e)(2), applicable towing vessels must be equipped with "...lined commercial fire-hose." Hoses that are considered to meet this requirement are those that meet Underwriters Laboratories (UL) Standard 19, or are constructed in accordance with National Fire Protection Association (NFPA) Standard 1961. Hoses meeting either standard still must meet the minimum diameter (1.5 inches) and length (50 feet) requirements. Other fire hoses will be considered on a case-by-case basis.
Acceptable lined hoses include single or double jacket woven cotton/polyester hose or rubber covered fire hose. Woven jacket fire hose has a single or double layer of outer woven fabric with an internal rubber lining. Rubber covered fire hose is constructed with the rubber covering integral with the weave. This hose appears homogeneous and does not have separate layers.
In addition, hoses must be equipped with nozzles made of corrosion resistant material. Brass is acceptable for any service, while anodized aluminum may be used in fresh water applications. Fittings are to meet the same material requirements.
SEMI-PORTABLE FIRE EXTINGUISHING SYSTEMS
Q: Is the B-III semi-portable fire extinguishing system listed in 46 CFR 25.30-20(2)(ii) required on an uninspected towing vessel?
Ans: The B-III is not required per 47 CFR 27.303(a) and 46 CFR 27.305(a).
46 CFR Part 27 contains the regulations for provisions of fire protection and fire suppression equipment on towing vessels.
46 CFR 27.303 states that towing vessels in inland service and towing vessels in ocean or coastal service whose construction was contracted for before August 27, 2003 must carry both the minimum number of hand portable fire extinguishers required by subpart 25.30 of this part and, by April 29, 2005, either an approved B-V semi-portable fire extinguishing system to protect the engine room or a fixed fire extinguishing system installed to protect the engine room of the vessel.
46 CFR 27.305 states that towing vessels in ocean or coastal service whose construction was contracted for on or after August 27, 2003 must carry the minimum number of hand portable fire extinguishers required by subpart 25.30 of this part, an approved B-V semi-portable fire extinguishing system to protect the engine room, and a fixed fire-extinguishing system to protect the engine room. This section does not apply to any towing vessel pushing a barge ahead, or hauling a barge alongside, when the barge's coastwise or Great Lakes route is restricted (as indicated on the certificate of inspection), so that the barge may operate in fair weather only, within 12 miles of shore, or with words of that effect.
As stated above 46 CFR 27.303(a) and 46 CFR 27.305(a)(1) refer to subpart 25.30 for the minimum number of hand portable fire extinguishers required, but do not refer to subpart 25.30 for a B-III semi-portable fire extinguishing system. 46 CFR 25.30-10(c) states that sizes I and II are hand-portable fire extinguishers. 46 CFR 25.30-10(c) states sizes III, IV, and V are semi-portable fire extinguishers.
On June 18, 2004 the final rule was published adding 46 CFR 27.303 and 46 CFR 27.305 to 46 CFR Part 27 Towing Vessel regulations. Prior to this the B-III fire extinguishing system was required.
CO2 LIQUID LEVEL INDICATOR
Q: What do I do if during an UTV examination I find out the fire suppression company used liquid level indicators rather than weighing the CO2 cylinders while conducting the annual servicing of the vessel's fixed CO2 system?
Ans: National Fire Protection Association (NFPA) standard 12 /126.96.36.199.1 states all high pressure cylinders shall be weighed. The Coast Guard and NFPA require CO2 cylinders to be weighed to verify the cylinder contains the proper amount of CO2. Using liquid level indicators is not an acceptable alternative to weighing CO2 cylinders. If you come across this situation, explain to the towing vessel representative that the Coast Guard does not recognize the use of liquid level indicators and request they have the fire suppression company weigh the CO2 cylinders at the next annual servicing.
In NFPA 12 Annex G General Information on Carbon Dioxide it states the following:
"As the temperature of the CO2 liquid increases, the pressure also increases. As the pressure increases, the density of the vapor over the liquid increases. On the other hand, the liquid expands as the temperature goes up and its density decreases. At 87.8°F (31°C), the liquid and the vapor have the same density, and of course the liquid phase disappears. This is called the critical temperature for carbon dioxide. Below the critical temperature [87.8°F (31°C)], carbon dioxide in a closed container is part liquid and part gas. Above the critical temperature, it is entirely gas."
Note: There was a Navigation and Vessel Inspection Circular (NVIC) No. 8-73 (Alternate means of determining the weight of CO2 in fire extinguishing systems) that did allow the use of liquid level indicators in lieu of weighing the CO2 cylinders however, the NVIC has been cancelled.
FIXED HALON FIREFIGHTING SYSTEMS
Q: Can Halon 1301 be used as a firefighting suppression agent on an uninspected towing vessel?
Ans: 46 CFR 27.100 defines fixed fire-extinguishing systems as:
1. A carbon-dioxide system that satisfies 46 CFR subpart 76.15 and is approved by the Commandant;
2. A manually-operated clean-agent system that satisfies the National Fire Protection Association (NFPA) Standard 2001 (incorporated by reference in Sec. 27.102) and is approved by the Commandant; or
3. A manually-operated water-mist system that satisfies NFPA Standard 750 (incorporated by reference in Sec. 27.102) and is approved by the Commandant.
While some "clean agents" are listed in the National Fire Protection Association (NFPA) Standard 2001 (incorporated by reference in Sec. 27.102) Halon 1301 is not.
The Lifesaving and Fire Safety Division's (CG-5214) website indicates that the production of Halon 1301 fire fighting agent was terminated effective January 1, 1994, and the installation of new Halon systems on SOLAS ships is prohibited. However, existing systems may be retained if in good and serviceable condition. The best reference to use for a Halon 1301 systems is NVIC 06-72 Change 1.
National Fire Protection Association (NFPA) 12A (Standard on Halon 1301 Fire Extinguishing Systems) should be used as guidance to assist with conducting inspections and maintenance on existing fixed Halon fire extinguishing systems.
HILLERSAFE FIRE DETECTION SYSTEMS
Q. What do I do if I find a Hillersafe fire detection system during a UTV examination?
Ans. See Marine Inspection Notice 06-11 HillerSafe Fire Detection Systems on Uninspected Towing Vessels
FIRE DETECTION EXCESS EQUIPMENT
Q. What fire detection systems can be considered excess equipment under Policy Letter 10-06?
Ans. The engine room fire detection system is required by 46 CFR 27.203 and therefore is not considered excess equipment under Policy Letter 10-06. However, if a vessel has additional fire detection systems in other spaces of the vessel, they may be considered excess equipment if they meet the requirements contained in paragraph 5-c of the Policy Letter.
In accordance with CG-543 Policy Letter 10-06, existing fire detection systems and equipment that are carried and designated by the operator as excess are exempt from 46 CFR 27.203 (c) through (g) provided it (the equipment) is listed by an independent testing laboratory and is designed, installed, tested, and maintained in accordance with the equipment manufacturer's recommendations and relevant NFPA standard(s).
As an example, a vessel that is fitted with the required engine room fire detection system might also have a galley fire detection system. In this case, the galley system may be considered excess if it does not meet the requirements of 46 CFR 27.203 but does fall within the guidelines set forth in CG-543 Policy Letter 10-06.
NATIONAL INSTITUTE FOR CERTIFICATION IN ENGINEERING TECHNOLOGIES (NICET) LEVEL IV, SENIOR ENGINEERING TECHNICIAN (SET)
Q. Can a NICET Level IV, SET certify a fire detection system on board an uninspected towing vessel (UTV)?
Ans: Only on a case by case basis by submitting a request for equivalency. 46 CFR 27.203(g) states that the required engine-room fire detecting system needs to be certified by a Registered Professional Engineer, or by a recognized classification society.
A person having the NICET Level IV, SET Technician Certification trained in sub-fields of Fire Alarm and/or Special Hazards Suppression Systems can be considered equivalent to a Registered Professional Engineer or classification society as required in 46 CFR 27.203(g). The UTV owner/operator must request an equivalency for the specific NICET Level IV SET Technician that the owner/operator wants to use. The owner/operator of the UTV must forward the equivalency request to the local Coast Guard office to be processed. A guide detailing how to submit an equivalency request can be found under Policy and Guidance in the Towing Vessel National Center of Expertise's website.
Once the NICET Level IV, SET Technician has been granted equivalency approval from Coast Guard COMDT (CG-5431) the Marine Inspectors and Towing Vessel Examiners should require letters attesting to the installation of fire detection systems to bear the technician's NICET certified mark. Similar to a PE, NICET certified individuals receive a certification number. Any display of the NICET Certified Mark must include the following information about the corresponding NICET-certified person:
Level and/or Grade
When the NICET Level IV, SET Technician certifies a fire detecting system, the CG issued equivalency letter and the NICET certification letter should be kept together on board the vessel or be able to be produced on demand if required by the CG.
NICET is a not-for-profit organization created by the National Society of Professional Engineers to serve the certification needs of the engineering technology community. NICET certification is a tool to measure technical knowledge and skills. This certification program was designed for engineering technicians working in the fire alarm industry who engage in a combination of the following fire alarm systems activities: system layout (plan preparation), system equipment selection, system installation, system acceptance testing, system trouble-shooting, system servicing, and system sales. Technical areas covered include applicable codes and standards, types of signaling systems, supervision requirements, types of fire and smoke detectors, building occupancy considerations, basic electricity and electronics, and physical science fundamentals.
Information on NICET Level IV qualification requirements can be found at their website.
"USCG APPROVED" AND "LISTED BY INDEPENDENT TESTING LABORATORY" FIRE DETECTION SYSTEMS
Q: What is the difference between USCG Approved and Listed by Independent Testing Laboratory with regard to fire detection systems for installation aboard UTVs?
ANS: The difference is that the fire detection systems are qualified under different processes. The Listed by Independent Testing Laboratory process is the standard shore-side process in the US. This process focuses on the individual components and devices. Each model of a device (e.g., smoke detector, horn/strobe, pull-station, and control panel) is certified by the laboratory (i.e., UL, FM, and Intertek) as meeting the current appropriate national standard as produced. The listing of the control panel along with the manufacturer's instructions will identify compatible devices to be used with that control panel. The system designer/installer must ensure that all devices being used in a system are compatible.
The USCG Approval process follows the standard maritime tradition of approving a complete system which imposes a limitation that all components or devices must be from an approved component list. These systems have met the requirements of 46 CFR 161.002 which includes additional environmental tests for suitability for ship-board installation.
UTV's are required to have either a USCG approved or Listed fire detection system and thus UTV owner/operators and Professional Engineers (PE) who certify installations of fire detection systems aboard UTVs should be aware of these nuances:
• If the fire detection system is USCG Approved then the PE should ensure that all the components are from the system's list of approved components. Any deviations from the approved list will void the approval status.
• If the device (i.e. control panel) is Listed by Independent Testing Laboratory, then the PE should ensure that each component (i.e., detector) is compatible. In addition, regulations require that each compatible detector, control panel and fire alarm must also be Listed by Independent Testing Laboratory [46 CFR 27.203(a)]
Owner/operators should also be aware that some detection systems may be USCG Approved only for a certain class of vessels, such as small passenger vessels; which would not satisfy the fire detection requirements for Uninspected Towing Vessels. However, if components of that same system were Listed by UL or others, then it would satisfy the requirements of 46 CFR 27.203(a).
For more information on CG type approval, check out CGs Life Saving & Fire Safety Division (CG-521) website.
FUEL SHUT-OFF VALVES
Q: What are the requirements for the location of the remote fuel shut-off valves?
Ans: The fuel shut off valves should be located near the source of the fuel supply. This means near the storage tank, day tank or fuel distributions manifold.
46 CFR 27.207 states that to stop the flow of fuel in the event of a break in the fuel line, you must have a positive, remote fuel-shut-off valve fitted on any fuel line that supplies fuel directly to an engine or generator. The valve must be near the source of supply (for instance, at the day tank, storage tank, or fuel-distribution manifold). Furthermore, it must be operable from a safe place outside the space where the valve is installed. Each remote valve control should be marked in clearly legible letters, at least 25 millimeters (1 inch) high, indicating the purpose of the valve and the way to operate it.
This requirement, derived from the final rule, states that any fuel line subject to internal head pressure from the fuel tank must be provided with a remotely operable fuel shut-off valve. The intent is to require a means to stop the main supply of fuel to the engine room during a fire. Coast Guard data shows that failure of fuel lines and flexible hoses are among the leading causes of fires in engine rooms on towing vessels. Fuel leaking and spraying from gravity tanks significantly increases the magnitude of these fires and makes these fires almost impossible to extinguish without outside assistance.
Only a fuel line directly supplying an engine (or generator) needs a remotely operable positive shut-off valve.
The shut-off valves should be installed as follows:
1. If you have a day tank supplying fuel, install the shut-off valve at the day tank;
2. If you have a fuel-distribution manifold only (no day tank), install the shut-off valve in the single fuel supply line after (downstream of) the manifold; or
3. If you have a fuel tank directly supplying an engine or a generator, without the use of a day tank, a storage tank, or a fuel-distribution manifold, install the shut-off valve at the fuel tank.
Fuel shut-off valves have been found located at the end of the fuel piping before the fuel hose which is connected to the engine. Sometimes these fuel shut off valves are over 30 feet away from the fuel tank. The vessel owner/operators are calling these valves engine shutdowns. The location of these engine shutdown valves does not meet the intent of 46 CFR 27.207. The vessel owner/operator may continue to use the engine shutdown valves but they must also install fuel shut-off valves at the proper locations.
During the towing vessel examination the Coast Guard examiner should verify the proper location of the fuel shut-off valves and witness the vessel's representative conducting an operational test from the remote location to verify the fuel shut-off valves close properly. A number of towing vessels have the fuel shut-off valves located in the vessel's fuel tanks. During construction of towing vessels some shipyards installed these fuel shut-off valves in the fuel tanks and installed a reach rod to open and close the valve from the main deck. The examiner should have the vessel's representative close and open the fuel shut-off valve using the reach rod to verify that the valve is functioning properly.
The regulations do not specify an allowable distance between the shutoff valve and the storage tank, day tank or fuel distribution manifold. On some towing vessels, this distance should be minimized to reduce the chances of fire damage to attached piping. If it is necessary to locate the valve away from the storage tank, day tank or fuel distribution manifold, then the owner/operator will have to demonstrate that an equivalent level of protection can be provided. 46 CFR 24.15-1 gives the Commandant the authority to accept in substitution an alternative arrangement and grant an equivalency.
An example of an equivalent protection would be to install extra-heavy schedule 80 piping with all welded connections between the shutoff valve and the fuel tank. If the towing vessel owner/operator wants to request an equivalency they should submit their request through their local Coast Guard office. Some towing vessel owners/operators have requested equivalency for their fuel valve locations and have been granted approvals. Equivalency approvals can be granted for specific vessels or a company's fleet of vessels. An approved equivalency cannot be utilized by other companies. Each towing vessel company must obtain their own equivalency approvals as outlined in 46 CFR 24.15.
PORTABLE FIRE EXTHINGUSHER APPROVALS/MARKINGS
Q. What is the policy for CO2 or Dry Chemical portable or semi-portable fire extinguishers found onboard towing vessels that have no markings or proof they meet UL or Coast Guard standards?
Ans. If the vessel representative wants to keep the extinguisher(s) in service onboard the vessel, he/she will have to prove it is UL or CG approved. If the vessel representative is unable to provide proof the extinguisher(s) is an approved type, it will need to be replaced with an approved extinguisher(s).
46 CFR 25.30-5(b) requires all hand portable and sem-iportable fire extinguishers on board UTVs to be an approved type (i.e. Coast Guard approved). Navigation and Vessel Inspection Circular (NVIC) No. 13-86 provides guidance for accepting certain UL listed extinguishers as meeting the carriage requirements for approved extinguishers for commercial vessels. Design specifications for portable fire extinguishers can be found in 46 CFR 162.028. Design specifications for semi-portable fire extinguishers can be found in 46 CFR 162.039.
Search the Coast Guard approved equipment list.
Search the UL online certification directory.
For vessels contracted for prior to November 19, 1952 see 46 CFR 25.30-90 for possible acceptance of existing equipment that have no markings or proof they meet UL or Coast Guard standards.
PORTABLE FIRE EXTINGUISHER INSPECTION/MAINTAINANCE
Q. Where can I find information on maintenance and inspections required for portable fire extinguishers?
Ans. National Fire Protection Association (NFPA) 10 Standard for Portable Fire Extinguishers.
You may obtain a copy of NFPA 10 through the National Fire Protection Association.
IAW 46 CFR 27.100(d), the owner of a towing vessel is required to test and maintain all the equipment required by this part in accordance with the attached nameplate or manufacturer's approved design manual. All USCG/UL approved portable fire extinguishers will have a statement on the label indicating the extinguisher is to be inspected and maintained IAW NFPA 10. NFPA 10 chapter 7 is guidance for inspection, maintenance, and recharging of portable fire extinguishers. NFPA 10 chapter 8 is guidance for hydrostatic testing of portable fire extinguishers.
SELF-PRIMING PORTABLE FIRE PUMP
Q. 27 CFR 27.301 (e) allows for a self-priming/power driven portable fire pump in lieu of a fixed fire-pump. What does self-priming mean?
Ans. The term self-priming means the fire pump is able to create its own suction by priming itself independently without adding water to the pump casing or the suction hose. A device attached to the pump such as an exhaust primer or hand primer that requires the operator to pull the air out of the pump or suction hose is acceptable.
Note: Some pumps that are sold as self-priming pumps might not be fitted with an exhaust primer or hand primer. This type of self-priming pump will typically have a water reservoir built into the casing that allows the pump to self prime by recirculating water within the pump when it is first started. These pumps only have self-priming capability if the pump retains priming water from the previous pumping cycle. Self-priming pumps with a water reservoir that have been stored for a long period of time, or which are used in below-freezing weather, may not be able to pump effectively if the reservoir is low on water.
Owner operators are reminded of the requirement in 46 CFR 27.100(d) to maintain all fire-fighting equipment in accordance with the manufacturer's instructions. 46 CFR 27.209(a)(1)(i) requires all crewmembers to know how to operate all of the fire-extinguishing equipment on board the vessel. 46 CFR 209(c)(2) requires breaking out emergency equipment during the monthly drill. If the manufacturer's instructions don't require a shorter interval for operational testing of the pump, at a minimum, monthly testing by vessel crewmembers is highly recommended to ensure the pump is properly maintained, is ready for immediate use in an emergency and the crew is proficient in its operation.