FIRE PROTECTION
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Fire detection and suppression systems are considered essential systems – see 46 CFR 136.110.  All deficiencies related to fire protection requirements will, in most cases, have to be resolved prior to the vessel getting underway or issuing/endorsing the Certificate of Inspection (COI).  All fire equipment or arrangement details not covered within 46 CFR Part 142 must be to the satisfaction of the cognizant Officer in Charge, Marine Inspection (OCMI).

It is critical that fire protection systems and equipment function as designed when needed.  Improper fire protection system and equipment testing can cause system/equipment degradation or complete failure, crewmember injury(s), death(s) and/or catastrophic damage to the vessel.  Testing to verify compliance should only be conducted by properly trained personnel using procedures outlined in the approved equipment manufacturer’s nameplate and/or the approved operations manual.  Inspectors and TPOs can require the vessel owners and/or operators provide notification prior to conducting any fire protection system tests so they can attend the vessel to witness the test(s).  To avoid delays in the inspection/survey process the owner/operator and the inspector/TPO should discuss which fire protection systems and equipment will need to be tested during the inspection/survey.

Some fire protection systems and equipment requirements are found in standards that have been incorporated by reference (IBR) in accordance with 46 CFR 136.112.  IBR allows Federal agencies to establish requirements using standards already published elsewhere.  This means all applicable parts of the IBR standards have the full force of regulation.  46 CFR Part 142 contains numerous sections that utilize IBR standards that come from various organizations such as the National Fire Protection Association (NFPA) and Underwriters Laboratories (UL).  The inspector or TPO should have access to, become familiar with, and use these IBR standards when and where applicable to ensure full vessel compliance.

The flowchart contained in this enclosure provides a visual high-level representation of the towing vessel fire protection equipment requirements contained in 46 CFR Part 142.  It should not be used as a standalone tool for determining vessel compliance.  Flowchart notes:

  1. The carriage requirements listed are for domestic routes.
  2. Carriage requirements will need to be adjusted if specialized or additional equipment has been required by the OCMI.

46 CFR Table 142.240 summarizes the minimum tests and inspections required for semi-portable and fixed fire-extinguishing systems.

46 CFR 142.231(a) allows the OCMI to permit existing towing vessels to continue to utilize previously installed fire extinguishers with extinguishing capacities smaller than what is required so long as they are maintained in good condition to the satisfaction of the OCMI.   All new equipment and installations must meet the applicable requirements for new vessels. 

Semi-portable extinguishers fitted with wheels must be properly secured.  

Towing vessels can carry more fire suppression equipment than the minimum carriage requirements as excess equipment provided the equipment meets the same approval standard(s) as those outlined for the required equipment and the equipment is maintained in good and serviceable condition.  Guidance on excess equipment can be found in MSM Vol. II.  

Items to check:

  • As required, vessel is equipped with a 160-B semi-portable fire-extinguishing system and/or a fixed fire extingusghing system.
  • If equipped, semi-portable fire-extinguishing systems Coast Guard approved under approval series 46 CFR 162.039.
  • If equipped, fix fire-extinguishing system approved by Commandant and meets:
  • System inspected and tested annually by a qualified person.
  • Records of inspections and tests recorded in the TVR, official logbook, in accordance the TSMS or, for a semi-portable fire-extinguishing system, on a tag attached to the unit.  Records contain the following information:
    • Dates when inspections and tests were performed.
    • The number and any other identification of each unit inspected and tested.
    • Results of the inspections and tests.
    • The name of the person(s) who conducted the inspections and tests.
  • Receipts and other records generated by inspections and tests retained for at least 1 year.

Regulatory Cites:

46 CFR 136.110 Definitions
46 CFR 142.215 Approved equipment
46 CFR 142.230 Hand-portable fire extinguishers and semi-portable fire-extinguishing systems
46 CFR 142.231 Exception for portable and semi-portable fire extinguishers required for existing vessels
46 CFR 142.240 Inspection, testing, maintenance, and records
46 CFR 142.315 Additional fire-extinguishing equipment requirements
46 CFR 147.60 Compressed Gasses
46 CFR 147.65 Carbon dioxide and halon fire extinguishing systems
46 CFR 147.67 Halocarbon fire extinguishing systems  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
NVIC 6-72 Guide to Fixed Fire-Fighting Equipment Aboard Merchant Vessels
NVIC 3-95 Periodic Inspection and Testing of Fixed Halon Fire Fighting Equipment Aboard Merchant Vessels
NVIC 9-00 Change 1 Carbon dioxide fire extinguishing system safety

Items to check:

  • At least one (1)
  • Fire axe readily accessible.
  • Located on the exterior of the vessel. 

Regulatory Cites:

46 CFR 142.227 Fire axe

It is acceptable to install additional zones on the engine room detection system control panel to cover other areas where detection is not required by the regulations.  A separate system is not needed for the protection of areas outside the engine room.  

Non-Coast Guard approved detection equipment must be listed/approved by a nationally recognized testing laboratory such as UL or FM, and installed in accordance with the manufacturers approved design manual.  The system may use heat detectors, smoke detectors, or a combination of the two.  Optical flame detectors can also be used.  

Engine room monitoring systems may be modified by a qualified technician to meet alarm or indication requirements.  

HillerSAFE Fire and Bilge Flooding Alarm systems are not acceptable as an engine room fire-detection system aboard commercial towing vessels.   

The system certifying entity must have experience in fire detection system design.  

Only manufacturer approved system control panel(s) and remote indicator panel(s) such as a control panel repeater can be used on a required fire-detection system.  Installation of any unapproved component(s) will void the system approval and certification.

Fire detection systems and equipment can be installed in other spaces as excess equipment.  Existing fire detection systems and equipment designated by the owner/operator as excess are must be 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).  

Items to check:

  • As appropriate, an installed fire-detection system or an existing engine room monitoring system with fire-detection capability to detect engine room fires. 
  • If a fire-detection system is installed, the following components are approved under approval series 161.002 or listed by a NRTL:
    • Detector(s)
    • Control panel(s)
    • Remote indicator panel(s)
    • Fire alarm
  • If an existing engine room monitoring system is installed, it uses detectors listed by a NRTL.
  • For both fire-detection systems and existing engine room monitoring systems:
    • System is installed, tested, and maintained in accordance with the manufacturer's design manual
    • System is arranged and installed so a fire in the engine room automatically sets off alarms on:
      • A fire detection control panel at the primary operating station. 
      • On a fire detection control panel or a remote indicator panel at any other operating station(s).
    • The control panel includes:
      • Power available light
      • Audible alarm
      • Visual zone indication to identify the location of the fire
      • Means to silence the audible alarm while maintaining visual alarms
      • Circuit-fault detector test-switch or internal supervision of circuit integrity
      • Function Identifying labels for all switches and indicator lights
    • System draws power from two sources.
    • System serves no other purpose, unless it is an engine room monitoring system.
    • System certified by a registered professional engineer, a NICET level IV engineering technician or an authorized classification society.

Regulatory Cites:

46 CFR 136.110 Definitions
46 CFR 142.240 Inspection, testing, maintenance, and records
46 CFR 142.330 Fire-Detection System Equipment Requirements
29 CFR 1910.7 Definition and requirements for a nationally recognized testing laboratory  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
NVIC 7-80 Use of Fire Detection Systems Which are Not Approved Under 46 CFR 161.002
NFPA 72 National Fire Alarm and Signaling Code

An improperly sized firefighter’s outfit could be physically detrimental to the wearer and reduce a crew’s ability to respond to emergencies.  Firefighter's outfits are manufactured in various sizes and one size does not fit all.  The vessels operating company and the master must consider the crew complement  and the emergency duties assigned to each crewmember to ensure appropriately sized firefighter's outfits are carried on board the vessel at all times.  This may require the company to provide a means to change out firefighter outfits when the crews compliment changes.  

Items to check:

  • Sufficient number of firefighters outfits.
  • Firefighter’s outfits meet NFPA 1971, Protective Ensemble for Structural Fire Fighting.
  • Sufficient number of self-contained breathing apparatus (SCBAs)
  • SCBAs are:
    • Approved by NIOSH, under 42 CFR part 84.
    • Have a minimum 30-minute air supply
    • Full facepiece
    • Pressure demand
    • Open circuit type 

Regulatory Cites:

42 CFR Part 84 Approval of Respiratory Protective Devices
46 CFR 136.110 Definitions
46 CFR 142.226 Firefighter’s outfit  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
NVIC 6-01 Protective Equipment Required for Firefighter’s Outfit

Small amounts of combustible and/or flammable liquids such as oil are likely to be present in the bilges of operating towing vessels.  While small amounts of combustible and/or flammable liquids in the bilges due to normal operations is acceptable, any accumulation(s) of combustible and/or flammable liquids that present a fire hazard is not acceptable and must be removed.  For further guidance see MSM Vol. II.  

Likewise, accumulations of combustible and/or flammable materials (i.e. wood, paper, cardboard, oily rags, etc.) could present a fire hazard onboard the vessel and should be minimized.  All excess combustible and/or flammable material which are not required for normal vessel operations should be removed from the vessel.  

Items to check:

  • Bilges and void spaces free from excess accumulation of combustible and flammable materials.
  • Storage areas free from excess accumulation of combustible and flammable materials.

Regulatory Cites:

46 CFR 136.110 Definitions
46 CFR 140.665 Inspection and testing required when making alterations, repairs, or other such operations involving riveting, welding, burning or like fire-producing actions
46 CFR 142.220 Fire hazards to be minimized
46 CFR 143.220 Machinery space fire prevention  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II

The master of the vessel is required to conduct monthly firefighting drills and training. The drills are intended to familiarize the crew with the location and operation of all the fire protection equipment installed onboard the vessels and what their duties are in the event of a fire.  Video training supplemented with a discussion may be used to instruct the crew, however, crew participation in actual drills is required on a monthly basis.

During drills, the master or other qualified trainer is expected to instruct the crew in the operation of all fire protection equipment installed onboard the vessel.  For example, if a fixed fire extinguishing system is installed on board the vessel, the drills must show the crewmembers how to discharge the system by the remote controls and locally at the storage cylinders. The operation of any fire protection equipment, such as breathing apparatus, that is carried onboard the vessel should be included in regularly scheduled drills.

The location of the monthly fire drills should be varied to eventually cover all areas on the vessel.  During these drills, the crew should evaluate equipment limitations or other problems that may be encountered during an actual fire in that location. The drills should also address potential problems from transporting differing cargoes, traveling differing routes, and incapacitation of key crewmembers.

Items to check:

  • Crewmembers participate in fire-fighting drills and receive instruction at least once each month. 
  • All crewmembers familiar with:
    • Fighting a fire in the engine room and elsewhere onboard the towing vessel:
      • Operation of all fire-extinguishing equipment.
      • How to stop any mechanical ventilation system for the engine room and effectively seal all natural openings to the space.
      • Operation of fuel shut-off(s) for the engine room.
    • Activating the general alarm.
    • How to report inoperative alarm systems and fire-detection systems.
    • Donning a firefighter's outfit and a self-contained breathing apparatus, if the vessel is so equipped.
  • Records of fire-fighting drills and receive instruction recorded in the TVR, official logbook or in accordance the TSMS. 

Regulatory Cites:

46 CFR 136.110 Definitions
46 CFR 140.915 Items to be recorded
46 CFR 142.245 Requirements for training crews to respond to fires  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Marine Safety Manual Volume II
NVIC 6-91 Fire Drills and On-Board Training

If a fire main supplies water for services in addition to firefighting, pump performance criteria requirements must be met while simultaneously providing the additional water.  If performance criteria of a fixed or portable fire pump(s) are suspect during an inspection or survey, see NVIC 6-72 for procedures to properly calculate fire pump capacities.

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.  Portable self-priming pumps which have a manufacturer designed/installed 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 are acceptable.  Self-priming pumps that are not fitted with an exhaust primer or hand primer will typically have a water reservoir built into the casing that allows the pump to self-prime by recirculation of water within the pump when it is started. These pumps only have self-priming capability if the pump retains priming water from the previous pumping cycle within the reservoir.  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 self-prime if the reservoir is low on water or the reservoir water is frozen.  

Objective evidence of an acceptable fire hose would be a hose that meets UL 19 or is constructed in accordance with NFPA 1961; however, fire hoses used to meet this section are not required to meet UL or NFPA standards.  Other fire hoses can be considered on a case-by-case basis.  Any lined commercial fire hose that meets size and length specifications and is in serviceable condition is acceptable.  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.  Hose fittings should be brass or other suitable corrosion-resistant materials which comply with NFPA or standards otherwise acceptable to the cognizant OCMI.  Further Guidance on fire hoses can be found in MSM Vol. II.

Objective evidence of an acceptable fire hose nozzle would be a nozzle that meets approval series 162.027 or ASTM F 1546; however, nozzles used to meet the requirements of this section are not required to meet those standards.  Other nozzles can be considered on a case-by-case basis.  Any nozzles made of corrosion-resistant material capable of providing a solid stream and a spray pattern is acceptable.  Fire hose fittings and nozzles made of brass or bronze are acceptable for any service. Anodized aluminum fittings and nozzles should only be used for fresh water service.  

Items to check:

  • If equipped with a fixed fire pump:
    • The pump must be:
      • Power driven.
      • Self-priming.
      • Capable of delivering water simultaneously from the two highest hydrants or from both branches of the fitting if the highest hydrant has a Siamese fitting at:
      • Pitot-tube pressure of at least 50 psi.
      • Flow rate of at least 80 gpm.
    • Capable of being energized remotely and at the pump.
    • All suction valves necessary for the operation of the fire main in the open position or capable of operation from the same place where the remote fire pump control is located.
    • Isolation valves marked or color coded.
    • Sufficient number of fire hydrants to allow a stream of water to reach any part of the machinery space using a single length of fire hose.
    • Hose(s) attached to fire main.
  • If equipped with a portable fire pump:
    • The pump must:
      • Power driven.
      • Self-priming.
      • Capable of delivering water of at the pump discharge at:
      • Discharge gauge pressure of at least 60 psi.
      • Flow rate of at least 80 gpm.
      • Sufficient amount of fire hose to so that a stream of water will reach any part of the vessel
      • Fire hose(s) immediately available to attach to the fire pump.
      • Pump stowed with its hose(s) and nozzle(s) outside of the machinery space.
    • Fire hoses are:
      • Lined commercial fire hose(s)
      • 50 feet in length
      • At least 1.5 inches in diameter
    • Fire nozzle(s) are:
      • Made of corrosion-resistant material
      • Capable of providing a solid stream and a spray pattern.  

Regulatory Cites:

46 CFR 136.110 Definitions
46 CFR 142.240 Inspection, testing, maintenance, and records
46 CFR 142.325 Fire pumps, fire mains, and fire hoses
46 CFR 143.250 System Isolation and marking  

Additional Guidance:

Commandant (CG-ENG-4) Lifesaving and Fire Safety Division
Equivalency Determination - Fire Pumps for Subchapter C and Subchapter M Towing Vessels
Marine Safety Manual Volume II
NVIC 6-72 Guide to Fixed Fire-Fighting Equipment Aboard Merchant Vessels

The extinguishers required by 46 CFR Table 142.230(a) and (b) should be dispersed throughout the vessel outside the engine room so they are readily available to the crew during an emergency.    

Towing vessels greater than 65 feet in length are also required to carry additional 40-B hand portable extinguishers based on the vessels brake horsepower – one per 1000 BHP up to a maximum of six.  These extinguishers should be dispersed throughout the engine room.

46 CFR 142.231(a) allows the OCMI to permit existing towing vessels to continue to utilize previously installed fire extinguishers with extinguishing capacities smaller than what is required so long as they are maintained in good condition to the satisfaction of the OCMI.   All new equipment and installations must meet the applicable requirements for new vessels.

Some vessels carry K-rated extinguishers in the galley to protect against deep fat fryer fires.  These extinguishers may be carried as excess equipment.   

Towing vessels can carry fire extinguishers above the minimum carriage requirements as excess equipment provided the equipment meets the same approval standards as those outlined for the required equipment and the equipment is maintained in good and serviceable condition.