imo fp 56 - lloyd's register fp 56 agenda preview ... products having a similar fire hazards as...

IMO FP 56 Agenda preview (Overview) ©Lloyd’s Register 2012

1

IMO FP 56 Agenda preview – External Version

Introduction

The 56th session of the IMO Sub-Committee on the Fire Protection will be held from 7 to 11 January 2013, at the IMO headquarters in London. This briefing summarises subjects under discussion which are relevant to the work of Lloyd's Register. Due attention should be made to the “Advice” and “Applicability” sections given under each annex. Readers should note that regulations relating to SOLAS are generally, unless expressly provided otherwise in each Annex, applicable to ships (cargo ships of 500 gross tonnage and above, and passenger ships irrespective of tonnage) engaged on international voyages. Any reference to tankers means tankers carrying crude oil or petroleum products having a flash point not exceeding 60 degree Celsius (closed cup test) or other liquid products having a similar fire hazards as per SOLAS II-2/1.6. Note: Lloyd's Register internal only information is given in pink through the whole document.

Overview of agenda items

The following will be the major topics for the discussion at FP 56. Some of the details of discussions are given in the annexes to this document. Development of measures to prevent explosions on oil and chemical tankers transporting low-flashpoint cargoes (Agenda item 3) FP 56 will consider the draft amendments to SOLAS regulations II-2/16 and FSS Code Chapter 15 which proposes Inert Gas Systems to be used on new oil and chemical tankers (8,000 to 20,000 dwt), constructed (keel laid) on or after 1 January 2015. The draft SOLAS regulation clarify the operational objectives of the inert gas systems and sequence of applying the inerting medium in to the cargo tanks. The existing requirements in Chapter 15 of FSS code and resolution A.567(14) have been merged in to new draft Chapter 15 of FSS Code.

For details, refer to Annex 1 to this document

Development of requirements for the fire resistance of ventilation ducts (Agenda item 4) FP 56 will consider proposals in the report of the Correspondence Group, established at FP 55: Some of them include

1. Ducts serving more than one 'tweendeck space to be fitted with smoke dampers near the penetration of each deck.

2. In cargo ships and passenger ships carrying not more than 36 passengers, galley ducts which pass through accommodation spaces or spaces containing combustible material to be equipped with automatic and remotely operated fire dampers at their lower ends and remotely operated fire dampers at their upper ends, similar to the requirements for passenger ships carrying more than 36 passengers.

3. The proposal to allow smoke management systems onboard was generally accepted, which would use the ventilation ducts to manage smoke, provided that all required fire and smoke dampers will close automatically and independently in a fire. However, it was noted that the safety objectives, functional requirements and performance standards for smoke management systems for use on cargo and passenger ships are not clear at present and would need further development.

For details, refer to Annex 2 to this document.


2

Review of protection requirements for on-deck cargo areas (Agenda item 5) FP 56 will consider amendments proposed to SOLAS regulation II-2/1 and II-2/10 as well as draft MSC Circular which details the criteria for the design, performance, testing and approval of mobile water monitors used for the protection of on-deck cargo areas of containerships or ships carrying more than four tiers of containers on the weather deck. The report proposes that the draft amendments as well as guidelines for the performance standards should only be applicable to new containerships or ships carrying more than four tiers of containers on the weather deck, however these requirements could be extended to existing ships at a later stage when sufficient experience has been gained. For details, refer to Annex 3 to this document.

Review of the recommendations on evacuation analysis for new and existing passenger ships (Agenda item 6) Proposals FP 56 will consider the proposals to further improve the existing recommendations in MSC.1/Circ. 1238 for the evacuation analysis for new and existing passenger ships. It is suggested that guidelines are further amended to

- require a geometry which allows for a flexible exchange of persons between assembly stations, with the objective to prevent uncontrollable "horizontal" flow between main vertical zones.

- to develop embarkation process which works with minimal crew involvement - to store lifejackets nearby or close to assembly stations in order to improve the assembly process. - to explicitly forbid the counter flow as well as crossing flows of evacuation routes by crew or passengers

to prevent congestions - not to separate passenger flows through the same room and to prevent egress routes passing through

assembly stations, since dividing flows would require intensive influence by the crew and flows leading through e.g. assembly stations most certainly lead to significant congestions.

- take into account public spaces on open decks when dimensioning egress routes and performing evacuation analyses.

For details, refer to Annex 4 to this document.

Development of requirements for additional means of escape from machinery spaces (Agenda item 7) FP 56 will consider proposed amendments to SOLAS regulations II-2/13.4.1 and 13.4.2, for ensuring effective means of escape from engine control rooms and other enclosed working spaces located within machinery spaces in both cargo and passenger ships with the aim to provide the same level of fire protection to the personnel onboard passenger and cargo ships. It is proposed that minimum two means of escape shall be provided from the main workshop within a machinery space. At least one of these escape routes shall provide a continuous fire shelter to a safe position outside the machinery space. In addition, improved access to the normal exit and emergency escape routes, with the provision that all inclined ladders or stairways with open treads, not located within a protected enclosure, are to be of steel and protected against heat and flame by steel shields attached to their undersides. For details, refer to Annex 5 to this document.

Development of requirements for ships carrying hydrogen and compressed and natural gas vehicles (Agenda item 8) FP 56 will consider proposed arrangements to SOLAS Chapter II-2 to include requirements for ships carrying motor vehicles which uses hydrogen and compressed natural gas for their propulsion. Noting the concerns at FP 55 on whether the requirements should apply to cargo spaces on board ships irrespective of their type, it is now proposed that the subject draft amendments shall only apply to ‘pure car carriers’ and for this purpose a


3

definition for ‘Ro-ro cargo ship (vehicle carrier)’ as for a pure car carrier, taken from MARPOL Annex VI regulation 2.33 ("Ro-ro cargo ship (vehicle carrier)") (MEPC.203(62)) is included for consideration by the sub-committee. For details, please refer to Annex 6 to this document.

Consideration of IACS unified interpretations (Agenda item 9) Various IACS Unified Interpretations are submitted for consideration as Maritime Safety Committee (MSC) circulars, at this session. FP 56 should clarify the date of application of the MSC circulars to be agreed under this item.

For details, please refer to Annex 7 to this document.

Harmonization of the requirements for the location of entrances, air inlets and openings in the superstructures of tankers (Agenda item 10) FP 56 will be invited to consider FP 56/10, which presents a comparative study of the requirements for the location of entrances, air inlets and openings in the superstructures of tankers as given in various IMO instruments as well as in other international standards, with respect to the ignition of flammable gases or vapours in cargo that can enter through various openings in ship superstructures and will consider options to harmonise these requirements. It is pointed out that while SOLAS, based on IEC standards, specifies hazardous zones to determine the appropriate rating for electrical installations to be used in such spaces, however SOLAS requirements regarding the location of superstructure openings do not necessarily comply with the above hazardous zones criteria, and this inconsistency causes problems for the uniform implementation of safety measures. For details, please refer to Annex 8 to this document.

Development of unified interpretations for chapter 7 of the 2000 HSC Code (Agenda item 11) FP56 will consider the issue of developing unified interpretations for chapter 7 (Fire Safety) of the 2000 HSC Code as amended by resolutions MSC.175 (79) and MSC.222 (82). The paragraphs being addressed are paragraphs 7.4.1.3 and 7.4.1.4, related to fire-restricting materials. Most of the enclosed spaces on a high-speed craft are fire category C (areas of minor fire hazard). It is, in general, recognized that public spaces, kiosks, shops, crew accommodation and similar spaces shall be protected by fire-restricting materials. It is also proposed that technical spaces (auxiliary machinery spaces, as per paragraph 1.4.6 of the HSC Code) should comply with paragraph 7.4.1.3 of the HSC Code. Therefore, mainly the hull spaces (voids, tank compartments, etc.) are the areas that need to be addressed. For details, please refer to Annex 9 to this document.

Development of guidelines for use of fibre reinforced plastic (FRP) within ship structures (Agenda item 12) FP 56 will continue the discussions on the use of fibre reinforced plastic (FRP) within ship structures, based on submissions from Sweden (FP 56/12), China (FP 56/12/2) and the United States (FP 56/12/1). The papers from Sweden and China provide empirical data based on research and some sample fire tests of FRP bulkheads and decks and they propose to use such data as the basis for developing guidance for the approval of FRP structures, including fire testing of FRP materials. China clarifies that they support Option 1, as proposed by the United Kingdom in document FP 55/19, i.e. development of guidelines for the application of SOLAS regulation II-2/17 for evaluating FRP structures, rather than option 2, which calls for the development of a prescriptive regulatory frame work for the approval of such structures.


4

The United States vehemently opposes the Swedish, Chinese and UK proposals on the grounds that the use of such combustible materials as part of the ship structure would not meet the functional objectives of SOLAS Chapter II-2. For details, please refer to Annex 10 to this document.

Analysis of fire casualty records (Agenda item 13) FP 56 will consider a report on the casualty analysis of a fire on a vehicle deck of the RoPax vessel Lisco Gloria and appropriate evacuation measures taken, which enabled the safe rescue of all 235 persons onboard. The report notes that crew's education, training and awareness of the consequences of fire on board are essential for effective fire-fighting or evacuation of a ship. In this case, the immediate decision of the master to evacuate the ship, shortly after the fire broke out and noting the functional failure of the drencher (sprinkler) system and the difficulty for fire fighting teams to fight the fire, was critical in saving the lives of the passengers and crew. For details, please refer to Annex 11 to this document.

Development of amendments to SOLAS chapter II-2, the FTP Code and MSC/Circ.1120 to clarify the requirements for plastic pipes on ships (Agenda item 14) Denmark raises concerns on the use of plastic pipes for systems that are not normally filled with water, such as sanitary systems and describes a fire scenario in a vertically mounted plastic pipe penetrating several decks. They state that while the expanding sleeve of plastic pipe penetrations may be able to prevent the spread of flame and smoke upwards, the sleeves on the floor may not expand and close, allowing melting plastic to drop to the lower decks causing ignition. In light of the above, they propose that FP 56 should consider whether fire endurance requirements for plastic pipes should be introduced and whether existing FTP Code requirements are adequate to prevent the spread of fire downwards. For details, please refer to Annex 12 to this document.

Consideration of amendments to SOLAS chapter II-2 on location of EEBDs (Agenda item 15) FP 56 will consider proposals from United Kingdom (FP 56/15) to amend SOLAS regulation II-2/13.3.4 to state that the emergency escape breathing devices (EEBDs) for use within accommodation spaces shall be stored adjacent to the location of fire-fighters’ outfits, in fire lockers. United Kingdom is of the view that the EEBDs should be stored in a location which is readily accessible to everyone, so that they could also be taken to the trapped personnel by the rescue party, to ensure their safe escape from a hazardous atmosphere. This is current practice, especially in ships (normally in cargo ships) where only the minimum two EEBDs are used.


Development of amendments to the requirements for foam- type fire extinguishers in SOLAS regulation II-2/10.5 (Agenda item 16) FP 56 will consider the proposal from China (FP 56/16) to delete the requirement under SOLAS regulation II-2/10.5 for a 135ltr extinguisher to be used in boiler rooms. The proposal is supported by fire test data provided (FP 56/INF.6) which indicates that such extinguishers are ineffective on a spray fire that might occur in such spaces, and also point out the operational difficulties involved in fighting a pool fire with such extinguishers. It is also proposed that an approved type of fixed water-based local application fire extinguishing system which is required to be installed in machinery spaces of category A containing boilers as per SOLAS regulation II-2/10.5.6 will provide sufficient fire protection and can fully replace a 135 l foam-type fire extinguisher.


5


Development of amendments to SOLAS regulation II-2/20 and associated guidance on air quality management for ventilation of closed vehicle spaces, closed ro-ro and special category spaces (Agenda item 17) FP 56 will consider proposals from Denmark and the Netherlands (FP 56/17) to amend regulation SOLAS regulation II-2/20.3 to allow the use of an air quality management system as an optional measure to regulate the air flow in closed vehicle spaces, closed ro-ro spaces and special category spaces. The document also proposes amendments to MSC/Circ.729 “Guidelines for the design of ventilation systems in ro-ro cargo spaces” in order to accommodate the requirements of regulation 20.3 of SOLAS chapter II-2. It is proposed that the provision of an air quality management system will reduce emissions from auxiliary machinery, reduce air and noise pollution and also bring a lot of cost savings. The proposals are supported by the data presented in FP 56/INF.2. For details, please refer to Annex 15 to this document.

Any other business (Agenda item 20) FP 56 will consider several fire and safety related items under this agenda item. Some of the major discussion points are described in Annex 16 of this document. For details, please refer to Annex 16 to this document.

Review of general cargo ship safety (Agenda item 21) Following the instruction of MSC 90 (MSC 90/28, paragraph 25.10), the FP 56 Sub-Committee will be invited to consider (RCO) risk control option 28 (measure to prevent fire and explosion accident caused by inadequate repair and maintenance procedures and work during harbour stays) on its feasibility and how to realize them (MSC 90/WP.7, paragraph 20 and annex 4). However, no formal submissions have been made in relation to this agenda item as of 19 December 2012. For details, please refer to Annex 17 to this document. Annex 18 - Development of interpretation of SOLAS regulation II-2/13.6 on means of escape from ro-ro spaces (Agenda item 22) FP 56 will consider the draft interpretation of SOLAS regulation II-2/13.6 on Means of escape from ro-ro spaces as proposed by Sweden (FP 56/22) and supported by data provided in FP 56/INF.8 (Republic of Korea). It is proposed that ro-ro spaces should be considered as a place where crew are normally employed and therefore such spaces should be fitted with at least two means of escape located at the fore and aft ends of the space providing continuous fire shelter (this being defined as a protected internal route with fire integrity and insulation values equivalent to stairway enclosures) to the lifeboat, liferaft and marine escape system embarkation decks. For details, please refer to Annex 18 to this document.

IMO FP 56 Agenda preview ©Lloyd’s Register 2012

6

Annex 1 - Development of measures to prevent explosions on oil and chemical tankers transporting low-flashpoint cargoes (Agenda item 3)

Overview

FP 56 will consider the draft amendments to SOLAS regulations II-2/16 and FSS Code Chapter 15 which proposes Inert Gas Systems to be used on new oil and chemical tankers (8,000 to 20,000 dwt), constructed (keel laid) on or after 1 January 2015. The draft SOLAS regulation clarify the operational objectives of the inert gas systems and sequence of applying the inerting medium in to the cargo tanks. The existing requirements in Chapter 15 of FSS code and resolution A.567(14) have been merged in to new draft Chapter 15 of FSS Code. Possible discussion points on this item include:

• Review of products requiring oxygen dependent inhibitors. • requirements for nitrogen based inert gas systems • definitions on terminologies such as purging, gas-freeing, off-specification inert gas, inert gas main etc • agreement on the locations of IGS components onboard • whether 3000m3 should be the threshold size limit for cargo tanks for inerting.

In addition to the above, the Sub-committee will also be requested to reconsider the proposed amendments to regulation II-2/4.5.5 as presented in FP 55/WP.6, to clarify whether these amendments are applicable to gas carriers, noting that the original work programme in FP 54 was to define a new lower size limit for new oil and chemical tankers to which the requirement of fitting inert gas systems (IGS) would apply, but it was not intended to be applicable for gas carriers.

Background

Currently, tankers of less than 20,000 dwt are not required to be fitted with a fixed Inert Gas System (IGS). Following several casualty reports on the explosion of tankers, IMO has been addressing this issue since MSC 83 (October 2007). At FP 53 (April 2010) it was agreed that new oil tankers of below 20,000 tonnes dwt carrying low-flash point cargoes should be fitted with IGS. The lower dwt limit for the application of such requirements was left for further discussion. It was recognizing that a lower limit could be introduced by modifying provisions in SOLAS regulation II-2/4.5.5. FP 53 also agreed to develop requirements for the installation of inert gas systems on new chemical tankers; however, since chemical tankers present more operational complexity than oil tankers, separate requirements may need to be developed to cover them by means of amending SOLAS regulation II-2/4.5.5.2. FP55 prepared draft amendments to SOLAS II-2/4.5.5 and agreed a lower application limit of 8,000 (dwt) applicable to new oil and chemical tankers carrying low flash point cargoes, constructed (keel laid) on or after 1 January 2015. Nitrogen was agreed as the only medium to be used for inerting cargoes on chemical tankers. Draft SOLAS amendments were prepared to allow the use of equivalent systems in lieu of fixed inert gas systems installations on tankers between 8,000 dwt and 20,000 dwt. For chemical tankers, inert gas system in compliance with the Fire Safety Systems Code may be replaced by other requirements currently been developed by IMO (Guidelines). FP 55 agreed that inerting of cargo tanks after loading was an operational matter. The draft amendments are going to be finalised at FP 56. These requirements will apply to new oil and chemical tankers, carrying low flash point cargoes, constructed on or after 1 January 2015.

Lloyd’s Register’s position

Lloyd's Register is monitoring the progress on this item, specifically, SOLAS amendments to Chapter II-2/4.5.5 and the IBC Code. The following issues should also be clarified:


7

• There should be further clarity on whether the requirements will apply to gas carriers as this was outside the remit of the working group and there is a submission from SIGTTO suggesting that the inerting requirements are not applicable to gas carriers- noting that the original work programme in FP 54 was to define a new lower size limit for new oil and chemical tankers to which the requirement of fitting inert gas systems (IGS) would apply, but it was not intended to be applicable for gas carriers.

• For small chemical tankers, nitrogen cylinders were accepted, instead of having an inert gas system onboard. Needs clarification if this is the case.

• There should be further clarity on whether the requirements are intended to apply for new ships only and in that case the measures for ensuring safety of existing tankers should be discussed.

Advices to clients

Builders/ designers/ manufacturers The requirement will impact the design and operation of small oil and chemical tankers Owners/managers should take into account that IMO has developed separate guidelines on tank entry for tankers using nitrogen as an inerting medium (MSC.1/Circ.1401) which gives specific procedures and minimum precautions to be followed when persons enter a tank that has contained Nitrogen. This new guidance also includes the format of a tank entry permit for use when entering tanks. It is intended that this guidance is to be used in conjunction with the revised recommendations for entering enclosed spaces aboard ships adopted as Assembly resolution A.27/Res.1050. Ships which use Nitrogen as an inerting medium and ships where Nitrogen may be present in tanks should review their tank entry procedures to take account of the new recommendations. Owners & operators Significant impact due to the costs involved for providing suitable type of inert gas systems (IGS) onboard, depending on the type of vessel. In addition, the new requirements could possibly result in extended port-stay periods.

Applicability

The lower limit was set to 8,000 dwt for new oil tankers and chemical tankers carrying low-flash point cargoes constructed on or after 1 January 2015.

Documents submitted

FP 56/3 (United States) - Report of the Correspondence Group This document provides the report of the Correspondence Group on development of measures to prevent explosions on oil and chemical tankers transporting low-flashpoint cargoes. FP 56 is requested to :

.1 agree, in principle, to the amendments to chapter 15 of the FSS Code as set out in annex 1, with a view to finalization at FP 56;

.2 concur with the group's view that the draft amendments to SOLAS regulation II-2/4.5.5.2, agreed at the previous session, should be reviewed in light of the group's work;

.3 consider and decide as appropriate regarding the applicability of the draft amendments to SOLAS regulation II-2/4.5.5 to new gas carriers;

.4 agree that the operational requirements for inert gas systems should be located in SOLAS regulation II-2/16.3;

.5 agree to the amendments to SOLAS regulation II-2/16.3, as set out in annex 3, for submission to the Committee with a view to subsequent approval and adoption; and

.6 consider establishment of a working group at FP 56 to complete work on the remaining issues listed in paragraph 12.

FP 56/3/1 (France)- Overlap between MSC/Circ.677 and ISO Standard 16852


8

This document concerns the overlap between two standards relating to flame arresters: the IMO standard that appears in MSC/Circ.677, "Revised standards for the design, testing and locating of devices to prevent the passage of flame into cargo tanks in tankers" and ISO Standard 16852, "Flame arresters – Performance requirements, test methods and limits for use". In order to take into account the latest advances in the field, France proposes to amend these two standards and also ISO Standard 15364: 2000, "Ships and marine technology – Pressure/vacuum valves for cargo tanks", which is linked to them. FP 56/3/2 (Society of International Gas Tanker and Terminal Operators-SIGTTO ) This document comments on the report of the Correspondence Group set out in FP 56/3. In particular this document proposes to reconsider the draft amendments to SOLAS regulation II-2/4.5.5, already agreed by the FP 55 sub-committee and as set out in Annex 1 of FP 55/WP.6 as well as proposed text for regulation II-2/16.3.3.2, as set out in Annex 3 of document FP 56/3, with a view to clarify that these amendments do not apply to gas carriers.

Return to overall summary at the start of document


9

Annex 2 - Development of requirements for the fire resistance of ventilation ducts (Agenda item 4)

Overview

FP 56 will consider the following proposals in the report of the Correspondence Group, established at FP 55:

1. Ducts serving more than one 'tweendeck space to be fitted with smoke dampers near the penetration of each deck.

2. In cargo ships and passenger ships carrying not more than 36 passengers, galley ducts which pass through accommodation spaces or spaces containing combustible material to be equipped with automatic and remotely operated fire dampers at their lower ends and remotely operated fire dampers at their upper ends, similar to the requirements for passenger ships carrying more than 36 passengers.

3. The proposal to allow smoke management systems onboard was generally accepted, which would use the ventilation ducts to manage smoke, provided that all required fire and smoke dampers will close automatically and independently in a fire. However, it was noted that the safety objectives, functional requirements and performance standards for smoke management systems for use on cargo and passenger ships are not clear at present and would need further development.

4. The requirements for the remote operation of fire dampers located in galley and main laundry ducts in passenger ships carrying more than 36 passengers to be retained. However, a new proposal for the remote operation of fire dampers fitted in the galley ducts in cargo ships and passenger ships carrying not more than 36 passengers, will be considered at FP 56.

5. Proposal to prohibit the splitting of the ducts exceeding 0.075m2 at the penetration of A Class divisions 6. The correspondence group generally concurred with the view of the FP 55 Sub-Committee that the

threshold size of ventilation ducts where fire dampers are required to be fitted should remain at 0.075m2.

7. New proposed draft SOLAS regulation II-2/9.7 which incorporates unified interpretations given in MSC/Circ.1120, MSC/Circ.1169, MSC.1/Circ.1239 and Corr.1, and MSC.1/Circ.1276 and other revisions will be considered.

Matters arising from the correspondence group report which needs further discussions at the FP 56 include:

1. Development of safety objectives, functional requirements and performance standards for the smoke management systems for cargo and passenger ships

2. The requirement in MSC.1/Circ.1239 which asks for direct routeing of ventilation ducts serving engine-rooms needs further clarification.

Background

FP 55 discussed the proposed amendments to SOLAS regulation II-2/9.7 (ventilation systems), and recognised that they were introducing a number of substantial changes to the requirements for passenger and cargo ship. Some of the changes appeared not to have technical justification or compelling need, whilst in other cases the lack of clarity was a concern. FP decided not to approve the amendments due to the number of issues raised. Regarding the proposal to reduce the threshold size of ventilation ducts from 0.075 m2 to 0.02 m2, FP 55 agreed that the size should remain at 0.075 m2, until clear evidence is provided to support the changes. FP 56 will continue discussions.


Lloyd’s Register generally supports the proposals, which re-organise the existing relevant SOLAS text and consolidate in it a number of long-standing existing IMO and IACS Unified Interpretations (LR as IACS representative actively participated in the Correspondence Group, and most if not all IACS suggestion and recommendations were favourably regarded and incorporated in the proposed amendments).


10

As mentioned above, requirements are now being introduced, as previously available in MSC/Circ.1120, for smoke dampers. Those dampers, now required on passengers ships carrying more than 36 passengers should, as stated, be able to restrict the passage of smoke and hot gasses. No current IMO instruments, however, appear to be available for guidance on assessment of their performance in that respect, and there would be a concern that may lead to inconsistencies in design and application. The development of guidelines or performance requirements for smoke dampers is also being recommended by IACS. This can also possibly be done jointly with the work envisaged above on smoke management systems.

Advice for owners / builders

The following is a summary of changes that will impact the ventilation arrangements for ships. • Ventilation ducts shall be provided with hatches for inspection and cleaning. The hatches shall be located

near the fire dampers. Such requirement was so far only applicable to exhaust ducts on passenger ships carrying more than 36 passengers, it is now applicable to all ducts on all ships. While the above might have been good engineering practice in the past that now becomes a mandatory requirement.

• Ventilation openings or air balance ducts between two enclosed spaces are now explicitly prohibited, except as permitted by paragraphs II-2/9.4.1.2.1 and II-2/9.4.2.3 (similar requirements was previously included IACS UI SC119)

• As mentioned earlier, splitting of ducts having cross-sectional area exceeding 0.075 m2 into smaller ducts at the penetration of an "A" class division and then recombination of them into the original duct once through the division to avoid installing the damper required by this provision is now explicitly prohibited.

• A length of 5m of A-60 insulation beyond dampers is now required both in the case of machinery spaces ventilation running through accommodation spaces, service spaces and control stations, and vice versa (such insulation was previously only required in the first of those two instances).

• Exhaust ducts from galley ranges on cargo ships and passenger ships carrying not more than 36 passengers are now required to be fitted with an automatically and remotely operated fire damper located in the lower end of the duct at the junction between the duct and the galley range hood and, in addition, a remotely operated fire damper in the upper end of the duct close to the outlet of the duct; also, arrangements, operable from within the galley, should be provided for shutting off the exhaust and supply fans (so far the requirements were only for a fire damper (not automatically nor remotely operated) to be provided at the lower end of the duct and for means to shut off the exhaust fans only). This is likely to be a significant step change in the design and construction of those systems on new cargo ships and on new passenger ships carrying less than 36 passengers. It may be noted that the allowance currently made by IACS UI SC118 for the damper at the lower end of the duct not needing to pass the fire test in FTP Code 2010 (formerly Res. A.754(18), but to be of steel and capable of stopping the draught only, has now been incorporated in the Convention.

• In exhaust ducts from galley ranges on passenger ships carrying more than 36 passengers, remote-control arrangements for shutting off the exhaust fans and supply fans, for operating the fire dampers and for operating the fire-extinguishing system, shall be placed in a position outside the galley close to the entrance to the galley. (so far the requirements was only for them to be close to the entrance of the galley, but not necessarily outside). This requirement imposes a more prescriptive approach to the location of such controls.

• Reference is now made to "ISO 15371:2009, Ships and marine technology – Fire extinguishing systems for protection of galley cooking equipment" for design and testing of means for extinguishing a fire within the exhaust ducts from galley ranges on passenger and cargo ships. (no guidance was available so far). Fire protection system manufacturers should consider performing fire testing as appropriate and seeking fire type approval by Recognised Organisations, and builders and owners should be aware of requirements in the above standard when designing and installing such systems.

Advice for Flag Administrations / Recognized Organizations

Surveyors involved in the design appraisal and plan approval, as well as on site surveyors will need to be aware of the new requirements. The development of the safety objectives, functional objectives and performance standards for the use of smoke management system in all new cargo and passenger ships requires to be closely monitored.


11

Applicability

New cargo ships and passenger ships only. FP 56 should clarify the date of application of the new amendments and application to new and existing ships.

Document submitted

FP 56/4 (United States) - Report of the Correspondence Group This document provides the report of the Correspondence Group on Development of requirements for the fire resistance of ventilation ducts, established at FP 55. Some of the major discussion points include the fire protection arrangements for ventilation ducts serving more than one tweendeck space, galley ducts, proposals to allow smoke management systems to be used onboard, remote operation of fire dampers in galley ducts, as well as new draft SOLAS regulation II-2/9.7 Return to overall summary at the start of document


13

Annex 3 - Review of protection requirements for on-deck cargo areas (Agenda item 5)

Overview

FP 56 will consider amendments proposed to SOLAS regulation II-2/1 and II-2/10 as well as draft MSC Circular which details the criteria for the design, performance, testing and approval of mobile water monitors used for the protection of on-deck cargo areas of containerships or ships carrying more than four tiers of containers on the weather deck. The report proposes that the draft amendments as well as guidelines for the performance standards should only be applicable to new containerships or ships carrying more than four tiers of containers on the weather deck, however these requirements could be extended to existing ships at a later stage when sufficient experience has been gained. The document also suggests the minimum number of mobile water monitors and the water mist lance to be provided on board the ship, that ships with breadth up to 30 m should be provided with at least two mobile water monitors and those ships with breadth exceeding 30 m or more should be provided with at least four mobile water monitors.

Background

It has been proposed that deck fire fighting requirements on containerships, even mega containerships, were in need of update. Therefore, it was proposed to increase fire main and fire pumps capacity, pressure at hydrants and number of hydrants on deck to increase fire fighting capabilities to allow the use of additional fire fighting equipments such as portable water cannon on a voluntary basis. FP 55 could not agree on the amendments at this stage, because the text as drafted did not appropriately address containerships and implied applicability to all ships. The current text was rather imposing unnecessary requirements to other types of cargo ships. FP 56 was tasked to continue the discussions.


Lloyd's Register consider that the proposed amendments would address the difficulty in dealing with a container fire on deck, however consider that the following issues should be addressed It is very dangerous to try and move portable monitor with a hose attached to it once in operation. Therefore, the crew should not handle a high pressure hose connected to a monitor. In addition a monitor has a large reaction force which may make it unstable. It is important to ensure it is secured correctly to stop movement; however, this will be difficult on a steel deck. LR should only support the use of a portable monitor for crew who are fully trained. This can be a dangerous piece of equipment and may cause serious injury if used incorrectly. Depending on design there can be a large pressure loss when using a monitor, it is questionable whether 4 bar will give an effective throw to reach containers stacked 4 tiers high. This may introduce vessel requirements which do not really achieve the intent of the legislation. Where the ship (i.e. container ship) has not sufficient clear deck spaces on containerized cargo area, the following is to be considered; Stowage of monitor - Each mobile water monitor shall be kept ready for use in an easily accessible location and so distributed as to be readily available on both side of the ship. Transfer/handling arrangement In the event of fire, transfer routes from the stowage location shall allow for safe and efficient handling of mobile water monitors, and not interfere with the prompt preparation/handling of any other fire fighting; or


14

Transferring/handling for mobile water monitors shall be so arranged as to enable to carry out prompt fire fighting preparation.

Advices to clients

Builders/owners/manufacturers If the amendments are agreed, it is likely that fire fighting capabilities on deck will be increased for new containerships or ships carrying more than four tiers of containers on the weather deck. The carriage of additional fire fighting equipment is proposed as recommendatory measure. Owners that decide to use additional fire fighting equipment should take into consideration crew training.

Advice for Flag Administrations/Recognized Organizations

If the requirements are agreed, on-deck fire fighting capabilities, number of hydrants, and pressure at hydrant to cope with the demand of water required by the proposed monitors will be increased. Owner should provide crew training if additional fire fighting equipment is installed on board

Applicability

The proposed new requirements will apply to new container ships and cargo ships carrying more than 4 tier containers. There is also a proposal that the retroactive application is possible when sufficient experience is gained. The loading manual should be used to decide which ship should comply with the new requirements.

Documents submitted

FP 56/5 (Germany) - Report of the Correspondence Group This document reports on the outcome of the intersessional Correspondence Group on review of fire protection requirements for on-deck cargo areas Return to overall summary at the start of document


16

Annex 4 - Review of the recommendations on evacuation analysis for new and existing passenger ships (Agenda item 6)

Overview

Proposals FP 56 will consider the proposals to further improve the existing recommendations in MSC.1/Circ. 1238 for the evacuation analysis for new and existing passenger ships. It is suggested that guidelines are further amended to

- require a geometry which allows for a flexible exchange of persons between assembly stations, with the objective to prevent uncontrollable "horizontal" flow between main vertical zones.

- to develop embarkation process which works with minimal crew involvement - to store lifejackets nearby or close to assembly stations in order to improve the assembly process. - to explicitly forbid the counter flow as well as crossing flows of evacuation routes by crew or passengers

to prevent congestions - not to separate passenger flows through the same room and to prevent egress routes passing through

assembly stations, since dividing flows would require intensive influence by the crew and flows leading through e.g. assembly stations most certainly lead to significant congestions.

- take into account public spaces on open decks when dimensioning egress routes and performing evacuation analyses.

Safeguard Project FP 56 will also consider the document FP 56/INF.11, which details the work of the EU FP7 SAFEGUARD project , which was aimed at further developing the requirements in MSC.1/Circ. 1268, in particular to develop additional emergency scenarios, which could be used as benchmarks to decide the pass/fail requirement for the evacuation arrangements proposed onboard. It is recommended that all scenarios should take into account the congestion criteria as a pass/fail requirement, which the ship must comply in addition to the final evacuation time criterion. It is also recommended that the time component is dependent on the maximum assembly time allowed for the ship rather than the predicted assembly time. The document further proposes that MSC.1/Circ.1238 should include the fire and heel degraded scenarios to replace the current case 3 and 4. One of the key observations made by the project team was that the application of pre-defined benchmark scenarios to different designs and classes in MSC.1/Circ. 1268 was not straightforward and needs further development.

Background

It was proposed to amend the Guidelines for evacuation analysis for new and existing passenger ships (MSC.1/Circ.1238) to include a safe return to port criteria. It was suggested that the simplified evacuation analysis and the advance evacuation analysis were modified to include “identification of safe areas” and the scenarios to be considered for the analysis were to be increased to include “safe return to port criteria”. In addition, FP 55 considered a proposal to include a uniform safety criteria for evacuation routes within the Guidelines on alternative design and arrangements for fire safety (MSC/Cir.1002) that outline the methodology for the engineering analysis required by SOLAS II-2/17 to a specific fire safety system, design or arrangements that deviates from the prescriptive SOLAS II-2 requirements. FSS Code chapter 13 was proposed to be amended to address daytime cases where onboard procedures required passengers to first return to their cabins to retrieve lifejackets was not concluded because it was felt to be beyond the scope of this agenda item. Nevertheless, the specific matter of counter flow was agreed to be further discussed at FP 56 in the context of the outcome of SAFEGUARD project.


17


LR position: The proposals by Germany are actually relevant to the requirements for the sizing of the means of escape and relevant procedural arrangements which are included in SOLAS Ch II-2/Reg.13 and the FSS Code/Ch.13. These proposals include the introduction of strict prescriptive requirements for the assembly and evacuation of persons from passenger ships (cruise and ro-ro ships). If adopted they could have significant impact on the interiors arrangements and assembly/evacuation procedures on passenger vessels while derived merit is debatable. The proposals by Canada are relevant to the work carried out by SAFEGUARD project with a view to revise the guidance provided in MSC Circ.1238 for the evacuation analysis for passenger ships. It is to be noted that this analysis is currently required by SOLAS only for Ro-Ro ships and is used on a voluntary basis and some alternative design studies on cruise ships. The Safeguard project however also performed relevant tests and addressed the use of this guidance for cruise ships. In general there is merit in further considering the proposals in the papers by Canada especially the ones for the response time and the validation, INF.12 and 13 respectively as they are supported by testing onboard real ships. The proposals in paper INF.11 also have potential but they are based on modelling more than testing.

Advice to clients

There will be significant implications to the design of a cruise ships and Ro-Ro ships if the proposals by Germany are adopted and as in the paper title they mention applicability to both new and existing ships the later may need to modify their interiors arrangements to comply with the proposals. If this is the case then substantial costs will be involved for existing ships. The impact may be less for new ships are the proposed requirements will be considered at the design phase. Apart from construction related implications there will also be procedural ones to the operation of the ship as the assembly and evacuation procedures will have to change from what is applied currently by many ship operators. The papers FP56/INF 12, 13 by Canada however may have an impact on cruise ship interior arrangements, existing and new if the designers decide to follow the guidance as it is not mandatory. The same proposal appears to have minimum impact on Ro-Ro ships. The paper FP56/INF11 by Canada may have a bigger impact on the required size and arrangement for the escape routes for Ro-Ro ships and cruise ships (should the designers choose to follow it for cruise ships).

Applicability

It appears all proposals are made for both existing and new passenger ships. Relevant implications as per ‘advice to clients’ above. Documents submitted

FP 56/6 (Germany)- Problematic layouts being compliant with the guidelines The current guidelines are not sufficient to provide a safe environment for evacuation. Based on seven examples, demonstrated in document FP 56/INF.10, the rule compliant scenarios are shown. FP 56/INF.10(Germany)- Problematic layouts being compliant with the guidelines Based on seven examples, rule compliant scenarios are designed which show that the current guidelines would not be sufficient to provide a safe environment for evacuation FP 56/INF.11 (Canada) - The SAFEGUARD enhanced scenarios and recommendations for updating MSC.1/Circ.1238 This document details the work undertaken as part of the EU FP7 project SAFEGUARD to develop representative scenarios FP 56/INF.12 (Canada)- Response time data for large passenger ferries and cruise ships This document provides a summary of the findings and recommendations from the SAFEGUARD project relating to the Response Time Distributions (RTD) proposed for adoption in a modified version of MSC.1/Circ.1238


18

FP 56/INF.13 (Canada)- The SAFEGUARD validation data set and recommendations for updating MSC.1/Circ.1238 This document presents two evacuation model validation data sets collected as part of the EU FP7 project SAFEGUARD. In addition, a validation protocol and acceptance criteria are developed based on the collected data. It is proposed that the validation data sets, suggested validation protocol and the acceptance criteria could be adopted by IMO as part of a validation suite to determine acceptability of maritime evacuation models in a future enhancement to IMO MSC.1/Circ.1238. Return to overall summary at the start of document


19

Annex 5 - Development of requirements for additional means of escape from machinery spaces (Agenda item 7)

Overview

FP 56 will consider proposed amendments to SOLAS regulations II-2/13.4.1 and 13.4.2, for ensuring effective means of escape from engine control rooms and other enclosed working spaces located within machinery spaces in both cargo and passenger ships with the aim to provide the same level of fire protection to the personnel onboard passenger and cargo ships. It is proposed that minimum two means of escape shall be provided from the main workshop within a machinery space. At least one of these escape routes shall provide a continuous fire shelter to a safe position outside the machinery space. In addition, improved access to the normal exit and emergency escape routes, with the provision that all inclined ladders or stairways with open treads, not located within a protected enclosure, are to be of steel and protected against heat and flame by steel shields attached to their undersides. In addition, FP 56 will also consider the need for a unified interpretation to clarify the application of SOLAS regulation II-2/13.4.2.1.1, in particular the insulation arrangements for the escape trunks from the machinery spaces and also the outstanding issue regarding a clear definition of the term enclosed room.

Background

FP 55 discussed amendments to SOLAS II-2/13.4.1 and 13.4.2 that will mandate two (2) means of escape for other enclosed spaces within machinery spaces of category (A), where the ships crew carry out work on a daily basis, and ensure the same level of protection for the personnel onboard cargo and passenger ships and ensuring additional means of protection for open ladders forming part of or providing access to escape routes. exploring at the same time, the possibility of providing the same level of protection for the crew on board cargo ships as in passenger ships and the means to ensure additional protection to open ladders forming part or providing access to escape routes. However, it was agreed that the proposed amendments needed further clarification with regard to the requirements regulating dimensions of means of escape from machinery space and to the dispensation from the two means of escape and will be finalised at FP 56. In addition, FP considered proposals to develop unified interpretation to clarify vague expressions under SOLAS regulation II-2/13.4.2 and II-2/13.4, but these were not agreed at this stage. FP 55 also noted the intention of IACS (FP 55/10/2) to develop unified interpretations regarding the location of the door fitted on the lowest part of the enclosure protecting one of two sets of steel ladders; the arrangement of the open stairway providing access to the door from the lowest floor level; and the minimum clear opening of the door (SOLAS regulations II-2/13.4.1.1 and 13.4.2.1), taking into account the need to provide additional clarification for these requirements, in particular for port State control purposes. The definition of ‘enclosed room/space’ as taken from SOLAS regulation II-2/9.2.2.4.2.2, needed further clarity in terms of a lower threshold size of such rooms for the purposes of applying the proposed amendments; in particular, two possible criteria were put forward for consideration: floor area of 9 m2 or 27 m2. These will be finalised at FP 56


• LR generally Supports Bahamas, Korean and Chinese proposals on this item, however cannot agree to the proposal from Denmark on means of escape as it limits the application to large enclosed spaces only

• In addition LR also consider that the terminology “where crew are normally employed” is not correct

and instead proposes that safe means of escape should be provided to all workshops within a machinery space.

• LR also shared agreement to IACS submission that the entire escape trunks (boundary between trunk and adjacent spaces) should be insulated to Category 4.


20

• The application criteria to be confirmed, whether the requirements are applicable to new ships only.

Advices to clients

If agreed, possible cargo and passenger ships design change for engine rooms, i.e., to provide another means for escape, depending upon discussions at FP55.

Applicability

The requirements were intended to applicable for new cargo and passenger ships.

Document submitted (these relating to activities of Lloyd’s Register)

FP 56/7 (IACS) – Definition of a vague expression in SOLAS - Structural Fire Protection SOLAS regulation II-2/13.4.2.1.1 IACS is looking for a clarification on the requirements to insulate escape trunks from machinery spaces of category A (SOLAS regulation II-2/13.4.2.1.1) since it is questioned whether the insulation is required only against the space it serves. Essentially, it is important to clarify if the escape trunks are to be insulated to category (4) insulation only from the lower part of the engine-room to the position where the trunk connects to the outside of the space, or the category (4) insulation shall apply to the trunk against any adjacent space. FP 56/7/1 – Bahamas, IMarEST and ICS) - Proposed amendments to SOLAS regulations II-2/13.4.1 and 13.4.2 The document proposes amendments to SOLAS regulations II-2/13.4.1 and 13.4.2 on means of escape from machinery control rooms and main workshops within machinery spaces of cargo and passenger ships. The document takes into account comment made by the Sub-Committee on an earlier proposal and aims to satisfy the request for adjustment and clarification of the proposals contained in document FP 55/10/1 FP 56/7/2-Republic of Korea-Draft unified interpretation of SOLAS regulations II-2/13.4.1.1 and 13.4.2.1 –Escape trunk in machinery space for passenger ships and cargo ships Escape trunk in machinery space for passenger ships and cargo ships. This document propose a draft unified interpretation for the application of the requirements of SOLAS regulations II-2/13.4.1.1 and 13.4.2.1 regarding the arrangement of the escape trunk in machinery spaces of passenger ships and cargo ships FP 56/7/3-People’s Republic of China-Proposal to develop unified interpretation for means of escape from machinery spaces in passenger ships and cargo ships as required by SOLAS regulations II-2/13.4.1 and 13.4.2 This document seeks clarification and proposes development of unified interpretation for means of escape from machinery spaces in passenger ships and cargo ships as required by SOLAS regulations II-2/13.4.1 and 13.4.2, respectively FP 56/7/4-Denmark- Development of requirements for additional means of escape from machinery spaces This document proposes amendments to SOLAS regulations II-2/13.4.1 and 13.4.2 on means of escape from machinery control rooms, workshops and other enclosed spaces within machinery spaces of cargo ships and passenger ships. The document takes into account the discussions and agreements made on this subject at FP 55. FP 56/7/4-Denmark- Additional protection of ladders/stairways as part of the escape from machinery spaces This document further substantiates the proposed amendments to SOLAS regulations II-2/13.4.1 and 13.4.2, set out in document FP 56/7/4, on means of escape from machinery spaces of cargo ships and passenger ships. It proposes also that the protection of ladders/stairways be a part of the escape routes from engine-rooms. Return to overall summary at the start of document


21

Annex 6 - Development of requirements for ships carrying hydrogen and compressed natural gas vehicles (Agenda item 8)

Overview

FP 56 will consider proposed arrangements to SOLAS Chapter II-2 to include requirements for ships carrying motor vehicles which uses hydrogen and compressed natural gas for their propulsion. Noting the concerns at FP 55 on whether the requirements should apply to cargo spaces on board ships irrespective of their type, it is now proposed that the subject draft amendments shall only apply to ‘pure car carriers’ and for this purpose a definition for ‘Ro-ro cargo ship (vehicle carrier)’ as for a pure car carrier, taken from MARPOL Annex VI regulation 2.33 ("Ro-ro cargo ship (vehicle carrier)") (MEPC.203(62)) is included for consideration by the sub-committee. In addition to the above, it is proposed that all new requirements which could impact the ship structure, will only apply to new ships. These include the proposals that all electrical equipment and wiring used in spaces intended to carry such vehicles, including fans and other electrical equipment used in the ventilation ducts shall be of an explosion-proof type and to prohibit the use of any equipment in such spaces that may constitute a fire/explosion risk. However, existing ships should comply with all non-structure related requirements given in the draft amendments, such as at least two suitably safe type portable gas detectors for the detection of gas fuel emissions from the tanks of such vehicles. In addition to the above, a draft MSC Circular has been proposed which provides guidelines on safety measures for existing ships to address risks associated with carrying HFCVs and CNGVs, instead of retrospective application of structure-related requirements on existing ships. However it is noted that this circular contains too many undefined terms and it is anticipated that these will be addressed at FP 56.

Background

MSC 85 (MSC 85/23/5) accepted a proposal to review requirements for ships carrying compressed natural gas vehicles and instructed FP Subcommittee to look into it as high priority. The reason behind this proposal is the increase in demand and supply for such vehicles, and as a consequence, the efficient transport of these vehicles by sea is becoming essential. On the other hand, the current SOLAS regulations have been developed based on the carriage of the conventional vehicles with gasoline in their tanks. In considering, the proposals FP 55 noted that the scope of the new safety measures proposed under SOLAS Chapter II-2/20 and II-2/1 were prepared for cargo spaces on board all ships, irrespective of their type, which carry CNGVs and/or HFCVs, on either a regular basis or on a case by case basis. FP 55 instructed to continue the analysis of these amendments, especially in terms of the impact to existing ships. To provide clear guidance, FP 55 requested MSC 90 to clarify the scope of work specifically ship types and application to exiting ships. In addition, “equivalent safety measure” were proposed for existing ships such as limitation of number of CNGVs and HFCVs; securing arrangements, and details checks to prevent leakage. How will this proposed safety measure will be applied was not clarified, therefore careful considerations should be given to it before agreeing to the text. RO’s may be involved in disputes between Flags and owners if there is no clear guidance. FP55 considered the view to use explosion-proof electrical equipment using IEC 600079 standard throughout the spaces, and the provision of portable gas detectors of appropriate type on new and existing ships transporting CNVGs and HFCVs.


22


The submission from Japan (FP 56/8) proposes to apply all requirements that could impact the ship structure to new ships only, and to apply non-structure related requirements for existing and new ships. Lloyd's Register can agree with these proposals however consider that there should be further clarity on following issues. The guidelines in the draft MSC Circular, especially in paragraph 2.2 of Annex 2 of FP 56/8 needs further clarity, to ensure smooth implementation of these requirements in existing ships. The terms such limitation of vehicles, what type of additional securing arrangement noting the vehicles with tanks will have been crash tested should be further clarified.

1. In addition, the date on which existing ships should comply with the non-structural mandatory requirements such as the provision for gas detectors needs further clarification. Lloyd's Register is of the view that existing ships shall comply with the above requirements by the first renewal survey after the date of entry into force of the amendments.

2. The minimum fixed fire protection arrangements required for these spaces has not been addressed.

3. The requirements for ventilation (air transfer rate) at these spaces to prevent the build up of flammable gases has not been clarified.

4. Minimum safety rating for electric equipment to be used in vehicle spaces should be identified to prevent ambiguities. FP 55 considered the proposal to use explosion-proof electrical equipment complying with IEC 60079 standard (Electrical Apparatus for Explosive Gas Atmospheres) to be used in vehicle spaces, however such details are missing in FP 56/8 and should be further clarified.

Advices to clients

The proposed amendments when adopted will affect ship construction, provision of installation of fire detection systems, type of ventilation and its location, provision of approved explosion proof safe type equipment. Full list of impact will be provided after FP 56 has concluded deliberations on this item.

Applicability

It is proposed that these requirements should only apply to new “pure car carriers”, which carry HFCVs (Hydrogen Fuel Cell Vehicles) and CNGVs (Compressed natural Gas Vehicles).

Document submitted

FP 56/8 (Japan) - Proposed draft amendments to SOLAS chapter II-2 This document proposes draft amendments to SOLAS chapter II-2 to include requirements for ships carrying hydrogen and compressed natural gas vehicles Return to overall summary at the start of the document


23

Annex 7 - Consideration of IACS unified interpretations (Agenda item 9)

Overview

Various IACS Unified Interpretations are submitted for consideration as Maritime Safety Committee (MSC) circulars, at this session. FP 56 should clarify the date of application of the MSC circulars to be agreed under this item.


Lloyd’s Register agrees in general with the IACS interpretations proposed under this agenda item.


FP 56/9 (IACS) - Suction piping of emergency fire pumps which are run through the machinery space (SOLAS regulation II-2/10.2.1.4.1) – IACS UI SC 245 IACS provides Unified Interpretation (UI) SC 245 relating to SOLAS regulation II-2/10.2.1.4.1 on suction piping of emergency fire pumps, which are run through the machinery space. FP 54 agreed with the understanding IACS provided on regulation II-2/10.2.1.4.1 FP 56/9/Rev.1 (IACS) - Suction and discharge piping of emergency fire pumps which are run through the machinery space (SOLAS regulation II-2/10.2.1.4.1)-IACS UI SC 245/Corr.1 This document provides in the annex IACS Unified Interpretation SC 245/Corr.1 relating to SOLAS regulation II-2/10.2.1.4.1 on suction and discharge piping of emergency fire pumps, which are run through the machinery space FP 56/9/1 (IACS) - Emergency exit hatches to open deck (SOLAS regulation II-2/13.1) – IACS UI SC 247 IACS prepared unified interpretation SC 247 on the implementation of functional requirements contained in SOLAS regulation II-2/13.1 which aims is to ensure persons on board can safely and swiftly escape to the lifeboat and liferaft embarkation deck. IACS has created this UI to prescribe a maximum force necessary to open an overhead emergency exit hatch, considering that there have been problems at new construction stage as to what is an appropriate force to open hatches. In addition, surveyors experienced that hatches provided as means of escape to open decks may be heavy and hard to open, especially for a person standing in the exit ladder below deck. FP 56/9/2 (IACS) – Fixed gas fire-extinguishing systems (FSS Code, chapter 5, paragraph 2.2.2) - IACS UI SC 252 IACS provides Unified Interpretation (UI) SC 252 relating to FSS Code Chapter 5 section 2.2.2.1 (carbon dioxide systems controls) to clarify that the two separate controls for discharging the carbon dioxide media (one for the section valve and the other for opening the valves on the CO2 bottles) may be independent from the control activating the alarm, and that a single control to activate the alarm is sufficient. This UI also clarified that the "positive means", referred to in paragraph 2.2.2.1 for the correct sequential operation of the controls, is to be achieved by a mechanical and/or electrical interlock that does not depend on any operational procedure to achieve the correct sequence of operation. FP 56/9/3 (IACS) – IACS Unified Interpretation (UI) SC 250 on fire-extinguishing arrangements in cargo spaces (resolution MSC.268 (85), IMSBC Code) IACS submission in paragraph 3 and 4 is stating wrong understanding of the use of CO2 fixed fire extinguishing systems for the dangerous goods cargoes. The issue was raised with Sam James, William Millar and Bruce McDonald, for the attention of the SP, since the misunderstanding may well have the UI rejected by the DSC 17.


24

It is IACS understanding that any facility/system present on board that can supply carbon dioxide or inert gas could be suitable for the purpose of complying with IMSBC Code requirements for inerting the cargo space to prevent self heating of the cargo above 55 C. The fixed gas fire-extinguishing system required by SOLAS regulation II-2/10.7.1.3 or II-2/10.7.2 is considered sufficient for this purpose. However, if the fixed gas fire-extinguishing systems or inert gas systems installed on board is also designated to protect spaces other than cargo spaces, this system cannot be used for this purpose, as their use as "inerting system" would jeopardize the protection of other spaces on the ship. FP 56/9/4 (IACS) – Gas measurement and detection – portable instruments (SOLAS regulation II-2/4.5.7.1) – IACS UI SC 149 This document provides an interpretation to the requirements of SOLAS regulation II-2/4.5.7.1 regarding portable instruments used for gas measurement and detection which required sufficient set of spares. The expression “sufficient set of spares” is clarified by IACS UI SC 149 stating that the requirements is satisfied when a minimum of two instruments, each capable of measuring both oxygen and flammable vapour concentrations are provided on board. Alternatively, two portable instruments for measuring oxygen and two portable instruments for measuring flammable vapour concentrations could be provided on board. FP 56/9/5 (IACS) – Location of the fire main isolation valves in tankers (SOLAS regulation II-2/10.2.1.4.4) IACS is providing interpretation for SOLAS regulation II-2/10.2.1.4.4, to clarify requirements for tankers regarding fitting isolation valves in the fire main at the poop front in a “protected position”. What should constitute a protected position was considered unclear, since it was agreed that a fire in the cargo area could render the valve inaccessible/inoperable and that the valve itself, as well as the means to access the valve, should be protected to the same extent as that afforded by the poop front bulkhead, in which case the valve would need to be located within the accommodation space, but within the general area of the front of the deckhouse structure. FP 56/9/6 (IACS) - Fixed hydrocarbon gas detection systems This document seeks clarification on the meaning of "adjacent" relative to a fixed hydrocarbon gas detection system complying with the Fire Safety Systems Code for measuring hydrocarbon gas concentrations in all ballast tanks and void spaces of double-hull and double-bottom spaces adjacent to the cargo tanks, including the forepeak tank and any other tanks and spaces under the bulkhead deck adjacent to cargo tanks

FP 56/9/7 (IACS) - Fire resistance requirements for fibre-reinforced plastic (FRP) gratings used for safe access to tanker bows (resolution MSC.62(67)) This document provides in the annex, IACS Unified Interpretation SC 253 regarding the fire resistance requirements for fibre-reinforced plastic (FRP) gratings used for safe access to tanker bows (resolution MSC.62(67)) FP 56/9/8 (IACS) - Proposed clarification on the application of SOLAS regulation II-2/9.2.4.2.5 to the top boundary of accommodation spaces exposed as open decks in oil tankers This document discusses the need for a clarification regarding the insulation of the top boundary of accommodation spaces exposed as open decks in oil tankers, an issue which is not precisely addressed by SOLAS regulation II-2/9.2.4.2.5 FP 56/9/9 (IACS) - Implementation of the provisions of SOLAS regulation II-2/7.5.5 This document responds to the Maritime Safety Committee's request at its ninetieth session for IACS to submit to this Sub-Committee a draft MSC circular to clarify the application of the three protection methods (IC, IIC or IIIC) for control stations on cargo ships FP 56/9/10 (IACS) - Protection of load bearing structures (2000 HSC Code, paragraph 7.4.2.3) This document provides in the annex, IACS Unified Interpretation HSC 8, regarding the protection of load bearing structures as required by paragraph 7.4.2.3 of the 2000 HSC Code


25

FP 56/9/11 (IACS)-Request for clarification relating to MSC/Circ.1165 on Revised guidelines for the approval of equivalent water-based fire-extinguishing systems for machinery spaces and cargo pump-rooms This document seeks clarification from the Sub-Committee on the definition of bilge areas and requirements for dedicated water mist bilge nozzles. FP 56/9/12 (IACS)- Application of the IMDG Code and SOLAS chapter II-2 requirements to spaces carrying vehicles with fuel in their tanks This document examines the application of the IMDG Code and SOLAS chapter II-2 requirements to spaces carrying vehicles with fuel in their tanks. Amendment 35-10 of the IMDG Code includes special provisions 961 and 962, which allow motor vehicles with fuel in their tanks for their own propulsion to be carried either in specially designed cargo spaces as non-dangerous goods or in other cargo spaces as Class 9 dangerous goods. SOLAS regulation II-2/20 (SOLAS regulation II-2/53 for vessels constructed before 1 July 2002) provides requirements for cargo spaces intended for the carriage of vehicles with fuel in their tanks. There is an apparent need for clarification of the difference between the requirements of SOLAS and the IMDG Code special provisions 961 and 962. FP 56/9/13 (IACS)- Fire protection arrangements in cargo spaces (IACS UI SC 49) This document provides rationale behind the latest revision of IACS Unified Interpretation UI SC 49 regarding fire protection arrangements in cargo spaces as required by SOLAS regulation II-2/10.7.2 FP 56/9/13 (IACS)- Comments on document FP 56/9/9 This document provides comments on document FP 56/9/9 regarding the interpretation relevant to the fitting of a fixed detection fire alarm system in control stations submitted by IACS Return to overall summary at the start of the document


26

Annex 8 - Harmonization of the requirements for the location of entrances, air inlets and openings in the superstructures of tankers (Agenda item 10)

Overview

FP 56 will be invited to consider FP 56/10, which presents a comparative study of the requirements for the location of entrances, air inlets and openings in the superstructures of tankers as given in various IMO instruments as well as in other international standards, with respect to the ignition of flammable gases or vapours in cargo that can enter through various openings in ship superstructures and will consider options to harmonise these requirements. It is pointed out that while SOLAS, based on IEC standards, specifies hazardous zones to determine the appropriate rating for electrical installations to be used in such spaces, however SOLAS requirements regarding the location of superstructure openings do not necessarily comply with the above hazardous zones criteria, and this inconsistency causes problems for the uniform implementation of safety measures. It is concluded that a new hazardous area criteria consistent with that of the IEC standards could be adopted for the IMO instruments. This criteria would be based on the distance and type of gas emitting source rather than pre-established general arrangements that may not take into account different ship designs.

Background

FP 51 recognised that the admissible distances required in SOLAS Chapter II-2, IBC and IGC codes for entrances, air inlets and openings in the superstructure of tankers, need to be harmonized. It was also discussed that the use of IEC standards would reduce current IMO safety level and using MSC/Circ. 474, MSC/Circ.1120 and MSC/Cric.1203 would not give consistent results.

FP 54 discussed various options for harmonising the requirements such as;

• Produce a comparative table of all requirements in various IMO instruments, before proceeding to harmonize, to compare with other international standards

• Amend the FSS code by introducing a new chapter containing the harmonised requirements and subsequently amending SOLAS, the IBC and IGC Codes.

Lloyd’s Register Position

LR supports harmonisation of the requirements in different IMO instruments and IEC Standards and supports UK view that a unified interpretation (UI) is the best way to achieve this objective rather than amendment of individual instruments. However pointed out that certain differences which exists in IMO Instruments are intended to address specific risks involved with the type of cargo which the ship type is carrying and therefore such issues should be taken care of while trying to harmonise.

Advice for clients

Harmonised requirements will provide more clarity on the criteria for determining hazardous zones and the minimum safety rating required for electrical installations that may be used in such spaces.

Application

Although the document (FP 56/10) implies retroactive application, there should be further clarity on the application criteria (such as which type of tankers are included in the scope and whether the requirements will apply to both new and existing tankers and the implementation date)


27


FP 56/10 (Argentina) - a comparative study of the various requirements This document makes a comparative study of the various requirements that exist in different IMO instruments and other international standards with respect to ignition of flammable gases or vapours in cargo that can enter through various openings in ship superstructures and/or deckhouses, and proposes options for their harmonization Return to overall summary at the start of the document


28

Annex 9 - Development of unified interpretations for chapter 7 of the 2000 HSC Code (Agenda item 11)

Overview

FP56 will consider the issue of developing unified interpretations for chapter 7 (Fire Safety) of the 2000 HSC Code as amended by resolutions MSC.175 (79) and MSC.222 (82). The paragraphs being addressed are paragraphs 7.4.1.3 and 7.4.1.4, related to fire-restricting materials. Most of the enclosed spaces on a high-speed craft are fire category C (areas of minor fire hazard). It is, in general, recognized that public spaces, kiosks, shops, crew accommodation and similar spaces shall be protected by fire-restricting materials. It is also proposed that technical spaces (auxiliary machinery spaces, as per paragraph 1.4.6 of the HSC Code) should comply with paragraph 7.4.1.3 of the HSC Code. Therefore, mainly the hull spaces (voids, tank compartments, etc.) are the areas that need to be addressed.

Background

MSC 87 tasked FP55 to discuss unified interpretations for chapter 7 (Fire Safety) of the HSC Code due to major challenges with high speed craft constructed of fibre –reinforced polymers (FRP) have to ensure the fire safety arrangements complies with the HSC Code. Due to the limited number of FRP craft constructed since the introduction of this Code there are only a few unified interpretations available and the application of fire-restricting materials (paragraph 7.1.4.3 and 7.1.4.4 of the 2000 HSC Code, as amended by resolutions MSC.175 (79) and MSC. 222(82) is usually open to different interpretations and some Flag Administrations understand this paragraphs differently

Advice for all clients

Applicability


Return to overall summary at the start of the document


29

Annex 10 - Development of guidelines for use of fibre reinforced plastic (FRP) within ship structures (Agenda item 12)

Overview

FP 56 will continue the discussions on the use of fibre reinforced plastic (FRP) within ship structures, based on submissions from Sweden (FP 56/12), China (FP 56/12/2) and the United States (FP 56/12/1). The papers from Sweden and China provide empirical data based on research and some sample fire tests of FRP bulkheads and decks and they propose to use such data as the basis for developing guidance for the approval of FRP structures, including fire testing of FRP materials. China clarifies that they support Option 1, as proposed by the United Kingdom in document FP 55/19, i.e. development of guidelines for the application of SOLAS regulation II-2/17 for evaluating FRP structures, rather than option 2, which calls for the development of a prescriptive regulatory frame work for the approval of such structures. The United States vehemently opposes the Swedish, Chinese and UK proposals on the grounds that the use of such combustible materials as part of the ship structure would not meet the functional objectives of SOLAS Chapter II-2.

Background

Currently there are no standards governing building of ships in FRP. The need for further guidance regarding standards to be applied where FRP is being used to replace steel or other equivalent material was presented to MSC 87 by a Flag Administration that received proposals to build major parts of ship structure in FRP. It is to be noted that this deviation in materials is compliant with SOLAS regulation II-2/17 since regulation 17 relies on an alternative design meeting the fire safety objectives and the functional requirements set out in chapter II-2, parts B (prevention of fire and explosion), C (suppression of fire), D (Escape), E (Operational requirements) and G (special requirements). When evaluating the proposals under SOLAS regulation II-2/17, the Administration identified some difficulties in appraising the designs and as such presented a recommendation to MSC 87 to develop guidelines for use of FRP within ship structures. MSC 87 tasked the DE and FP Sub-Committees to consider the issue of developing guidelines for use of fibre-reinforced plastic (FRP) within ship structures. The guidelines are proposed to be applied if FRP is accepted as material to be use on ships structures within the SOLAS framework (SOLAS II-2/3.43) instead of steel or other equivalent material.


Lloyd's Register acknowledges that there are known problems with FRP. Therefore, consider that if such materials are to be used onboard, then a clear prescriptive regulatory framework should be developed which specifies the fire safety objectives, fire test procedures and application criteria for FRP materials, as proposed under Option 2 by the United Kingdom in document FP 55/19. Lloyd's Register cannot support the development of guidelines for the application of SOLAS regulation II-2/17 for evaluating FRP structures, as they could lead to misinterpretations and cause problems during applications. Lloyd's Register will continue to closely monitor the development on this item

Advice for owners / operators / for builders:

Note discussions on this item which is currently under development.


30

Applicability:

It is not been discussed yet how the guidelines will apply.


FP 56/12 (Sweden) - Proposal for a new set of guidelines regarding the use of fibre reinforced plastic for ships The aim of this document is to provide more input to the work on development of guidelines for approval of FRP structures, including fire testing of FRP materials. It is proposed that a correspondence group under the Sub-Committee on Fire Protection be established and a proposal for terms of reference for the group is presented. A proposal for the guidelines is also included. This proposal gives an idea of a possible structure and content of the guidelines and could be used as a starting document for the work. FP 56/12/1 (United States) - Possible use of FRP materials in ship structures within the limits of the SOLAS chapter II-2 fire safety regime This document presents the United States' views on the possible use of FRP materials in ship structures within the limits of the SOLAS chapter II-2 fire safety regime FP 56/12/2 (China) - Proposals for development of guidelines for the use of fibre reinforced plastic for ships The document provides comments on the development of guidelines for use of fibre reinforced plastic (FRP) within ship structures. Besides, the document offers proposals in relation to the development of guidelines for fire resistance testing of FRP structures, based on the study on the results of tests on FRP bulkheads and decks FP 56/INF.9 (China) - Data and information from fire resistance testing of fibre reinforced plastic (FRP) structures This document provides data and information from fire resistance testing of FRP structures carried out by China Return to overall summary at the start of the document


31

Annex 11 - Analysis of fire casualty records (Agenda item 13)

Overview

FP 56 will consider a report on the casualty analysis of a fire on a vehicle deck of the RoPax vessel Lisco Gloria and appropriate evacuation measures taken, which enabled the safe rescue of all 235 persons onboard. The report notes that crew's education, training and awareness of the consequences of fire on board are essential for effective fire-fighting or evacuation of a ship. In this case, the immediate decision of the master to evacuate the ship, shortly after the fire broke out and noting the functional failure of the drencher (sprinkler) system and the difficulty for fire fighting teams to fight the fire, was critical in saving the lives of the passengers and crew. The report notes that a quick and comprehensive fire response is required to prevent the rapid spread of the fire. However, limited accessibility of ro-ro decks can cause a problem for even a fully equipped fire fighting team to fight the fire. The structural fire protection was noted to be significantly more effective than would have been expected under the given circumstances and, supplemented by the crew’s cooling measures, it facilitated safe evacuation of the passengers. The effectiveness of a (sprinkler) drencher system to control the fire is also questioned based on experience from the Commodore Clipper case. The report also recommends that in the event of evacuation, crew members should be equipped with safety vests or other means to make them clearly recognizable as points of contact for passengers and also notes the importance on the effective use of public address system for informing passengers.


Lloyd's Register will note the information provided and will take actions as appropriate.

Advices to clients

To note the information provided.


FP 56/13 (Germany and Lithuania)- Information on fires in vehicle spaces in a passenger ship and evacuation off the vessel This document provides information on the casualty analysis of a fire on a vehicle deck of the RoPax vessel Lisco Gloria and measures taken for evacuation. Return to overall summary at the start of the document


32

Annex 12 - Development of amendments to SOLAS chapter II-2, the FTP Code and MSC/Circ.1120 to clarify the requirements for plastic pipes on ships (Agenda item 14)

Overview

At present, the International Code for Application of Fire Test Procedures (FTP Code), annex 1, part 2, contains specific provisions on the smoke and toxicity requirements applicable to plastic pipes, however MSC/Circ.1120 states that the flame spread requirements of SOLAS regulation II-2/5.3.2.4 and the smoke and toxicity requirements of regulation II-2/6.2 are not applicable to plastic pipes, thus in effect invalidating the FTP Code requirements. Denmark raises concerns on the use of plastic pipes for systems that are not normally filled with water, such as sanitary systems and describes a fire scenario in a vertically mounted plastic pipe penetrating several decks. They state that while the expanding sleeve of plastic pipe penetrations may be able to prevent the spread of flame and smoke upwards, the sleeves on the floor may not expand and close, allowing melting plastic to drop to the lower decks causing ignition. In light of the above, they propose that FP 56 should consider whether fire endurance requirements for plastic pipes should be introduced and whether existing FTP Code requirements are adequate to prevent the spread of fire downwards.

Background

At MSC 88, there was a proposal to further develop the requirements for plastic pipes on ships by clarifying the application of smoke, toxicity and flame spread criteria. (MSC 88/23/8 and MSC INF.2) with regard to SOLAS regulations II-2/5.3.2.4 and II-2/6.2 and the Fire Test Procedures Code, as interpreted by MSC/Circ.1120/ Subsequently, FP 56 was instructed to consider this issue.


Lloyd's Register notes that Resolution A.753 (18) contains specific provisions to determine three levels of fire endurance for plastic pipes depending on their application onboard. This test procedure also calls for low flame spread properties of plastic pipes when used in accommodation spaces, and resolution A.653 (16) could be used to determine the low flame spread properties. Thus the required test procedures are already in place and no further rule development work needs to be carried out. However, we also note that the use of plastic pipes is almost the norm in passenger ships and therefore the necessity of such a new requirement, at this late stage is considered questionable. In addition, it is also noted that the proposal from Denmark is quite vague and does not provide a solution to address the issue.

Advices to clients

Note the discussions on this item which is currently under development.

Applicability

It has not been discussed yet how the guidelines will apply.


33


FP 56/14 (Denmark)- Considerations on flame spread This document provides a proposal to consider introducing requirements on fire endurance tests for plastic pipes penetrating bulkheads and decks and consider the test requirements for such penetrations Return to overall summary at the start of the document


34

Annex 13 – Consideration of amendments to SOLAS chapter II-2 on location of EEBDs (Agenda item 15)

Overview

FP 56 will consider proposals from United Kingdom (FP 56/15) to amend SOLAS regulation II-2/13.3.4 to state that the emergency escape breathing devices (EEBDs) for use within accommodation spaces shall be stored adjacent to the location of fire-fighters’ outfits, in fire lockers. United Kingdom is of the view that the EEBDs should be stored in a location which is readily accessible to everyone, so that they could also be taken to the trapped personnel by the rescue party, to ensure their safe escape from a hazardous atmosphere. This is current practice, especially in ships (normally in cargo ships) where only the minimum two EEBDs are used. However, Bahamas opposes this view and consider that the EEBDs are solely for escape and not for rescue purposes, that emergency teams should not be burdened with the EEBDs alongside all their other equipment, that the priority should be to remove the casualty to clear air at the earliest time and that the removal of EEBDs from the accommodation removes the option of escape for persons trapped within a space. They propose that, additional rescue/resuscitation equipment at fire lockers would be more suitable than EEBDs, to meet the objectives of the proposal from United Kingdom and requests FP 56 to decide accordingly.

Background

SOLAS regulation II-2/13.3.4 requires that emergency escape breathing devices (EEBDs) are to be carried within accommodation spaces, however there is no clear guidance regarding the storage, location and use of EEBDs in accommodation spaces. As a consequence, EEBDs are currently being stored in different locations onboard, including alleyways, mess rooms, galleys, navigating bridge, etc, which could cause problems in an emergency.


Lloyd's Register will note the proposal from UK.

Advices to clients


Applicability

The current discussions imply that the requirements will only apply to EEBDs in cargo ships.

Document submitted (these relating to activities of Lloyd’s Register

FP 56/15 (United Kingdom) - Emergency Escape Breathing Devices This document proposes an amendment to SOLAS regulation II-2/13.3.4 concerning the storage, location and use of emergency escape breathing devices within accommodation spaces Return to overall summary at the start of the document


35

Annex 14 - Development of amendments to the requirements for foam- type fire extinguishers in SOLAS regulation II-2/10.5 (Agenda item 16)

Overview

FP 56 will consider the proposal from China (FP 56/16) to delete the requirement under SOLAS regulation II-2/10.5 for a 135ltr extinguisher to be used in boiler rooms. The proposal is supported by fire test data provided (FP 56/INF.6) which indicates that such extinguishers are ineffective on a spray fire that might occur in such spaces, and also point out the operational difficulties involved in fighting a pool fire with such extinguishers. It is also proposed that an approved type of fixed water-based local application fire extinguishing system which is required to be installed in machinery spaces of category A containing boilers as per SOLAS regulation II-2/10.5.6 will provide sufficient fire protection and can fully replace a 135 l foam-type fire extinguisher.

Background

At MSC 89, there was a proposal to review the requirements in SOLAS regulation II-2/10.5 for the arrangements of 135 litre and 45 litre foam-type extinguishers in the engine-rooms and boiler-rooms of cargo ships, based on results of fire tests (spray fire and pool fire respectively), carried out by China, and relevant analysis. The heat release rate of the burner of auxiliary boilers in tankers is generally more than 6MW. The 135 litre foam type extinguisher was tested on a 6MW spray fire (one of the test scenarios as specified by the Guidelines for the approval of fixed water-based local application fire-fighting systems for use in category A machinery spaces (MSC.1/Circ.913)) and the results showed that the test fire could not be extinguished within the period of foam application. In addition, it was concluded that the limited space available in engine rooms would make it impossible to fight a pool fire of heat release rate above 12 MW, normally anticipated in engine rooms. Based on the above results, it was proposed to deleted the carriage requirement of the 135 l foam-type extinguisher in engine-room for cargo ships. It was proposed that the following benefits would accrue from this proposal for cargo ships:

• a considerable reduction of operational costs;

• a considerable reduction of maintenance workload; and

• a considerable contribution to environmental protection due to reduction on treatment of expired foam solution.


Lloyd's Register notes the test data provided, however consider that it should also be clarified, if the amendment is retroactive i.e. if existing ship can remove any 135l extinguishers currently available, including any equivalent provisions which might have been accepted by the Administration (as there have been numerous cases in which extinguisher using different extinguishing media or having different sizes have been installed (DP, or even CO2). In addition, it is noted that a local application system may not be in use in ships of all sizes and ages. LR also recommends to obtain input from operators and ship-owners to understand if the 135 litre extinguisher had actually been used or found of some use to fight fires in boiler areas, or then what they might consider appropriate, as an alternative.

Advices to clients

If the proposal is being agreed, the 135 litre foam type extinguishers need not be provided in engine rooms of cargo ships, which will reduce operational costs for owners/operators, as mentioned above.


36

Applicability

It is proposed that the amendments shall only apply to foam type extinguishers provided in machinery spaces of cargo ships.


FP 56/16 (China) - Proposal to delete the requirement for 135 l foam-type extinguishers in boiler-room and amend the requirement for 45 l foam-type extinguishers in machinery room in cargo ships as required by SOLAS regulation II-2/10.5 This document makes a proposal to amend SOLAS regulation II-2/10 regarding the arrangement of 135 litre foam-type extinguishers in the boiler-rooms based on the results gained from fire tests and relevant analysis FP 56/INF.6 (China)- Information regarding extinguishing tests of foam-type extinguishers This document provides concrete information regarding the extinguishing tests of foam-type extinguishers to extinguish spray fire, flowing fire and pool fire

Return to overall summary at the start of the document


37

Annex 15 - Development of amendments to SOLAS regulation II-2/20 and associated guidance on air quality management for ventilation of closed vehicle spaces, closed ro-ro and special category spaces (Agenda item 17)

Overview

At present, SOLAS regulation II-2/20.3 requires an effective power ventilation system to prevent the build up of flammable vapours in closed vehicle spaces, closed ro-ro spaces and special category spaces. The effective power ventilation system shall be sufficient to provide at least 10 air changes per hour for passenger ships and 6 air changes for cargo ships. The ventilation systems working on the principle of dilution with fixed numbers of air changes consume considerable amounts of energy in ports as well as under way at sea. In the cargo spaces there is no clear indication of the air quality, and consequently the ventilation is normally running continuously at the air change rates as specified in SOLAS. FP 56 will consider proposals from Denmark and the Netherlands (FP 56/17) to amend regulation SOLAS regulation II-2/20.3 to allow the use of an air quality management system as an optional measure to regulate the air flow in closed vehicle spaces, closed ro-ro spaces and special category spaces. The document also proposes amendments to MSC/Circ.729 “Guidelines for the design of ventilation systems in ro-ro cargo spaces” in order to accommodate the requirements of regulation 20.3 of SOLAS chapter II-2. It is proposed that the provision of an air quality management system will reduce emissions from auxiliary machinery, reduce air and noise pollution and also bring a lot of cost savings. The proposals are supported by the data presented in FP 56/INF.2.

Background

The air quality in the region of Rotterdam is poor, especially due to the high concentrations of particulate matter and nitrogen dioxide. The most important sources that contribute to air pollution within this region are traffic, industry and shipping. At MSC 88, The Netherlands submitted a proposal (MSC/88/23/7), to amend SOLAS regulation II-2/20 to include the possibility of air quality management to be used for ventilation in closed vehicle spaces, closed ro-ro spaces and special category spaces. Regulating the airflow by air quality management instead of ventilation via a fixed number of air changes per hour saves energy, results in lower CO2 emissions and reduces noise levels whilst maintaining the high level of fire safety as required in SOLAS chapter II-2.


Lloyd's Register notes that this is a proposal on the safety requirements from environmental protection (air pollution) perspective, i.e., reducing ventilation requirements/ number of air changes to save power and to reduce emissions, subject to the monitoring of air quality in vehicle spaces. Therefore LR supports the proposal noting the benefits such as reduced emissions from auxiliary machinery, reduced air and noise pollution and also cost savings as explained in FP 56/17 and FP 56/INF.2, however consider that as safety is of paramount importance and as in this case it is dependent entirely on the quality of the detectors/air quality management scheme, therefore the minimum specifications, minimum numbers, test standards etc for such systems/detectors would need to be identified/developed.

LR also consider that if new carriage requirements (monitoring device) are introduced as a condition of applying guideline, that should be given in the SOLAS regulation.


38

Advices to clients

The air quality management system works on the principle of detection of CO, NO2 and Lower Explosive Limit (LEL) value and automatic operation of the ventilation. Therefore the costs involved with such detectors may be a consideration. It is also anticipated that IMO may issue clear guidance on the specification and test standards for such devices and it is recommended to closely monitor the developments on this item.


FP 56/17 (Denmark and the Netherlands) - Proposal to amend regulation 20 of SOLAS chapter II-2 and development of associated guidance. This document proposes amendments to regulation 20 of SOLAS chapter II-2 and provides guidance, through a proposed amendment to MSC/Circ.729, on how to use air quality management as an instrument to regulate the air flow in closed vehicle spaces, closed ro-ro spaces and special category spaces. Air quality management results in lower fuel consumption and consequently lower CO2 emissions, and reduces the amount of noise while maintaining at least the same level of fire safety. FP 56/INF.2 (The Netherlands)- Background information relevant to the use of air quality management This document provides background information for the proposal in document FP 56/17 to use air quality management as an instrument to regulate the air flow in closed vehicle spaces, closed ro-ro spaces and special category spaces, and contains the report of a study where the calculation method of Computational Fluid Dynamics (CFD) is used to determine which ventilation rates are considered sufficient in ro-ro cargo areas Return to overall summary at the start of the document


39

Annex 16 - Any other business (Agenda item 20)

Overview

FP 56 will consider several fire and safety related items under this agenda. Some of the major discussion points are as follows: FP 56/20 (IACS)- Fire protection requirements for waste stowage spaces in resolution MEPC.76(40) This document provides information to facilitate the Sub-Committee's task in responding to the request of the Marine Environment Protection Committee (MEPC) to advise both the Maritime Safety Committee (MSC) and MEPC as to whether the survey and certification of fire protection of incinerator spaces and waste stowage spaces as contained in annex A2 to resolution MEPC.76(40) should fall under SOLAS or MARPOL. Overview IACS in response to request of MEPC (MEPC 62/7/6 (IACS)) proposes that the survey and certification of fire protection of incinerator spaces and waste stowage spaces should fall under, and be included in the provisions of, the SOLAS Convention. Lloyd's Register Position: Lloyd's Register can support IACS proposal FP 56/20/1 (Belgium)- Fire test procedures for vertically supported textiles and films This document seeks clarification of the text of the performance criteria for curtains and drapes contained in part 7 of the 2010 FTP Code and proposes an interpretation of paragraph 3.1 of part 7 of annex 1 and appendix 1 to part 7 of the Code Overview Belgium seeks clarification (FP 56/20/1) of the text of the performance criteria for curtains and drapes as contained in part 7 of the 2010 FTP Code. Lloyd's Register Position: Lloyd's Register will observe the discussion as this is a minor issue which could be resolved between the test labs conducting the tests. FP 56/20/2 (Norway)- Typing error in the 2010 FTP Code This document informs the Sub-Committee on what Norway believes is a typing error in the 2010 FTP Code and proposes the issuing of a corrigendum Overview Norway identifies a possible editorial mistake in Part 8 of the 2010 FTP Code, and proposes that this should be corrected to read that non-flame-retardant flexible polyether foam with a density of 22 kg/m3

should be used as the substrate to be used for the test, in accordance with the wording in 1998 version of FTP Code. Lloyd's Register Position: Lloyd's Register can support the proposal from Norway FP 56/20/3 (United States)- Proposed consequential amendments to SOLAS regulation II-2/18.5 and related instruments This document identifies necessary consequential amendments to SOLAS regulation II-2/18.5, the MODU Code, and MSC/Circ.895, for the purpose of harmonizing the requirements for helideck fire-fighting appliances with MSC.1/Circ.1431. Overview The United States proposes to correct a possible drafting error in the new regulations regarding helidecks and identifies additional vessel types which need to be included in the scope of these regulations and propose amendments to relevant instruments to achieve this.


40

Lloyd's Register Position: Lloyd's Register can support the proposal from the United States FP 56/20/4 (United Kingdom)- Non-mandatory instruments Vague provisions of MSC.1/Circ.1270 This document comments on document FP 56/INF.3 regarding the referenced MSC.1/Circ.1371 and through it, MSC.1/Circ.1270 which details the Revised Guidelines for the approval of fixed aerosol fire-extinguishing systems equivalent to fixed gas fire-extinguishing systems, proposing a potential course of action Overview UK has submitted a paper (FP 56/20/4) which is based on a recent assessment by Lloyd's Register, raising concerns on MSC. 1 /Circ. 1270 (Revised Guidelines for the approval of fixed aerosol fire-extinguishing systems equivalent to fixed gas fire-extinguishing systems). The paper notes that there are shortcomings on the extinguishing acceptance criteria for the wood crib tests and also raises questions on the ability of aerosol systems in combating deep seated Class A fires. Lloyd's Register Position: Lloyd's Register supports UK and consider that the anomalies in the test procedure should be resolved to ensure appropriate use of aerosol systems onboard. Other documents submitted under this agenda item for information are as follows FP 56/INF.3 (Secretariat) - Codes, recommendations, guidelines and other non-mandatory instruments The document updates the status of non-mandatory instruments related to the work of the Sub-Committee, as these are listed in MSC.1/Circ.1371 "List of codes, recommendations, guidelines and other safety- and security-related non-mandatory instruments" FP 56/INF.4 (United Kingdom) Information on the European Research Project FIREPROOF-Probabilistic Framework for Onboard Fire Safety This document contains information on the research project FIREPROOF, the objective of which was the development of a risk-based framework for fire safety of passenger ships, which is submitted by the United Kingdom on behalf of the FIREPROOF Consortium FP 56/INF.5 (Japan) Environmental exposure test on fixed fire detection and fire alarm systems for cabin balconies This document contains relevant information of the results of environmental exposure test on fixed fire detection and fire alarm systems for cabin balconies in Japan FP 56/INF.7 (Republic of Korea) - Research on air cylinders and air recharging systems for fire-fighter's outfits This document provides information regarding research on air cylinders and air recharging systems for fire-fighter's outfits on board vessels Return to overall summary at the start of the document


41

Annex 17 - Review of general cargo ship safety (Agenda item 21)

Overview

Following the instruction of MSC 90 (MSC 90/28, paragraph 25.10), the FP 56 Sub-Committee will be invited to consider (RCO) risk control option 28 (measure to prevent fire and explosion accident caused by inadequate repair and maintenance procedures and work during harbour stays) on its feasibility and how to realize them (MSC 90/WP.7, paragraph 20 and annex 4). No formal submissions are available on this agenda item as of 19 December 2012.

Background

At MSC 90, the Working Group on Goal-Based Standards and Formal Safety Assessment was instructed to prepare action plans for the relevant sub-committees to further consider final recommendations (RCOs) included in the IACS's FSA study on General Cargo Ship Safety and advise the Committee accordingly, taking into account document MSC 90/21/1.

Lloyd's Register Position

Lloyd's Register will monitor the developments on this item.

Applicability

This agenda item is related to the safety of General cargo ships; however as the discussions are still at the early stage and no formal submissions have been made to the sub-committee at this time, therefore the scope of the proposals are not clear at this time.

Advices to clients



No submissions on this item as of 20/12/2012 Return to overall summary at the start of the document


42

Annex 18 - Development of interpretation of SOLAS regulation II-2/13.6 on means of escape from ro-ro spaces (Agenda item 22)

Overview

FP 56 will consider the draft interpretation of SOLAS regulation II-2/13.6 on Means of escape from ro-ro spaces as proposed by Sweden (FP 56/22) and supported by data provided in FP 56/INF.8 (Republic of Korea). It is proposed that ro-ro spaces should be considered as a place where crew are normally employed and therefore such spaces should be fitted with at least two means of escape located at the fore and aft ends of the space providing continuous fire shelter (this being defined as a protected internal route with fire integrity and insulation values equivalent to stairway enclosures) to the lifeboat, liferaft and marine escape system embarkation decks.

Background

The current SOLAS regulation II-2/13.6 on means of escape from ro-ro spaces requires that at least two means of escape shall be provided in ro-ro spaces where the crew are normally employed. It further states that the escape routes shall provide a safe escape to the lifeboat and liferaft embarkation decks and shall be located at the fore and aft ends of the space. MSC 90 noted that the terminologies such as "normally employed" and "safe escape" could lead to different interpretations and potentially different levels of safety onboard different ships. Therefore the Committee invited proposals to develop a unified interpretation to ensure consistent implementation of the requirements

Lloyd's Register Position

Lloyd's Register notes the proposals, however consider that the practical difficulties involved in applying the requirements of passenger ships to ro-ro spaces of cargo ships would need careful consideration. For example, the term continuous fire shelter as given in the draft interpretation will be difficult to apply because most RORO cargo ships arrangement will be with the forward escape leading up to the open weather deck. As such, the proposal to apply the last paragraph ‘a protected internal route with fire integrity and insulation values for stairway enclosures’ for the open weather deck route to the lifeboat deck would need to be reconsidered. Lloyd's Register also cannot support retroactive application of these requirements.

Applicability

The requirements will apply to cargo ships fitted with ro-ro spaces.

Advices to clients

The design and arrangements for the escape routes from ro-ro spaces of cargo ships will need to be reviewed. If the proposals are being accepted then the same level of protection as for passenger ships will be required to be provided for cargo ships with ro-ro spaces.


43


FP 56/22 (Sweden) - Proposal for interpretation regarding means of escape from ro-ro spaces on cargo ships This document proposes clarification of SOLAS regulation II-2/13.6 on means of escape from ro-ro spaces on cargo ships. Its aim is to provide a clear understanding and develop a common interpretation of the terms "normally employed" and "safe escape". FP 56/INF.8 (Republic of Korea) - Report on studies on practical application of the regulation in support of interpretation of requirements This document provides information regarding practical application of SOLAS regulation II-2/13.6 in shipyards and shipping companies in order to facilitate the development of clarification on the regulation through findings from studies on the actual application Return to overall summary at the start of the document


44

External Affairs, Lloyd’s Register T +44 (0)20 7423 2962 F +44 (0)20 7423 1564 E [email protected]

Lloyd's Register EMEA T +44 (0)20 7709 9166 F +44 (0)20 7423 2057 E [email protected]

Lloyd's Register Asia T +852 2287 9333 F +852 2526 2921 E [email protected]

Lloyd's Register Americas, Inc. T +1 281 675 3100 F +1 281 675 3139 E [email protected]

71 Fenchurch Street London EC3M 4BS UK

71 Fenchurch Street London EC3M 4BS UK

22nd Floor, Dah Sing Financial Centre 108 Gloucester Road, Wanchai, Hong Kong, SAR of PRC

1330 Enclave Parkway Suite 200 Houston Texas, 77077 USA

Lloyd’s Register is a trading name of Lloyd’s Register Group Limited and its subsidiaries. For further details please see http://www.lr.org/entities © Lloyd's Register Group Limited 2012