Fire
Safety Guidance for Uninspected Towing Vessels
PAGE INDEX:
Introduction
The fire safety regulations in
46 CFR
Part 27 apply to towing vessels that are classified as
uninspected vessels by Part 46 of the Code of Federal Regulations.
Because of this, the required fire protection equipment is not subject
to plan review or inspection for certification by the Coast Guard. This
equipment is inspected during random
boardings, as are currently conducted for life saving and fire
protection equipment on uninspected vessels. The below section contains
guidance to assist operators in complying with the regulations.
General Alarm Systems
The regulations require the installation of a general alarm system,
similar to those required on larger inspected vessels. These alarms are
intended for notifying the crew of an emergency condition. The general
alarm system consists of manual alarm switches or "contact makers"
located in the wheelhouse and alarm bells installed through the
occupied areas of the vessel. When the general alarm sounds, the crew
is to report to their emergency assignments. The new regulations
require a general alarm that can be activated from the wheelhouse,
because it is expected that the master or operator of the vessel will
be the most cognizant of an emergency condition. Additional contact
makers are not required. The general alarm system should be constructed
of marine grade components, but there is no requirement that they be
approved equipment. The wiring for the system should follow good marine
practice, but it does not need to comply with the electrical
engineering regulations listed in 46 CFR 110-113. The general alarm
system is not required to meet any design criteria or performance
specifications,
other than it must be audible throughout the occupied areas. In the
engine room, the alarm bells must be supplemented by a flashing red
light to ensure that the crew will notice the alarm when the engine is
running. Although not required by the regulations, 46 CFR 113.25
may be used as guidance in the design and specification of the system.
Fire Detection Systems
Coast Guard approved fire detection systems and equipment complying
with 46 CFR 161.002 [TEXT] [PDF], as well as, non-Coast Guard approved
fire detection systems meeting the criteria listed in 46 CFR 27.203 are
acceptable. The regulations also permit towing vessels
contracted for before January 18, 2000 to use an engine room monitoring
system to comply with the requirement for fire detection
capability. Engine room monitoring systems have been proven
reliable through actual field experience and are considered an
acceptable substitute for a stand-alone detection system on existing
vessels. If an existing engine room monitoring system is
installed that has fire detection capability, but does not have all of
the alarm or indication features required by the new part 27, it may be
modified to meet the rule.
Non-Coast Guard approved detection equipment must be Underwriters
Laboratories (UL) listed or Factory Mutual (FM) approved, and installed
in accordance with the manufacturer's approved design manual. The
approved design manuals will also require that the installation comply
with the criteria listed in National Fire Protection Association
standard 72 (NFPA 72). The installer may use either heat detectors,
smoke detectors, or a combination of the two. Optical flame detectors
could also be used. Detector location and spacing in the engine room
should be in accordance with the manufacturer's approved design manual
and should also comply with the criteria contained in NFPA 72. A
Registered Professional Engineer (PE) or a classification society such
as ABS must certify that the installation satisfies 46 CFR 27.203.
Drawings and specifications for the detection system should not be
submitted to the Coast Guard for review. The Coast Guard has determined
that a certification process is necessary because towing vessels are
uninspected vessels, meaning that they are not normally inspected by
the Coast Guard. It is therefore necessary to have a Professional
Engineer or classification society inspect the system to confirm that
the installation follows good marine practice and is in conformance
with part 27. The certification report for the system should
be maintained onboard the vessel for the review of Coast Guard
inspectors during random boardings.
The regulations require the fire detection system only for the
protection of the engine room. Owner / operators are encouraged to
consider extending the system to other areas. Our historical casualty
review indicated that following the engine room, the galley is the
second most likely area to suffer a fire. Heat detection in this area
is considered a prudent investment. Manual pull stations that would
allow the crew to manually activate the system may also be desirable.
These stations should be located in main passageways and by the exit
from the engine room.
Fire Detection System Certification
Guidance
46 CFR 27.203 (g) specifies that a towing vessel engine room fire
detection system must be certified by a Professional Engineer or a
Classification Society as complying with 27.203 (a) through (f). The
following information is suggested certification guidance.
1. The engineer performing the certification should be working within
their area of expertise as an engineer. This means that the person
should either be a fire protection engineer or an electrical engineer
or a marine engineer with experience in detection systems. The person
should be familiar with fire alarm systems and marine electrical
systems.
2. 46 CFR 27.203 (a) allows three optional types of detection systems.
Existing systems are acceptable and need not be replaced if they meet
the required criteria:
-
Option one is a Coast Guard approved
system that has been type approved under 46 CFR 161.002. These are
systems generally used on larger vessels where a significant number of
detectors are needed. They should be installed in accordance with their
USCG approved design manual.
-
Option two is the use of a fire alarm system that is UL listed
or FM
approved. This is the type of fire alarm system commonly installed in
buildings. These systems are not specifically approved for marine use,
and are designed to be installed in accordance with the guidance in
NFPA 72 and their manufacturer's design manual.
-
The third option is a hybrid system that consists of an existing
fire
detection system that is combined with an engine room monitoring
system. The only guidance for these types of systems is that listed in
27.203. This option was provided to allow existing vessels to continue
using these types of systems, provided they have the minimum fire
detection features specified in 27.203. In cases where the required
alarm and indication criteria or other features are not strictly met,
the system can be modified accordingly. In the case where an existing
engine room monitoring system does not have fire detection capability,
a separate fire detection system should be installed.
The detectors used in either of the three optional systems may be heat
detectors, smoke detectors, or a combination, appropriate to the
installation. All detectors should be approved by an independent
laboratory (UL listed or FM approved).
3. 46 CFR 27.203 (b) states that the system is to be installed, tested
and maintained in accordance with the manufacturer's design manual. The
USCG expects that the certification would encompass all three aspects.
The engineer should:
a. verify that the fire detection
system is designed in accordance with
its listing and manufacturer’s design requirements:
- USCG approved systems should be designed in accordance with the
Coast Guard approved design manual.
- Listed systems should be designed in accordance with their UL
listing or FM approval and manufacturer’s design manual.
- Engine room monitoring systems should be designed in accordance
with any criteria provided by the manufacturer, plus, the location and
spacing of detectors should satisfy NFPA 72 and their laboratory
approval.
b. verify that the detectors have been properly installed. The most
important aspect of the installation is to ensure that the detectors
are properly located to rapidly detect expected fires, without causing
excessive false alarms. NFPA 72 may be consulted for guidance in regard
to detector spacing and location. Important features to check include
the location of the detectors below the ceiling or overhead, the
location of detectors with regard to engine exhausts, ventilation
outlets and intake manifold openings.
c. verify that the system has been installed using acceptable wiring
practices. Towing vessels are uninspected vessels. They do not have to
comply with the USCG Electrical Engineering rules listed in 46 CFR
110-113, Subchapter J. These rules may however be used for guidance.
Sections of NFPA 72 and the National Electric Code may also be used for
guidance, however, to ensure that the system will function in the
marine environment, the wiring practices used to connect the system
panels and devices should be appropriate for the vibration common to
vessel engine rooms. IEEE 45 provides specialized guidance on shipboard
wiring practices.
d. perform functional testing as necessary to confirm that the system
is operational. Each device should be tested to ensure that it sounds
the appropriate alarm on the control panel. A fire alarm signal should
provide a general audible alarm at the panel and visible indication of
the affected zone.
4. 46 CFR 27.203 (e) contains the requirements for main and emergency
power for the system. Generally it is expected that the ship's service
generator will be the main power supply and a dedicated battery in the
fire alarm control panel will be the back-up. Acceptable guidance on
the minimum battery capacity can be found in NFPA 72. The battery
should have sufficient capacity to power the system in a non-alarm mode
for at least 24 hours and then be capable of powering all connected
devices for 5 minutes. This feature can be verified by either checking
calculations or by actual testing of the system. On some vessels, the
backup power supply could be another generator or battery system,
provided the backup system would not be affected by a fire in the
engine room.
5. The engineer should provide the owner of the vessel with a letter
report that details the equipment installed on the vessel, summarizes
the review performed and certifies that the system installation is in
conformance with 46 CFR 27.203. The report should be maintained onboard
the vessel for future reference. It is not necessary to send copies of
the report to the Coast Guard.
Internal Communication Systems
The regulations require the installation of a system that allows
communications between the wheelhouse and the engine room. During an
engine room fire emergency, it is necessary for the master or operator
to co-ordinate the navigation of the vessel with the operation of the
machinery, and the fire fighting efforts. Twin screw vessels that have
controls for both engines in the wheel house are exempt from this
requirement.
The regulations allow a wide range in the manner of communication
selected. A sound powered telephone system is the preferred type of
system, however, hand-held radios or an intercom could be substituted
if the system has a secondary power supply that permits it use if
normal power is unavailable. The communications system should link the
navigating bridge to the engine room control booth, or alternatively to
a convenient location near the engine room exit door. As with the
requirements for a general alarm system, the internal communications
system is not required to be approved equipment.
On small vessels, a communications system is not required if the engine
room door is within 3 meters (10 feet) of the navigating bridge, and
the crew can maintain direct visual contact. In this situation, it is
reasonable to expect that the crew will be able to communicate without
electronic assistance.
Fuel Shutoff Valves
Remote fuel shutoff valves are required on all fuel lines that supply
an engine or generator. Generally a single valve can be installed
at the outlet of the day tank or at the fuel supply manifold to satisfy
this requirement. The valve must be fitted with a remote operator
such as a reach rod or steel pull cable to allow the crew to close the
valve from a safe location in the event of an engine room fire.
Although the regulations refer to a "positive shut-off valve",
retro-fit compliance with 46 CFR 56.20-15 is not intended. The
regulations do not specify any material requirements for the fuel
shutoff valve. As a minimum, it should be steel or other non-heat
sensitive material. Although not required, 46 CFR 56.20 may be used as
guidance in the selection of newly installed valves.
Existing valves can be modified by the installation of a suitable reach
rod. The remote operator for the valve must be
capable of functioning if there is a fire in the engine room. The
remote operator should be a reach rod or similar mechanical device.
Electronic or pneumatic operators will not satisfy this provision. The
regulations require that a sign be posted near the valve
explaining the function of the valve and the direction to turn it to
open or close it.
The regulations specify that the fuel shutoff valve should be located
"at" the tank or manifold. On existing vessels, it may not be possible
to locate the valve adjacent to the tank. The regulations do not
specify an allowable distance between the fuel tank and the valve. On
existing vessels, this distance should be minimized to reduce the
chances of fire damage to the intervening piping. If it is necessary to
locate the valve away from the tank, it will be necessary for the owner
/ operator to demonstrate that an equivalent level of protection is
provided. One method of providing equivalent protection is to install
Extra-Heavy Schedule piping with all welded connections between the
tank and the valve.
A single valve installed in the main fuel piping where it connects to
the fuel tank will satisfy the regulations. If the vessel has twin
engines, this will cause both of the engines to stop when the valve is
closed. If it is desirable to retain the capability to operate one
engine when the other is stopped, then a manifold with two separate
fuel shutoff valves could be installed, provided the piping between the
manifold and the tank is designed to afford an equivalent level of
protection.
Instructions, Drills, and Safety
Orientation
The regulations require that the master or person in charge conduct
monthly training. These drills are intended to familiarize the crew
with the location and operation of the specific safety equipment
installed onboard their vessels. The drills are also important to show
the crewmembers what their duties are in the event of a fire. The
regulations do not require the crewmembers to attend a USCG approved
fire school.
During drills, the master or other qualified trainer is expected to
instruct the crew in the operation of the fire protection equipment
installed onboard the vessel. For engine room fires, this should
include information on how to stop the machinery space ventilation
system and secure open ventilators. It must also include demonstration
of how to operate the remote fuel shutoff valve and sound the general
alarm. If a fixed fire extinguishing system is installed, the drills
must show the crewmembers how to discharge the system. The operation of
any additional equipment, such as breathing apparatus, that is carried
onboard the vessel should be included in regularly scheduled drills.
The location of the monthly fire drills should be varied to eventually
cover all areas on the vessel. During these drills, the crew should
evaluate equipment limitations or other problems that may be
encountered during an actual fire in that location. The drills should
also address potential problems from transporting differing cargoes or
traveling differing routes. As noted in the rule, video tapes may be
used to instruct the crew, however, participation in actual drills is
still required on a monthly basis. A variety of basic fire-fighting
training manuals and videos are available from commercial sources.
Maintaining an updated onboard library of these materials is
recommended.
New crewmembers must undergo a safety orientation before working on the
vessel for the first time. This orientation should include a review of
basic fire response procedures, the crewmembers duties during an
emergency, how to operate the fire protection equipment installed on
the vessel, and instruction on how to operate the fuel shutoffs and
ventilation controls.
Fire Suppression Requirements
All towing vessels in ocean or coastal service whose construction is
contracted for on or after August 27, 2003 must have a fixed fire
extinguishing system for the protection of their engine rooms. They
must also carry a USCG approved B-V fire extinguisher.
The regulations permit the use of any one of three types of fixed
fire-extinguishing systems. By allowing a choice among the three,
towing vessel operators are able to select a form of protection that is
best suited to their vessels. Acceptable systems are: approved total
flooding carbon dioxide systems designed in accordance with 46 CFR
76.15; clean agent systems such as FM-200 or Inergen that are
USCG type approved; and approved water mist systems that are designed
in accordance with the Marine chapter of NFPA 750. The water mist
system requirements have been specially formulated for towing vessels
and are based on the use of a local application network of nozzles with
a self-contained 10 minute supply of water.
By April 29, 2005, all towing vessels regardless of service must have a
fire pump with fire hoses and hydrants as specified by 46 CFR
27.301. The fire pump system can be either a fixed power-driven
pump with an installed fire main and hydrants, or a portable pump may
be used to meet this requirement. If a portable pump and hoses
are used, they must be stowed outside the engine room. The pump must be
capable of supplying 1-1/2 inch (40 mm) diameter fire hose at a flow
rate of at least 80 gpm (300 lpm) with a nozzle pressure of at least 50
psi (344 kPa). If a portable pump is used, the pump must be
capable of a discharge pressure of 60 psi (414 kPa) measured at the
discharge outlet of the pump.
By April 29, 2005, all towing vessels regardless of service whose
construction was contracted for before August 27, 2003 must also carry
a USCG approved B-V semi-portable fire extinguisher for the protection
of the engine room. B-V fire extinguishers are available in a variety
of sizes and with different types of extinguishing agents.
Because of their larger size, these extinguishers have a connected hose
used to discharge the agent. The minimum approved sizes are: foam
– 40 gallons; carbon dioxide – 100 lbs; dry chemical – 50 lbs. A
fixed fire extinguishing system may be installed for the protection of
the engine room in lieu of the required B-V semi-portable extinguisher
on vessels contracted for before August 27, 2003.
Existing fixed fire extinguishing systems may be used to satisfy the
requirement for a fixed suppression system, if the operator can
demonstrate that the system has been designed and maintained in
accordance with USCG approval criteria. Certification by a
Registered Professional Engineer or by a classification society that
the system meets appropriate design criteria is one acceptable method
of demonstrating compliance.