Clean Agent Fire Extinguishing System Approval
In order to obtain a certificate of approval (i.e. type approval) for a
Clean Agent Fire Extinguishing System,
compliance with the following criteria is required. The below
criteria determines the equivalency of a new clean agent systems to the
carbon dioxide systems currently specified in the various vessel
regulations, and to the Halon 1301 systems previously approved as
equivalent to carbon dioxide systems.
Approvals are issued only for complete systems made up of
specific components and utilizing specific extinguishing agents.
Approval is not issued for individual system components by themselves,
such as hardware or extinguishing agents.
The agent must be acceptable to the U.S. Environmental Protection
Agency (EPA) for use in occupied spaces under the Significant New
Alternatives Policy (SNAP list).
The agent must be recognized as a fire extinguishing medium by
NFPA Standard #2001 on Clean Agent Fire Extinguishing Systems.
The system must comply with the fire tests in the appendix of the
International Maritime Organization's (IMO) Maritime Safety Committee
Circular 848 (MSC/Circ. 848 -- replacing MSC/Circ.776). The testing
must include the components of the proposed delivery system.
The system must pass an additional fire test (number 1 of MSC
Circ 848) with the agent storage cylinder at the lowest temperature
permitted by the manufacturer.
The system must be designed to meet the intent of the principal
requirements of MSC/Circ.848. Since IMO has not developed complete
acceptance tests and criteria, we require compliance with the
applicable sections of UL Standards 2166 and 2127 (for halocarbon and
inert gas systems, respectively), as well as applicable sections of
NFPA Standard 2001 such as pipe and fitting schedules.
The system must be intended for the protection of Class B hazards
(flammable liquids) in machinery spaces and flammable liquid storage
spaces such as paint lockers.
The pipe flow calculation technique, including computer programs,
must be verified through tests, and listed in accordance with UL 2127
or UL 2166 as appropriate.
The system must be suitable for use in a marine environment. This
includes major components (valves, nozzles, etc.) to be made of brass
or stainless steel, piping to be corrosion resistant (stainless steel
or galvanized), and major components having a melting point of not less
than 927º C (1700º F).
The systems must be listed and labeled for marine use by a Coast
Guard accepted independent testing laboratory. All tests must be
conducted under the control of the laboratory. To be acceptable, the
laboratory, including any government laboratory, must apply, and be
accepted, in accordance with 46 CFR 159.010 prior to conducting any
tests. A laboratory must demonstrate independence and technical
expertise in the evaluation of the fire suppression systems in
accordance with the latter specification.
Finally, the listing organization (laboratory) must:
Control all product evaluation tests and verify the accuracy
and results of all tests.
Identify the limitations of tested systems.
Publish a list of their listed equipment.
Require their name or mark to be printed on the listed
equipment and control the use of the name or mark by limiting it to
Verify that all listed equipment and components are identical
to equipment tested for listing.
Have a follow-up inspection program in place to verify that
equipment and components manufactured in the future are identical to
equipment and components originally tested and currently produced.
Have a follow-up inspection program covering the extinguishing
agent at the agent manufacturer's plant (i.e. a component recognition
Review the design manual and ensure that the system components
shown reflect the components tested, and that limitations stated in the
design manual fully describe the limitations of the system, its uses,
its installation criteria, and its arrangements.
The system must have an associated marine design, installation,
operation and maintenance manual. The manual must be specific to marine
applications and must include the following:
Limitations on nozzle placement and spacing not exceeding that
determined from tests in accordance with IMO MSC/Circ. 848.
Actuation arrangements and controls in accordance with NVIC
6-72, Change 1 and sections of 46 CFR applicable to CO2 systems.
Bulkhead and deck connections and penetrations must be in
accordance with 46 CFR subchapter F and NVIC 9-97.
Identify the applicable design and installation standard(s)
required by paragraph 8 of IMO MSC/Circ. 848. Provide arrangements
complying with the design standard.
Recommended arrangements to address products of thermal
decomposition as required by IMO MSC/Circ. 848 paragraphs 10 and 14.
Recommended arrangements to maintain the agent and hardware
within the allowable storage temperature limits. Identify environmental
exposure limitations of all of the hardware.
Sample marine system design and layout.
Sample computer calculation input and output sheets.
Parts list, preferably in alphabetic or numerical order.
In addition to maintenance and recharge instructions, provide
detailed safety instructions to be followed during periodic testing of
The Coast Guard does not charge a fee for issuing approvals.
However, the manufacturer is expected to reimburse the testing
laboratory directly, and is responsible for all costs associated with
testing and listing the system.
A new installation requirement must conduct door fan tests in order to
show compliance with the intent of IMO MSC/Circ. 848, paragraph 12.