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Clean Agent Fire Extinguishing System Approval Criteria

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.
  1. 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.

  2. 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).

  3. The agent must be recognized as a fire extinguishing medium by NFPA Standard #2001 on Clean Agent Fire Extinguishing Systems.

  4. 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.

  5. 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.

  6. 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.

  7. 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.

  8. 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.

  9. 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).

  10. 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.

  11. 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 listed equipment.
    • 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 program).
    • 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.

  12. 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 system.

  13. 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.

Questions concerning this subject may be directed to the Coast Guard's Lifesaving and Fire Safety Division.

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Last Modified 7/17/2008