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Fire Safety Guidance for Uninspected Towing Vessels



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:

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:

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.

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Last Modified 5/9/2012