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Structural Fire Protection Materials

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APPROVAL GUIDANCE

SOLAS or CFR Standards
Structural fire protection materials may be submitted for approval under two different regulatory standards: 1) Safety of Life at Sea (SOLAS) or 2) Code of Federal Regulations (CFR). The structural fire protection material approved under SOLAS standards may be used on U.S. flag vessels going on either international or domestic voyages. Those materials approved to the standards in 46 CFR are restricted for use on U.S. flag vessels that only operate on domestic voyages. While the two systems use different test standards, the tests must be performed by an independent testing laboratory acceptable to the U.S. Coast Guard for those tests. If the material meets the appropriate test criteria and follow-up services to the satisfaction of the Coast Guard, the manufacturer will be provided with a Certificate of Approval; the approval will also be listed on the Coast Guard’s Approved Equipment website which is updated on a weekly basis: http://cgmix.uscg.mil/Equipment/. This information is used by shipyards and others in specifying/selecting approved materials for ship construction. See DOMESTIC STRUCTURAL FIRE PROTECTION MATERIALS or INTERNATIONAL STRUCTURAL FIRE PROTECTION MATERIALS for more information and how to receive approval of structural fire protection material under the two regulatory standards.

In addition, there are fire protection materials and arrangements that are not specifically covered by the CFR or SOLAS, but do have to meet a safety standard to be installed on board a Coast Guard inspected vessel. See RELATED FIRE PROTECTION MATERIALS for more information on this.

Navigation and Vessels Inspection Circulars (NVICs)
The Coast Guard periodically issues NVICs. These documents, while not regulations themselves, are intended to explain the regulations and provide guidance as well as examples of accepted constructions. NVIC 9-97 (replaces NVIC 6-80) explains the Coast Guard’s structural fire protection program in greater detail.

RELATED FIRE PROTECTION MATERIALS

ACOUSTIC AND THERMAL INSULATION	DECK FINISH EXEMPTION	NONCOMBUSTIBLE CEILINGS (C-CLASS)
ALUMINUM CONSTRUCTION	FLOOR FINISHES	NON-LOAD BEARING INTERNAL DIVISION
ASBESTOS	MODULAR ACCOMMODATION QUARTERS	PAINT

Note: These materials do not have approval numbers, and are not covered by the Mutual Recognition Agreement.

ACOUSTIC AND THERMAL INSULATION: The CFRs contain no performance requirements for acoustic and thermal (i.e. comfort) insulation. However, all acoustic and thermal insulation materials must meet the applicable fire safety requirements such as non combustibility.

ALUMINUM CONSTRUCTION: Aluminum bulkheads and decks can generally be insulated to A-60 by using materials tested and approved for steel bulkheads and decks. The procedure is explained in Technical and Research Bulletin 2-21, entitled "Aluminum Fire Protection Guidelines," published by The Society of Naval Architects and Marine Engineers (SNAME), 601 Pavonia Ave. Jersey City, NJ 07306. Also, NVIC 9-97 provides a summary of Coast Guard requirements. However, some specific materials and designs such as sprayed fiber insulation and continuous ceilings can not be used with aluminum unless specifically tested and approved for use with aluminum construction. SNAME Bulletin 2-21 can not be used to calculate aluminum construction for SOLAS vessels. Instead, the aluminum constructions must be tested to IMO Res. A. 754(18).

ASBESTOS: Although neither Title 46 of the CFRs or SOLAS treaty specifically prohibits asbestos, the U. S. Coast Guard does not approve structural fire protection materials containing asbestos fibers.

DECK FINISH EXEMPTION: The Code of Federal Regulations permits the use of unapproved deck leveling and finishing material which do not exceed 3/8 inch (9.5 mm) in thickness. SOLAS does not contain this exemption.

FLOOR FINISHES: Under the CFR, these must be approved either as deck coverings under 164.006, or as noncombustible materials under 164.009. Under SOLAS, they must meet the IMO Fire Test Procedures (FTP Code).

MODULAR ACCOMMODATION QUARTERS: The Coast Guard does not have a program of type approving complete accommodation systems for fire safety. Instead, the various structural fire protection elements (bulkhead panels, ceiling, insulation, etc.) of which the system is constructed are approved separately under their individual approval categories. This subject is not currently addressed in the FTP Code.

NONCOMBUSTIBLE CEILINGS (C-CLASS): The U. S. Coast Guard does not issue type approval for noncombustible ceilings and other C Class partitions because C-Class partitions are not required to be tested for fire resistance. The only requirement is that ceilings must be constructed of approved noncombustible materials.

NON-LOAD BEARING INTERNAL DIVISION: A recent IMO interpretation permits light-weight construction such as honeycomb panels of steel or equivalent material to be used as non load-bearing internal "A" class division in accommodation and service spaces provided they have been tested to the FTP Code criteria for a one hour period. These panels are constructed of thin metal sheets bonded to an insulated core material and do not have a 4-mm steel core plate. The use of lightweight construction cannot be used as an integral part of main fire zone bulkheads and stairway enclosures on passenger ships.

PAINT: The CFR permits a limited number of coats of standard paint are permitted without requiring tests or approval. Nitrocellulose or other highly flammable or noxious fume-producing paints or lacquers are prohibited. The SOLAS treaty requires paint in certain spaces to meet low flammability, smoke, and toxicity criteria.

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Last Modified 7/31/2008