Requirements for ships carrying hydrogen and compressed natural gas vehicles

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1 Lloyd's Register briefing IMO FP 55 Summary report for clients Overview The 55 th session of the IMO Fire Protection Sub Committee (FP) was held from 25 th to 29 th July 2011, at the IMO headquarters in London. This briefing provides a summary of discussions relevant to Lloyd's Register and its clients. Major issues discussed: FSS Code amendments finalised at this session (refer to annex 1) Guidelines for the approval of helicopter facility foam fire fighting appliances (refer to annex 1) Guidelines for the approval of fixed water-based fire fighting systems for ro-ro spaces and special category spaces (refer to annex 1) Requirements for ships carrying hydrogen and compressed natural gas vehicles Inerting of small chemical and oil tankers below 20,000 deadweight (dwt) Fire fighting requirements for on-deck cargo areas Means of Escape from Machinery Space Use of Fibre Reinforced Plastic (FRP) within Ship Structures Performance testing and approval standards for fire safety systems (agenda item 3) FSS Code amendments and non mandatory guidelines Background: Amendments to the FSS Code chapters 3, 5, 8, 9, 12, 13 and 14 have been under review at IMO FP Subcommittee. In addition, FP has been developing amendments to the Guidelines for the approval of fixed water-based fire fighting systems for ro-ro spaces and special category spaces (A.123 (V)), Guidelines for the approval of helicopter facility foam fire fighting appliances and Guidelines for the maintenance and inspection of fire-protection systems and appliances. FP 55 finalised FSS Code amendments for chapters 3, 5, 8, 9, 12, 13 and 14. The mandatory items finalised at this session are given below and will be submitted to MSC 90 (May 2012) for approval. Main FSS Code amendments finalised at this session: 1. Chapter 3 Fire-fighters outfits the chapter was amended to introduce requirements for fitting of a low pressure warning alarm in the breathing apparatus. 2. Chapter 5 Fixed gas fire extinguishing system the chapter was amended to include clarification of the spaces to be protected by carbon dioxide system and also to introduce unified interpretations contained in MSC./Circ.1120 that are relevant to this chapter. 3. Chapter 6 Fixed foam fire-extinguishing systems FP 55 agreed to recommend MSC 90 that the amendments approved by MSC 88 for chapter 6 should be further modified specifically to limit the relaxation of systems protecting vehicle, ro-ro spaces and special category spaces with a deck height of 3 metres or less, only if the decks are gas tight. 4. Chapter 9 Fixed fire detection and fire alarm system this chapter was amended to clarify the location of the control panel and indicating unit in cargo ships. In addition, reference to IEC standard IEC was introduced.

2 5. Chapter 14 Fixed deck foam fire-extinguishing systems The whole chapter has been replaced by the amendments finalised at FP 55, mainly to clarify foam solution and foam concentrate component requirements for tankers. 6. MSC./Circ.1120 Unified interpretations relevant to the FSS Code chapters 3, 5, 8, 9, 12, 13 and 14 were also introduced as amendments to the Code. Non-mandatory guidelines finalised at this session; 1. Guidelines for the approval of fixed water-based fire fighting systems for ro-ro spaces and special category spaces. (Supersedes A.123 (V) and MSC.1/Circ1272). 2. Guidelines for the approval of helicopter facility foam fire fighting appliances. 3. Guidelines for the maintenance and inspection of fire-protection systems and appliances (supersedes MSC/Circ.850) applicable to all ships. These guidelines provide minimum recommended levels of maintenance and inspections for fire-protection systems and appliances, but do not address maintenance and inspection of fixed carbon dioxide systems (see MSC.1/Circ.1318) or portable fire extinguishers (see resolution A.951 (23)). For further detail on the application of the amendments to the FSS Code refer to Annex 1 of this document. For the list of MSC Circulars/Resolution finalised at FP 55 under agenda item 3 refer to Annex 2 of this document. Requirements for ships carrying hydrogen and compressed natural gas vehicles (agenda item 4) Background: In the past 3 years IMO has been exploring new safety measures that can be introduced in the SOLAS Convention to cover transport of vehicles powered by hydrogen and compressed natural gas. The scope of this proposal was understood to cover new pure car carriers only. At FP 55, a proposal to amend SOLAS regulation II-2/20 (protection of vehicle, special category and ro-ro spaces) was put forward to address safety concerns of ships carrying such vehicles. However, while discussing this item some expressed concerns that by amending regulation 20 the new requirements will be applicable to ro-ro passenger ships as well, which was not the intention of the original proposal. At the same time, there were views in favour of considering expanding the new safety measures to cover other type of ships carrying such vehicles. FP 55 decided to request MSC 90 (May 2012) to clarify the scope of this item and to confirm whether the measures should be developed for new pure car carriers or if should cover other types of ships including existing ships. Safety measures discussed: Use of safe type equipment in accordance with IEC (Type IIC, T3 for compressed hydrogen vehicles and IIA, T3 for compressed natural gas vehicles); exhaust fans of non- sparking type and suitable wire mesh guards; All electrical equipment and wiring should be of a type suitable for use in an explosive hydrogen and air mixture. Use of portable gas detectors Increased the amount of carbon dioxide for fixed fire extinguishing system. FP 55 agreed to continue discussing the draft amendments at FP 56 (July 2012) and the application of the requirements to other types of ships will depend on the decision to be made at MSC 90. Implications Builder/Designer: builder/designers should be aware of the new requirements being developed for the carriage of compressed natural gas vehicles and hydrogen vehicles, when designing ships that may carried such vehicles. It is to be noted that the types of ships to which the amendments will applied will be decided by MSC 90 in May Shipowners/manager:

3 The extend of application of these requirements for existing ships is still uncertain; however owners of ships that may carried such vehicles, should aware of the new developments. The identification or declaration, on board, of such vehicles is a challenge that has not been addressed at this stage. Further impact will be dictated by MSC 90 decision, on application to other ship types and existing ships (e.g. ro-ro passenger ships). When the amendments are approved new ships carrying such vehicles will have to comply with additional safety requirements such as portable gas detectors, safetype electrics, safe-type ventilation arrangements and increased quantities of extinguishing medium for fixed CO2 fireextinguishing systems. Application: type of ships (new and existing) is to be confirmed. (Ships carrying compress hydrogen and natural gas vehicles). For new ships the date of application will be based on keel laid date. Inerting of chemical and oil tankers, below 20,000 (dwt), that transport low flash point cargoes (agenda item 6) Background: Following several tankers explosions, IMO has being discussing applying inert gas systems requirements to new oil and chemical tankers below current limit of 20,000 deadweight. FP55 prepared draft SOLAS amendments to mandate fitting of inert gas systems (SOLAS II-2/4.5.5). A lower application limit, the use of alternative arrangements, and the medium to be used for inerting were discussed. The following were the primary points of agreement: FP 55 agreed to a lower limit of (dwt) applicable to new oil and chemical tankers, carrying low flash point cargoes, constructed (keel laid) on or after 1 January Nitrogen was agreed as the only medium to be used for inerting cargoes on chemical tankers. Under SOLAS amendments requirements for equivalent systems in lieu of fixed inert gas systems installations will be permitted on tankers between 8,000 dwt and 20,000 dwt. For chemical tankers inert gas system in compliance with the Fire Safety Systems Code may be replaced by other requirements currently been developed by IMO (Guidelines). FP 55 agreed that inerting of cargo tanks after loading was an operational matter. The draft amendments are going to be finalised at FP 56 (July 2012). Application: Applicable to new oil and chemical tankers, carrying low flash point cargoes, constructed (keel laid) on or after 1 January 2015 Implications Owner/Builder: Even though the requirements are coming into force in 3 years time, it is advisable that owners and builders should take into account the developments of these requirements when negotiating new building contracts, since the application date is based on keel lay date. Fire fighting requirements for on-deck cargo areas (agenda item 11) Background: Deck fire fighting requirements on containerships, even mega containerships, are considered insufficient. Therefore, it has been proposed to increase fire main and fire pumps capacity, pressure at hydrants and number of hydrants on deck to increase fire fighting capabilities to allow the use of additional fire fighting equipments such as portable water cannon on a voluntary basis. FP 55 considered the draft amendments, however, could not agreed on them until further discussions, because the text as drafted did not appropriately address containerships and application to new ships only. The current text was rather imposing unnecessary requirements to other types of cargo ships.

4 Implications: Owner/Builder: Builders/Owners it is likely that fire fighting capabilities on deck will be increased and there will be a potential to carry dedicated fire fighting equipments once the amendments are approved. Application: The requirements are most likely to be applicable to new container ships. Final application will be confirmed when the amendments are approved. SOLAS amendments to regulation II-2/ and addressing means of escape from machinery space (agenda item 10) Background: FP has been considering a need for having a common approach to the escape requirements from machinery control rooms for both passenger and cargo ships. At FP55, it was proposed that in addition to this common approach, escape facilities from other enclosed spaces other than machinery control rooms within machinery spaces of category A should also be addressed in both cargo ships and passenger ships. It was suggested the escape routes should apply to: workshops and machinery control room; other enclosed spaces used for longer periods throughout the day, e.g., during maintenance/repair work; and enclosed spaces where daily rounds of inspection/fire patrols, are necessary. It was proposed to amend SOLAS regulation II-2/ (cargo ships) in line with the proposed amendments to SOLAS regulation II-2/ for passenger ships (including the control rooms escape requirements). In addition, the escape routes ladders from engine rooms should be fitted with protection against heat and flame from beneath and should be made of steel to protect crew members. A final amendment could not be agreed at this stage and FP 55 decided to postpone discussions until FP 56 (July 2012). Application: The outcome of these amendments will apply to new cargo and passenger ships only. Implication: Owner/Builder: When amendments are finalised, possible design changes affecting engine rooms on cargo and passenger ships are envisaged. Use of Fibre Reinforced Plastic (FRP) within Ship Structures (agenda item 19) Background: The use of FRP contradicts a number of prescriptive provisions in the SOLAS Convention, where the structure and divisions of the vessels are required to be made of non-combustible materials. Therefore, currently is not allowed under regulation II-2/3.43. However, the need for further guidance regarding standards to be applied where FRP is being used to replace steel or other equivalent material was presented to MSC 87 by a Flag Administration that received proposals to build major parts of a ship structure in FRP. It is to be noted that a deviation from the requirements for materials may be addressed by an alternative design methodology, as described in SOLAS regulation II-2/17, to demonstrate compliance with the fire safety objectives and the functional requirements as set out in SOLAS chapter II-2, parts B (prevention of fire and explosion), C (suppression of fire), D (Escape), E (Operational requirements) and G (special requirements). When evaluating the proposals to use FRPs under SOLAS regulation II-2/17, this Flag Administration identified some difficulties in appraising the designs and as such presented a recommendation to MSC 87 to develop guidelines for use of FRP within ship structures.

5 Despite the innovative idea, the majority of views expressed at FP 55 were conservative and major shipping countries and NGOs raised concerns on the use of this material and also on the problems for its recycling. IMO will continue to explore possible solutions at next DE 56 and FP 56. Implications: The outcome at FP 55 may be a set back for any further developments on the application of this technology in the ship industry. What is LR doing? Following the above decisions made by FP 55, Lloyd s Register will be preparing Classification News to advise clients of the amendments to mandatory requirements agreed at this session, as applicable. Clients, who wish to have more information, please contact local Lloyd s Register office.

6 Lloyd's Register briefing IMO FP 55 Annex 1 - Performance Testing and Approval Standards for Fire Safety Systems (agenda item 3) FSS Code - amendments to mandatory instrument agreed at this session: 1. Chapter 3 - Fire fighters outfits. Chapter 3 was amendment to introduced fitting of low pressure warning alarm in the breathing apparatus (paragraph 2.1.2). FP 55 agreed that a breathing apparatus should be fitted with an audible alarm and a visual or other device which would alert the user before the volume of the air in the cylinder has been reduced to no less than 200 litres. This is the only amendment to the FSS Code agreed at FP 55 that will be applied retrospectively. Application new ships - the warning alarm should apply to ships constructed on or after the date of entry into force of the expected amendment. Application existing ships - Ships constructed before the date of entry into force should comply with the revised requirements five (5) years after the date of entry into force. Advice for clients: Builders/ designers/ manufacturers: The new requirement will pose stricter approval arrangements of the breathing apparatus equipment. This may result in a small cost increase. Owners: Update training and operational procedures. In addition, training may be required for crews who have not used this BA equipment before. Advice for Flag Administrations and Recognized Organizations: Flag and ROs to ensure the requirement is met for new ships and existing ships when the amendment enters into force. 2. Chapter 5 Fixed gas fire extinguishing system Various amendments were introduced and in particular to clarify that the spaces to be protected by carbon dioxide system (paragraph ) are the same spaces refer to on the interpretation of paragraph contain in MSC.1/Circ To make it simple, paragraph was modified to include that means shall be provided for automatically giving audible and visual warning of the release of fire-extinguishing medium into any ro-ro spaces, container holds equipped with integral reefer containers, spaces accessible by doors or hatches, and other spaces in which personnel normally work or to which they have access." Unified interpretations contained in MSC/Circ.1120 were also included into Chapter 5, paragraph and Application: to new cargo ships of 500 gross tonnage and above, and passenger ships irrespective of tonnage. Advice for clients: Shipbuilders: FSS Code, chapter 5, should be applied in a consistent manner. Owners and managers: Same as builders Flag Administrations and Recognized Organizations: Same as builders 3. Chapter 6 Foam generating capacity of fixed high expansion foam fire-extinguishing system for the protection of vehicle, ro-ro, special category and cargo spaces (paragraph and ). Noticing that these amendments are only pending adoption by MSC 90, FP 55 agreed to recommend MSC 90 to limit the relaxation for decks that are reasonably gas-tight as mentioned in the draft text of Chapter 6 paragraph and FP 55 recommended replacing the existing draft for the following text: (Annex 1 - Performance Testing and Approval Standards for Fire Safety Systems)

7 Sufficient foam-generating capacity shall be provided to ensure the minimum design filling rate for the system is met and in addition shall be adequate to completely fill the largest protected space within 10 min. However, for systems protecting vehicle and ro-ro spaces and special category spaces, with decks that are reasonably gas-tight and that have a deck height of 3 metres or less, the filling rate shall be not less than two-thirds of the design filling rate and in addition sufficient to fill the largest protected space within 10 min. Implications: These amendments will affect all new Ro-Ro vessels. 4. Chapter 9 Fixed fire detection and fire alarm system Paragraph , was amended to indicate that in ships with cargo control room, an additional indicating unit shall be located in the cargo control room. This text was introduced to clarify the intention of the previous amendments adopted by resolution MSC. 311(88). Application: new cargo vessels which have a cargo control room will be affected. Reference to standard IEC were replaced by IEC in chapter 9. In addition, recognizing the need for an interpretation by the time this draft amendment enter into force, FP 55 agreed to issue a unified interpretation to indicate the changes in reference. Amendments covering the operation of automatic changeover switch and the use of batteries of adequate capacity to ensure continuous changeover operation to avoid loss of fire detection capabilities were introduced. Paragraph , is amendment to indicate that detectors installed within cold spaces such as refrigerated compartments shall be tested using procedures having due regard for such locations. Advice for clients: Shipbuilders: FSS Code, chapter 9, should be applied in a consistent manner. Owners and managers: Same as builders Flag Administrations and Recognized Organizations: Same as builders 5. Chapter 14 - Fixed deck foam fire-extinguishing systems The amendments include a clarification of the rate of supply of foam solution and foam concentration needed on tankers as indicated by the carriage requirements of SOLAS II-2 and the IBC Code. In addition, additional foam concentrate is to be provided if the deck foam system is supplied by a common line from the fire main. It is clarified in Chapter 14 that for tankers carrying chemicals in bulk listed in chapter 17 and 18 of the IBC Code having a flashpoint not exceeding 60ºC (closed cup), the rate of supply of foam solution shall be as required by the IBC Code. Chapter 14 describe when type B foam concentrates and type A foam concentrates shall be applied and also prescribes that foam concentrate supplied on board shall be approved by the Administration for the cargoes intended to be carried. Application: to new oil and chemical tankers. Advice for clients: Owners and builders should be aware of the new requirements to ensure the FSS Code is being uniformly applied. 6. MSC/Circ.1120 (Unified interpretations). In addition to the amendments mentioned above, FP 55 agreed to introduce unified interpretations contained in MSC/Circ.1120 relevant to the FSS Code in Chapters 3, 5, 8, 9, 12, 13, and 14. The unified interpretations contained in such circular are widely used. Application: new cargo ships of 500 gross tonnage and above, and passenger ships irrespective of tonnage Advice for clients: There should not be impact to the current practice. Non mandatory circulars agreed at this session: 1. Revised guidelines for the approval of fixed water-based fire fighting systems for ro-ro spaces and special category spaces. (A.123(V)) (Annex 1 - Performance Testing and Approval Standards for Fire Safety Systems)

8 This circular supersedes MSC.1/Circ.1272, except that fire and component tests previously conducted in accordance with MSC.1/Circ.1272 remain valid for the approval of new systems. Existing fixed fire-extinguishing systems for special category spaces approved and installed based on resolution A.123(V) and MSC.1/Circ.1272 should be permitted to remain in service as long as they are serviceable. Application: One (1) year after its approval by MSC 90. Advice for clients: new systems should be approved in accordance with this guideline. Prescriptive-based systems should comply with section 4, and performance-based systems should comply with section 5 of the guidelines. 2. Guidelines for the approval of helicopter facility foam fire-fighting appliances. These Guidelines should be applied when approving helicopter facility foam fire-fighting appliances in accordance with SOLAS regulation II-2/ to 5.1.5, Chapter 9 of the 2009 MODU Code and MSC/Circ.895 on Recommendation of helicopter landing areas on ro-ro passenger ships. Application: One (1) year after its approval by MSC 90. Advice for clients: Shipbuilders: possible design changes affecting the helicopter landing area and capacity of the fire fighting appliances. These need to be addressed at the design stage of a ship. Owners and managers: May required crew training Flag Administrations Advice for clients: to provide instructions to surveyors. 3. Revised Guidelines for the maintenance and inspection of fire-protection systems and appliances. These Guidelines should be applied when performing maintenance, testing and inspections in accordance with SOLAS II- 2/ These Guidelines apply to all ships and provide the minimum recommended level of maintenance and inspections for fire-protection systems and appliances. This information may be used as a basis for the ship's onboard maintenance plan required by SOLAS regulation II-2/14. These Guidelines do not address maintenance and inspection of fixed carbon dioxide systems or portable fire extinguishers. Refer to the comprehensive instructions provided in MSC.1/Circ.1318 for fixed carbon dioxide systems, and in resolution A.951(23) for portable fire extinguishers. Application: One (1) year after its approval by MSC 90. Advice for clients: The guidelines have been amended to include inspection and maintenance requirements for high expansion foam systems. The onboard maintenance and inspections of fire-protection systems and appliances should be carried out in accordance with the ship s maintenance plan. When the inspections and maintenance are carried out by crew with advanced fire fighter, training records should be kept on board the ship. In cases the inspections and maintenance are carried out by trained technicians other than the ship s crew, reports should be provided at the completion of testing. Return to overall summary at start of document (Annex 1 - Performance Testing and Approval Standards for Fire Safety Systems)

9 Lloyd's Register briefing IMO FP 55 Annex 2 - List of instruments agreed at FP 55 under agenda item 3 *Note: Circulars numbers will be published on the final FP 55 Report. List of draft mandatory resolutions MSC Resolutions Resolution No. Title Intended application date MSC.(90)* Draft amendments to the FSS code, chapters 3, 5, 8, 9, 12, 13 and 14 To be confirmed List of non-mandatory circulars, for approval at MSC 90 in May 2012 MSC Circulars Circular No. Title Intended application date MSC./Circ.* MSC./Circ.* MSC./Circ.* MSC./Circ.* MSC Circular to Revised Guidelines for the design and approval of fixed water-based fire-fighting systems for ro-ro spaces and special category spaces. (This circular superseded A.123(V) and MSC.1/Circ.1272) Guidelines for the approval of helicopter facility foam fire-fighting appliances Revised Guidelines for the maintenance and inspection of fire-protection systems and appliances. (This circular supersedes MSC/Circ.850) Unified interpretations of SOLAS regulation II-2/ and Chapter 9 of the FSS code. 1 year after the date of approval 1 year after the date of approval 1 year after the date of approval Return to overall summary at start of document (Annex 2 List of instruments agreed at FP55 under agenda item 3)

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