Proceedings of the ASME/USCG 2013 3rd Workshop on Marine Technology and Standards MTS2013 July 24-25, 2013, Arlington, VA, USA MTS2013-0321 NFPA Marine Fire Protection Codes and Standards An Overview Guy R. Colonna, P.E. National Fire Protection Association Quincy, MA 02169 USA ABSTRACT The National Fire Protection Association (NFPA) develops consensus codes and standards for fire and life safety for a wide array of occupancies, including the maritime industry. With documents originating in the early 1920 s, NFPA maritime safety standards reflect current practices in vessel design and operations, new hazards, and new technology. These documents include safe practices associated with confined space entry and hot work operations during construction, maintenance, and repair; shipyard fire protection safety management; and suppression system design, installation, and testing/maintenance. This presentation highlights those consensus standards contributing to safety management within the maritime industry. INTRODUCTION NFPA s mission is to reduce the worldwide burden of fire and other hazards on the quality of life by providing and advocating consensus codes and standards, research, training, and education. Our consensus codes and standards trace their origins to the nineteenth century development of automatic sprinkler systems. Though immediately effective in their performance as extinguishing devices, the systems were initially installed in so many ways that their reliability was uncertain. So, in 1895 the key stakeholders from sprinkler and insurance interests met in Boston to discuss the different approaches utilized for design and installation of systems. Their product from that meeting became today s NFPA 13, Standard for the 200 Published with permission.
Installation of Sprinkler Systems, and prompted the creation of NFPA. Today NFPA develops some 300 safety consensus codes and standards that deal with a range of subjects related to fire, electrical, chemical, building, and life safety. In the standards development arena, full consensus means that anybody can participate and expect fair and equal treatment. The first marine fire protection standards date from the early 1920 s and today, NFPA has 6 standards specifically applicable to marine vessels or facilities. Two of those are focused on the pleasure boating domain NFPA 302, Standard for Pleasure and Commercial Motor Craft and NFPA 303, Standard for Marinas and Boatyards and will not be featured in this treatment of the NFPA marine fire protection standards. In addition to the standards applicable to vessel and facility fire protection, NFPA also offers standards on specific suppression systems for which vessel applications have been developed and emergency response standards for fires and spills involving marine vessels. Before describing the specifics of each of the standards, a review of the NFPA codes and standards consensus development process would be helpful. NFPA STANDARDS PROCESS NFPA is one of many consensus standards development organizations that adhere to the essential requirements of the American National Standards Institute (ANSI) for development of their standards. The NFPA standards are prepared through the efforts of over 200 technical committees, comprised of over 5000 volunteers. NFPA utilizes its Standards Council to administer the standards development process. It is the Council that approves the standards development committees and that appoints the volunteers to serve as members of specific technical committees. The consensus process requires a balance of interests to be represented on the committees so that there is a lack of dominance by any single interest. NFPA achieves that balance by defining nine categories of membership interest and by requiring that no single interest category can make up more than one third of the total voting membership. For example, the interest categories include the owner/operators of vessels or marine facilities (like shipyards), insurers, manufacturers (like suppression equipment or instrumentation), installer/maintainers of systems, consultants, and regulators or enforcers (like the Coast Guard or OSHA). The NFPA staff and Standards Council manage the committee makeup to ensure that membership by those interest categories does not exceed one third of the total size of the committee, which is typically limited to a maximum of thirty principal voting members. In addition to the balance, consensus requires a basis for agreement on specific issues in order to develop or change the requirements. NFPA recognizes that consensus has been achieved on a 201
specific issue when two thirds of the eligible voting members affirm a position as indicated in a written letter ballot. Though NFPA is a membership organization, anyone can apply and be appointed to a technical committee. In addition, all committee meetings are open to the public. In accordance with the ANSI provisions, NFPA codes and standards are revised at least every five years. If it is not feasible to apply and serve on a committee, it is possible to monitor the status of the various committees and their respective documents using the NFPA web page and the specific document information page (or doc info page for short) established for each document. Anyone, using the doc info page, can submit proposed changes or comments on changes to a specific standard during the revision cycle. Each revision cycle requires approximately two years from the point at which notice is given that proposed change recommendations are being solicited to the point at which the Standards Council issues the new edition complete with its revisions. The diverse segments of the marine industry are well represented on the various NFPA committees that are responsible for the six, marine specific committees as well as on those committees that include marine related provisions (for example, the water mist fire protection system committee). NFPA documents, like other documents developed by consensus standards developers, are referred to as voluntary, consensus standards. NFPA does not enforce its codes and standards; instead, NFPA promotes the adoption and enforcement through state or local fire or building codes. In some cases, however, NFPA documents are incorporated by reference into federal agency standards, like those of the US Coast Guard, Department of Homeland Security, and OSHA. NFPA works closely with the adopting jurisdictions at the state and local levels to assist their implementation of the documents into their fire and building codes by offering free training. NFPA also recognizes the importance of the enforcing official voice within the various committees, and for that reason began reimbursing the travel expenses for attendance and participation at technical committee meetings. As a strategic goal since 2010, NFPA realizes that adoption is important but each adoption must be complemented with enforcement and compliance in order for the mission of NFPA to be achieved. The document revision process involves two major steps: first, is the receipt of proposed changes from the public (now called Public Input), and second, is the receipt of comments from the public addressing specific proposed changes (now called Public Comment). Following the Public Input submittal, the committee reviews and acts on the proposed changes and develops the First Draft, which incorporates the proposed changes that have been accepted by the committee. The committee approves its First Draft by a written letter ballot that again, must achieve at least a two thirds affirmative vote to confirm all the proposed revisions to the document. The public may then submit comments to the First Draft to recommend changes to 202
the action taken by the committee as part of this first step in the revision process. The committee must review and act on the comments to determine whether to support the further revision of the draft or to retain the initial changes established as part of the First Draft stage. Another letter ballot occurs with the same two thirds vote to indicate consensus by the committee on their work. Any revisions incorporated in response to the comments forms the basis for the Second Draft. Individuals submitting input or comment are permitted to pursue one additional opportunity to justify a specific technical revision during the NFPA annual conference. Once these stages have been completed, the Standards Council acts to issue the new edition of the document. MARINE STANDARDS OVERVIEW Over ninety years ago, cargo vessels returning from the First World War were being converted to carry larger cargo parcels on longer voyages. Shipbuilding activity, specifically repair and conversion, contributed to an increase in the number of fires and explosions within US shipyards. Vessel owners, shipyard owners, and insurance underwriters expressed their concern to the NFPA and its Marine Committee. In 1922, NFPA s Marine Committee adopted a series of standards known as the Regulations Governing Marine Fire Hazards. Appendix A of those regulations addressed the control of gas hazards on vessels during repair activities, and would eventually become today s NFPA 306, Standard for the Control of Gas Hazards on Vessels. With the adoption of the specific standards of practice for safeguarding entry and work on vessels during shipbuilding, repair, and conversion, the maritime industry needed technically knowledgeable and skilled individuals who could ensure that those fire prevention requirements were implemented. One of the industry stakeholders that approached NFPA was the American Bureau of Shipping (ABS), whose role was to establish and maintain minimum standards for construction and operation of ship and offshore structures. ABS already had a cooperative relationship with ship owners and shipyards, and they agreed to initiate procedures for certifying specialists (then called gas chemists), who would apply and essentially enforce this new NFPA standard within the shipyards on a daily basis. The first 25 gas chemists became certified by ABS in 1922. By the early 1960 s, ABS was seeking a successor to manage the program and NFPA assumed that role in 1963; a duty it continues to oversee to this day. Today, NFPA manages the certification and recertification of Marine Chemists through the Marine Chemist Qualification Board. The Board applies the rules for certification and recertification that are approved by the NFPA Board of Directors. Today there are nearly 100 Marine Chemists operating in ports throughout the United States, applying the provisions of NFPA 306, which complements the OSHA Shipyard Employment regulations found in 29 CFR 203
1915, Subpart B. Use of a Marine Chemist to inspect and authorize entry and hot work repairs in or on confined spaces, particularly where fuels or flammable cargoes are present, is now required by both OSHA and Coast Guard regulations. NFPA 306 provides the essential safeguards required during entry and hot work for all marine vessels whether during construction, repair, conversion, or shipbreaking. Because flammable and combustible liquids are used as fuels, lubricants, and cargoes, any time hot work is planned there is a potential for these materials that are so vital to the operation of the vessel, to become the unwanted fuel for the repair process ignition source. So, for that reason, Coast Guard and OSHA regulations require an inspection and certificate authorizing hot work to be prepared and issued by an NFPA certificated Marine Chemist. Confined spaces possess many hazards, including those associated with hot work repair; the Marine Chemist has also become the entry specialist for the industry as many confined space standard operating procedures within the various industry segments start with the inspection and permit provided by a Marine Chemist. NFPA 306 establishes standard safety designations for ease of use throughout the industry to denote the conditions found during the inspection and monitoring of the atmospheric conditions. Safe for Workers and Safe for Hot Work are commonly understood within the industry and not necessarily limited to the ports and waterways of the United States. Though NFPA 306 has not been explicitly adopted internationally, the framework its requirements provide is clearly understood and in some cases imitated in other ports around the globe. Shipyard fire safety is the focus of another standard, NFPA 312, Standard for Fire Protection of Vessels during Construction, Conversion, Repair, and Lay up. This document originated in 1933 and provides the fundamental requirements necessary for managing the potential fire hazards associated with construction, conversion, and repair operations. This includes establishing hot work safety procedures, fire watch duties and training requirements, inspection of fixed extinguishing systems, and fire brigade duties and organization. Vessels in a lay up status pose unique hazards due to their non operational condition and limited crew resources. This standard provides the minimum requirements to be followed when placing a vessel into a lay up status and when monitoring a vessel during lay up. Another standard focused on the facility fire protection is NFPA 307, Standard for the Construction and Fire Protection of Marine Terminals, Piers, and Wharves. NFPA 307 began as two separate standards, NFPA 87, Standard for the Construction and Protection of Piers and Wharves, and NFPA 307, Recommendations for the Operation of Marine Terminals, that were combined in 1980 to form today s NFPA 307. NFPA 87 was first adopted in 1925 following a development process that took nearly 10 years, while NFPA 307 was first adopted in 1951. Today, the standard addresses the construction of pier and wharf structures and terminal 204
buildings; operation and storage requirements for terminal yards; water supply and fire protection for the facility; and special provisions associated with hazardous material storage. NFPA 301, Code for Safety to Life from Fire on Merchant Vessels, demonstrated how the NFPA codes and standards development process works in response to a request to address a new or unique situation. In 1993, the Coast Guard approached the NFPA Standards Council with a request to form a new committee that would develop a consensus standard on fire protection of merchant vessels, similar in format to the NFPA 101, Life Safety Code. The basis for this request was a Coast Guard initiative known as Maritime Regulatory Reform. One aspect of maritime regulatory reform involved greater use of industry standards in lieu of detailed design requirements contained in the Code of Federal Regulations. By shifting development and maintenance of regulations to standards making organizations, the regulators (in this case the Coast Guard) would be assured of dynamic standards that were regularly updated. The marine industry benefits through increased input into the rules it would subsequently be required to follow. Similar efforts will be discussed in this paper involving the addition of marine specific criteria to existing fire protection system standards, such as automatic sprinklers, water mist extinguishing systems, foam, carbon dioxide, and clean agent extinguishing systems. NFPA 301 provides minimum requirements for the design, operation, and maintenance of merchant vessels for safety to life from fire and similar emergencies. The document establishes occupancy classifications and then provides requirements for design and construction, access and egress, and fire protection. The document applies to passenger vessels, towing vessels, and cargo vessels. Marine specific chapters for the design and installation of suppression systems were incorporated into NFPA 11, 12, 13, 750, and 2001 beginning in the late 1980 s. In 1998, NFPA 11, Standard for Low, Medium, and High Expansion Foam, established requirements for lowexpansion foam systems for marine applications. Like NFPA 11, a marine specific chapter was incorporated in NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, in 1998. NFPA 13, Standard for the Installation of Sprinkler Systems, provides a marine specific chapter that details the deletions, additions, and modifications for designing and installing an automatic sprinkler system for a marine vessel application. Passenger ferry engine rooms were among the first application for testing water mist fire protection systems during the 1940 s. NFPA 750, Standard on Water Mist Fire Protection Systems, was first issued in 1996 due to renewed interest in the technology possibly resulting from the phasing out of halon. A factor contributing to its early use on marine vessels is its potential as a fire safety system for spaces where the amount of water that can be stored or that can be discharged is limited. Like NFPA 13, NFPA 750 offers a marine specific chapter for designing and installing water mist fire protection systems. NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, is the last 205
of the suppression system documents to include a marine vessel unique chapter that details the design and installation requirements for such systems when installed on marine vessels. Emergency response to marine vessel fires and other casualties, such as cargo spills, is also addressed by NFPA documents. As previously noted in the discussion of the development of NFPA 301, requests for new standards are received routinely; based on the expressed and documented need and any indication of support from potential affected parties or interested stakeholders, such requests are often approved and become new committees with new documents. In the mid 1980 s NFPA received another such request from the Coast Guard; this time the request came in the wake of several fire incidents involving vessels while in port where the fire response was complicated due to lack of coordination on the part of vessel personnel, port personnel, and local fire department responders. At the recommendation of the National Transportation Safety Board (NTSB), the Coast Guard requested that an NFPA committee develop guidance for land based fire departments when responding to marine vessel fires. At the time of the request, it was recognized that marine vessel fires constitute one of the greatest challenges that structural fire fighters can face. The first edition of NFPA 1405, Guide for Land Based Fire Departments That Respond to Marine Vessel Fires, was adopted in 1990. Today, there is also a companion standard on professional qualifications for marine firefighting by land based fire fighters; that document is NFPA 1005. Over the past decade, NFPA 472, Standard for Competence of Emergency Responders to Hazardous Materials/Weapons of Mass Destruction Incidents, has added competencies for technicians with a marine tank vessel specialty. At the request of the Coast Guard, competencies have been included in order to ensure that individuals are qualified when providing technical support pertaining to marine tank vessel incidents, such as providing oversight for product removal and movement of damaged marine tank vessels, and acting as a liaison between technicians and outside resources. CLOSING NFPA s relationship with the maritime industry dates from 1915 and provides fire and life safety guidance for vessels, facilities, suppression systems, and emergency response practices. The development of the NFPA standards benefits today from the continued participation of the same affected industry parties that first approached NFPA over 90 years ago. The standards remain up to date and respond to changes in operations or technology through regularly scheduled revisions. Technology enables users and other interested parties to participate in the development of proposed changes and to follow the work of the committees during specific revision stages. An important aspect of all NFPA standards is their availability for read only viewing through the NFPA web page, at no cost. NFPA remains 206
committed to its mission and operates a unique outreach program for the maritime industry in support of the Marine Chemist certification program as well as the related codes and standards activity. For more information on the Marine Chemist program visit www.nfpa.org or email the NFPA Marine Field Service at marine@nfpa.org. REFERENCES NFPA Standards NFPA 11, Standard for Low, Medium, and High Expansion Foam, 2010 NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2011 NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 NFPA 301, Code for Safety to Life from Fire on Merchant Vessels, 2013 NFPA 306, Standard for the Control of Gas Hazards on Vessels, 2009 NFPA 307, Standard for the Construction and Fire Protection of Marine Terminals, Piers, and Wharves, 2011 NFPA 312, Standard for Fire Protection of Vessels during Construction, Conversion, Repair, and Lay up, 2011 NFPA 472, Standard for Competence of Emergency Responders to Hazardous Materials/Weapons of Mass Destruction Incidents, 2013 NFPA 750, Standard on Water Mist Fire Protection Systems, 2010 NFPA 1005, Standard for Professional Qualifications for Marine Fire Fighting for Land Based Fire Fighters, 2007 NFPA 1405, Guide for Land Based Fire Departments That Respond to Marine Vessel Fires, 2011 NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2012 OSHA Regulations 29 CFR 1915, Subpart B, Shipyard Employment US Coast Guard Regulations 46 CFR 35.01 1(c), Special Operating Requirements 207