Chapter II-2 Construction - Fire protection, fire detection and fire extinction

SOLAS

Chapter II-2 - Construction - Fire protection, fire detection and fire extinction

1 Emergency Escape Breathing Devices (10-45)

SOLAS

Chapter II-2

Emergency Escape Breathing Devices (10-45)
As a result of the Tripartite meeting it was decided that that the placement of Emergency Escape Breathing Devices (EEBDs) on ships of less than 500 Gross Tonnage is impractical and has no direct added value to the safety of the crew (due to the size of the vessel) and therefore (as it was in the past) not required.
The proposed modification concerning these subjects, part of the Regulation safety of seagoing ships (Regeling veiligheid zeeschepen- Rvz) were posted in the law gazette and applicable from the 1st of January 2012.
Article 37b, exemptions for ships as meant in article 3a, 1st paragraph, part a of the Rvz is changed as follows:

• Regulation 13.3.4 and 13.4.3 concerning EEBD’s are added.
  

2 Separation between Engine en Purifier Room (11-22)

SOLAS

Chapter II-2

Separation between Engine en Purifier Room (11-22) 
The separation between the Engine Room and purifier/separator room, as per SOLAS II-2, regulation 4.2.5, is required. In case this is not practicable and can’t be realised, a well founded exemption proposal must be forwarded for approval by the RO to NSI.

3 Fuel Oil tanks adjacent to, or in machinery spaces (12-06)

SOLAS

Chapter II-2

Fuel Oil tanks adjacent to, or in machinery spaces (12-06)
With regard to the requirements for fuel oil tanks adjacent to, or in machinery spaces, MSC Circ.1322 has to be applied.
A60 insulation is not considered as an alternative for a void space. Deviation is only allowed in duly justified and exceptional cases, which should be dealt with as an exemption proposal, submitted by the RO to the NSI.

4 Interpretation on ‘designated under deck space’ (12-23)

SOLAS

Chapter II-2

Interpretation on ‘designated under deck space’ (12-23)
SOLAS Chapter II-2 Regulation 19.3.1.3 reads: Means shall be provided for effectively cooling the designated under deck space by at least (…).

The term “designated under deck space” does it mean:

1. A designated forward part of one hold
   
   
2. A designated complete hold
   
   

Until 20 January 2009, NSI was of opinion that possibility as mentioned under a) was applicable. After consultation with stakeholders, we changed our interpretation and from that day the interpretation as mentioned under b) is applicable.

However, NSI may accept on case by case basis possibility a) under the following conditions:

1. When in the forward part of the hold dangerous goods of class 1 are carried the mechanical ventilation for the entire hold is switched off. This means that no cargoes are allowed to be carried that require mechanical ventilation.
   
   
2. The grain bulkhead has to be reasonable gastight and watertight and the proper sealing arrangement is to the (attending) surveyor's satisfaction (new construction only). Sealing arrangements to be submitted to plan approval of the class society.
   
   
3. Regulation 19.3.1.3 concerning water supplies shall be complied with for the designated forward part of the cargo hold. Additional spraying nozzles are directed straight onto the grain bulkhead for boundary cooling.
   
   
4. Dangerous goods and combustible materials has to be stowed at least 3 meters from the grain bulkhead or an additional grain bulkhead has to be placed at least 1.5 meters aft of the forward grain bulkhead.

5 Electrical activation of quick closing valves (Class-ILT: 2013-02)

SOLAS

Chapter II-2

Electrical activation of quick closing valves (Class-ILT: 2013-02)
During an inspection, NSI noticed that in some configurations quick-closing valves were operated by electrical activation. It was found that a quick closing valve for the fuel supply for the main propulsion was installed that would automatically close in case of a wire breach (no redundancy). NSI stresses that this is not according to SOLAS, while it is not fail safe and the normal operation of the ship’s propulsion may be jeopardized. It was therefore decided that in principle, activation of quick closing valves by electrical means is not allowed by NSI, unless agreed otherwise.

6 MSC/Circ. 1432 status policy rule (13-16)

SOLAS

Chapter II-2

MSC/Circ. 1432 status policy rule (13-16)
The implementation of MSC/Circ. 1432 Revised guidelines for the maintenance and inspection of fire protection systems and appliances was discussed. the Inspectorate regards the content of the documents included as so important that a lower level of safety and/or environmental protection cannot be accepted. The intention is to incorporate the requirements in formal policy rule.

8 Emergency fifi pump fire line - short length (CI 2013-12)

The interpretation on ‘short length’ for the emergency fifi pump fire line has been under discussion. At the IMO, IACS proposed an interpretation on this matter, but States couldn’t agree on the length of the fire line. NSI has determined that no separate national requirement for the short length will be drawn up. The IACS interpretation (SC.245) may be followed.

9 Aerosol systems (14-04)

NSI was informed that the aerosol containers have certain dates of expiry. NSI therefore kindly request the ship owner and the RO during surveys of the fire fighting systems to check the aerosol containers if they are not overdue in time.

10 Spare BA Cylinders training set (14-08)

As per 01st  of July 2014, SOLAS II-2, regulation 15.2.2.6 stipulates that means of recharging or a suitable number of spare BAcylinders should be carried on board. Questions were raised concerning the definition of suitable number. NSI has the following interpretation:
Compliance with the above is the responsibility of the ship owner, either by providing sufficient training cylinders or by providing a BA compressor. Naturally they shall be able to provide sufficient  documentation/ procedures proving compliance with the above.

11 Pressure testing of pilot bottles (15-02)

 Time period of pressure testing of pilot bottles for fire extinguishing systems is prescribed by two IMO documents MSC.1/Circ. 1318 and A.951(23). These Guidelines provide the minimum recommended level of maintenance and inspections for fixed carbon dioxide fire-extinguishing systems on all ships, and are intended to demonstrate that the system is kept in good working order as specified in SOLAS Chapter II-2, Regulation 14.2.1.2. Portable fire-extinguishing systems should be kept in good working order and readily available for immediate use:

1. According to MSC.1/Circ. 1318 high pressure cylinders should be subjected to periodical tests at intervals not exceeding 10 years.
2.  According to Resolution A.951(23) paragraph 9.1.2 all extinguishers together with propellant cartridges should be hydraulically tested in accordance with the recognized standard or the manufacturer’s instruction at intervals not exceeding ten years.

The NSI interpretation is that pilot bottles (including < 1 kg) should be hydrostatic tested every 10 years (according to the percentages mentioned). With regard to the percentage of testing, according to §6.1.2 van MSC.1/Circ.1318 the 10% testing percentage applies for all pilot bottles including those of <1 kg.

12 Marking of the Safety Plan (Tripartite 11-02)

According to SOLAS, the Fire Control Plan needs to be approved by the (RO on behalf of the) Administration. For the Safety Plan there is no such requirement. For NSI it is sufficient that the RO marks the Safety Plan with a minimum of noted (or equivalent term used by the RO), meaning that it is verified that a Safety Plan was drawn up and available for placement on board concerning vessel.

13 Spare charges for fire extinguisher on short sea routes

The number of spare charges for vessels operating on short sea routes may be reduced where arrangements have been made for the ready availability of spare extinguishers or charges. Equivalence may be granted only while the vessel is in service on the designated route, an arrangement is made with an identified reputable supplier and the arrangements for supply of spares can be verified.

• Informatietype: Informatie voor uitvoering
• Documentsoort: Nieuwsbrief
• Toegangsrechten: Intern
• Identificatie: PUC_1345_14
• Versie: 4
• Datum beschikbaarheid: 21-07-2021
• Geldigheid van: 23-02-2018
• tot en met: 20-07-2021
• Wijzigingsdatum: 21-07-2021
• Titel: Chapter II-2 Construction - Fire protection, fire detection and fire extinction
• Organisatie: Inspectie Leefomgeving en Transport
• Taal: Engels
• Thema: SOLAS Convention - Decisions and Interpretations