Legend / Explanation of abbreviations:
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FSS code: International Code for Fire Safety Systems as defined in chapter II-2 of the International Convention for the Safety of Life at Sea, 1974, as amended
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IMO: International Maritime Organization
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IACS: International Association of Classification Societies
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ISO: International Organization for Standardization
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MAPROL: International Convention for the Prevention of Pollution from Ships
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MED: Directive 2014/90/EU on marine equipment
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MSC: Maritime Safety Committee
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NSI: Netherlands Shipping Inspectorate
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RO: Recognised Organisation
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SMS: Safety Management System
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SOLAS: the International Convention for the Safety of ife at Sea, 1974, and its protocol of 1988: articles, annexes and certificates, as amended
1 Separation between Engine and Purifier Room
With regard to SOLAS regulation II-2/4.2.5, and taking into account MSC.1/Circ.1321, Part 3, chapter 5, paragraph 3.1, for equipment which treats flammable liquids automatically (e.g. oil fuel purifiers), the NSI may exempt a ship from the requirement to have the purifiers installed in a special space reserved for purifiers, in case the installation of the purifiers in a special space reserved for purifiers is not practicable, provided that a well-founded proposal for an exemption has be forwarded by the RO to the NSI for approval.
2 Waste receptacles for the storage of garbage
With regard to SOLAS regulation II-2/4.4.2 and paragraph 4.2 of MSC.1/Circ.1120, the NSI accepts that for the storage of garbage, as defined in MARPOL Annex V:
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waste receptacles placed inside the ship in areas where rust is an issue (e.g. galleys), may be lined with plastic or rubber inserts; and
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waste receptacles (e.g. wheely bins) placed on deck may be constructed of combustible material.
3 Spare charges to be carried on board (lifeboats and tenders)
SOLAS regulation II-2/10.3.3 makes the carriage of spare charges for fire extinguishers mandatory on board of ships. However, lifeboats and tenders are not mentioned in MSC.1/Circ.1275.
Therefore the NSI only recommends that spare charges or additional portable fire extinguishers of the same quantity are provided for the extinguishers placed in lifeboats and tenders (as per SOLAS regulation II-2/10.3.3.1 and SOLAS regulation II-2/10.3.3.2).
It is also recommended by the NSI to use extinguishers of a same type as used elsewhere on the ship where possible. In that case spare charges are provided for such extinguishers without increasing the number of spare charges carried on board.
4 Reduced number of spare charges for fire extinguishers on board Ro-Ro (passenger) ships
With regard to SOLAS regulation II-2/10.3.3, for a Ro-Ro (passenger) ship undertaking short international voyages, as defined in SOLAS regulation III/3.22, between specified ports (fixed schedule), the required number of spare charges for fire extinguishers may be reduced as follows:
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spare charges shall be provided for 10% of each type of fire extinguisher capable of being recharged on board;
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for fire extinguishers which cannot be recharged on board, additional portable fire extinguishers of the same quantity, type, capacity and number as determined for the 'extinguisher capable of being recharged on board' shall be provided in lieu of spare charges; and
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not more than 20 spare charges in total, equally distributed over the available types, are required,
provided that:
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the ship owner or ship operator can demonstrate a contract or other arrangement with a supplier of spare charges;
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the ready availability of service and spare parts can be verified; and
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instructions for recharging are carried on board.
5 Fixed aerosol fire-extinguishing systems
With regard to SOLAS regulation II-2/10.5 as well as FSS Code chapter 5, regulation 2.4, and taking into account the 'Revised guidelines for the approval of fixed aerosol fire-extinguishing systems equivalent to fixed gas fire-extinguishing systems, as referred to in SOLAS, for machinery spaces' (MSC.1/Circ.1270, as corrected), the NSI requires the replacement date(s) of the condensed or dispersed aerosol generators:
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to be verified for non-exceedance at an annual interval, as stipulated in paragraph 7.10 of the annex to the 'Revised Guidelines on maintenance and inspection of fire protection systems and appliances' (MSC.1/Circ.1432); and
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to be included in the maintenance plan on board the ship, as referred to in SOLAS regulation II-2/14.2.2.
6 Marine fire-fighter's outfit
In accordance with SOLAS regulation II-2/10.10.1 ships are required to have fire-fighter's outfits which meet the standards stated in the FSS Code. The FSS Code applies to all fire-fighter's outfits required by SOLAS and stipulates the requirements in chapter 3, regulation 2.1, i.e.:
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Protective clothing of material to protect the skin from the heat radiating from the fire and from burns and scalding by steam. The outer surface shall be water resistant;
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Boots of rubber or other electrically non-conducting material; and
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Rigid helmet providing effective protection against impact.
6.1 Type approval
It is noted that the FSS Code does not refer to a type-approval for subject outfits. However, type approval for marine fire-fighting outfits is required under the Dutch Ship's equipment Act and the MED and is confirmed by a Wheelmark. Current EN 469:2020 approval mandated for all new outfits since August 25th, 2024, replacing the previous 'EN 469:2005 standard (incl. A1:2006 and AC:2006)'. It is important to note that EN 469:2020 and EN 469:2005 both contain a specific reference indicating the performance level of the outfit.
Furthermore attention is drawn to the fact that for professional shore-based fire-fighting departments, there are three basic types of these outfits/suits, whereby the following distinction is made:
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Approach suit, used for work in the general area of high temperatures such as steel mills and smelting facilities. These usually provide ambient heat protection up to ≈90 °C.
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Proximity suit, used for instance in aircraft rescue and firefighting, providing ambient heat protection up to ≈260 °C.
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Entry suit, used for entry into extreme heat, such as kiln work requiring entry into the heated kiln, and situations requiring protection from total flame engulfment. Most commonly made of Zetex or vermiculite and not aluminized. These provide ambient protection up to ≈1100 °C for short duration and prolonged radiant heat protection up to ≈800 °C.
6.2 The use of approach-/fire proximity suits on board
There is a concern that some ships are provided with 'basic fire proximity suits' which, whilst complying with the above requirements for open spaces, do not provide the wearer sufficient thermal protection from radiated heat if entering an enclosed space (including machinery and accommodation spaces) where a fire has started.
Proximity clothing stating 'not suitable for fire entry', 'not a fire entry suit' or similar is primarily intended for boundary cooling or for search and rescue activities in an enclosed space without raised temperatures, directly or indirectly, caused by a fire. It may also be used with extreme caution for search and rescue purposes or fire-fighting within an enclosed space where a fire has just started (actual contact with flames must be avoided at all times). An explanation on the correct use of the fire-fighter's outfits provided on board shall be included in the Training Manual as required by SOLAS regulation III/35. During the execution of a fire drill this shall be taken into account as well, so that the crew is well aware of the limitations of the fire-fighter's outfits provided on board.
6.3 Recommendation for the uniform application
To avoid false expectations by the wearer of the suit on the level of protection the suit will provide, and to ensure the correct practical application of fire-fighter's outfits available on board the NSI urges shipowners to evaluate the condition- and intended application of the fire-fighter's outfits available on board and to conduct a risk assessment to confirm the range of operation of subject fire-fighter's outfits. The results of this risk assessment shall be included in the SOLAS training manual, and procedures on board should be updated accordingly.
Fire fighters outfits that are placed on board after August 25th, 2024 must comply with the EN 469:2020 standard. With regard to outfits placed on board before this date but not due for replacement, it is still strongly recommended that they be replaced with outfits that comply with EN 469:2020. The NSI recommends that shipowners choose for performance level 2 outfits, as defined in section 6.2 of EN 469:2020, because these outfits:
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are suitable for firefighting inside structures;
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are also suitable for firefighting in spaces where a high amount of fuel can be expected, such as Ro-Ro ships;
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provide adequate protections when fighting alternative fuel fires.
For the boots (in accordance with EN 15090:2012) type 2 should be chosen. When equipment with a lower performance level is placed on board, the procedure above should be followed.
7 CO2 systems' testing and inspection
7.1 Additional guidance regarding MSC.1/Circ.1318(/Rev.1)
With reference to SOLAS regulation II-2/14.2 and contrary to what is stated in the introduction to this MSC.1/Circ.1318/Rev.1 (under point 4: "This circular supersedes MSC.1/Circ.1318.", dated 25 May 2021), the NSI considered MSC.1/Circ.1318 as valid 'Policy Rule' until 31-12-2022 and the revision had been assigned with status 'Policy Rule' from 1-1-2023, superseding MSC.1/Circ.1318 from that date on.
For ships that already have completed the 10 yearly maintenance/pressure testing (due to its 10-, 20-, 30-, 40th yearly term) before 1-1-2023, the regime as per MSC.1/Circ.1318 ('…as a minimum another 10% of its CO2 cylinders will have been subjected to an internal inspection and hydrostatic test') might be applied, however also the revised circular might be applied already.
All Dutch flagged ships shall have to comply with the 10 yearly hydrostatic testing requirements for all1 CO2 cylinders on board in accordance with MSC.1/Circ.1318/Rev.1, ultimately before the next scheduled dry docking2 of the ship; resulting that ultimately 01-01-2028 all ships will comply with revision MSC.1/Circ.1318/Rev.1.
Note: the pressure testing due date is to be related to the age stamped on the bottle or the last 10 yearly inspection/pressure test stamped on the bottle and not the actual age of the ship.
7.2 Low pressure CO2 bulk storage containers
With regard to SOLAS regulation II-2/14.2.1.2 and MSC.1/Circ.1318/Rev.1, and taking into account IACS recommendation No.53/Rev.1, the NSI requires a low pressure CO2 bulk storage container to be maintained and inspected in accordance with:
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IACS recommendation No.53/Rev.1, and
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the requirements of the manufacturer of the low pressure CO2 storage container, in case those are more stringent.
With regard to IACS recommendation No.53/Rev.1, the NSI clarifies that:
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With reference to section 1.3: Removal of insulation should be done as necessary in accordance with the manufacturer's procedure or (if this is not available) as instructed by the surveyor e.g. at the location of appendages, other connections and mounting supports.
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With reference to section 4: For low-pressure CO2 bulk storage containers hydrostatic testing may be required at the surveyor's discretion, depending on the results from internal survey.
8 Testing and examination of pilot cylinders of fixed gas fire-extinguishing systems
With regard to SOLAS regulation II-2/14.2.1.2, for fixed gas fire-extinguishing systems, the pilot cylinders, including any pilot cylinder of less than 1 kg in weight, shall be hydrostatically tested and internally examined every 10 years, in accordance with paragraph 10.1.1 of 'Guidelines for the maintenance and inspections of fire protection systems and appliances' (MSC.1/Circ.1432).
9 Hydrostatic testing of self-contained breathing apparatus cylinders
With reference to SOLAS regulation II-2/14.2.2, the NSI follows the ISO standards in the case of paragraph 9.4 of MSC.1/Circ.1432 on the test interval for hydrostatic testing of self-contained breathing apparatus cylinders, i.e.:
However, if the maker recommends a shorter interval, that shorter interval should be followed.
10 Fire control plans
With regard to SOLAS regulation II-2/15.2.4, the NSI requires:
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the ship's fire control plans to be approved, and re-approved following an amendment, by the RO on behalf of the NSI;
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Alternatively, the details, as set out in SOLAS regulation II-2/15.2.4.1, may be set out in a booklet, a copy of which shall be supplied to each officer, and one copy shall at all times be available on board in an accessible position.
11 Interpretation on 'designated under-deck cargo space'
SOLAS, regulation II-2/19.3.1.3 reads: Means shall be provided for effectively cooling the designated under-deck cargo space by at least (…).
In continuation of the earlier information to shipping regarding this topic, there are 2 interpretations for the term 'designated under-deck cargo space' by the NSI:
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A designated complete hold (which is in line with the international interpretation); or
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A designated part of one hold, under the following conditions (i – iv):
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When in the designated 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;
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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;
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Regulation 19.3.1.3 concerning water supplies shall be complied with for the designated part of the cargo hold. Additional spraying nozzles are directed straight onto the grain bulkhead for boundary cooling; and
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Dangerous goods and combustible materials have to be stowed at least 3 meters away from the grain bulkhead or an additional grain bulkhead has to be placed at least 1.5 meters away from the grain bulkhead.