Chapter II-2 - Construction - Fire protection, fire detection and fire
1 Emergency Escape Breathing Devices (10-45)
Emergency Escape Breathing Devices (10-45)
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.
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)
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)
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
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)
Interpretation on ‘designated under deck space’ (12-23)
SOLAS Chapter II-2 Regulation 188.8.131.52 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:
- A designated forward part of one hold
- 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
- 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.
- 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
- Regulation 184.108.40.206 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.
- 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)
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)
MSC/Circ. 1432 status policy rule (13-16)
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.
7 Manual closing devices under the waterline (13-02)
For machinery spaces intended for unattended operations, the location of the controls of any valve serving a sea inlet, a discharge below the waterline and an emergency bilge system is to be such as to allow adequate time for operation in case of influx of water to the space.
The adequate time should allow enough time after the bilge level alarm in the engineer's quarters is sounded for the crew to close the valves mentioned. If for example, the valves are operable from the tank top floor and subsequent to sounding of the bilge level alarm the water level would not raise above the tank top floor in the time allowing closure of the necessary valves, such time would be considered as the “adequate time.”
A time of 10 minutes is to be used as a minimum benchmark for the 'adequate time'; if a designer selects a lesser time, the basis shall be submitted and the owner is to be made aware of the same.
In enclosed documents the applicable requirements are mentioned:
- MSC.1/Circ.1424, Unified interpretation of SOLAS Regulation II-1/48.3.
- IACS recommendation nr.100: IACS recommended practice on the time requirement for thoroughly closing sea inlets and discharges below the waterline in case of influx of water.
- Resolution A.1021(26) CODE ON ALERTS AND INDICATORS, 2009.
- IACS Unified Interpretation (UI) SC 251 on controls of emergency bilge suction valve in periodically unattended machinery spaces (SOLAS regulation II-1/48.3) as guidance.
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 220.127.116.11 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 18.104.22.168. Portable fire-extinguishing systems should be kept in good working order and readily available for immediate use:
- According to MSC.1/Circ. 1318 high pressure cylinders should be subjected to periodical tests at intervals not exceeding 10 years.
- 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.