MARINE FIRE SAFETY : MARINE FIRE SAFETY Objectives:
The International framework for standards on fire protection.
State Legislation – how it relates to Commonwealth and between States
Developing appropriate standards for coastal vessels – the NSCV
Typical fire safety systems International Maritime Organisation : International Maritime Organisation The International Maritime Organisation (IMO) is a UN body dealing with marine safety.
The IMO develops a range of codes / standards:
The IMO has:
General assembly (all countries)
Council (executive management)
In relation to fire safety, the Committee concerned is the Maritime Safety Committee (MSC)
The MSC has a fire protection sub- committee IMO – Instruments : IMO – Instruments There is a hierarchy of standards produced by IMO:
Conventions ( SOLAS relates to fire)
These are adopted under particular criteria –eg SOLAS -entry into force requires acceptance by 25 States whose merchant fleets comprise not less than 50 per cent of the world's gross tonnage
Circulars (specific advice / interpretation that is more detailed or refines a convention)
Circulars relating to fire safety are produced by the Maritime Safety Committee (MSC)
Eg MSC/Circ 776 – Guidelines for the approval of equivalent fixed gas fire extinguishing systems for machinery spaces and cargo pump rooms
Codes – eg the Fire Safety System Code – detailed specifications (eg fire extinguishers)
Codes – Fire Test Procedure Code – details of testing procedures for fire products Commonwealth Legislation : Commonwealth Legislation The Australian Maritime Safety Authority (AMSA) provide input for Australia on technical standards developed by IMO
Once an IMO Convention comes into force, the Commonwealth makes legislation to enforce the convention.
Generally, Fire Safety comes under the Navigation Act 1912 and Marine Orders made under the Nav Act. Marine Orders. : Marine Orders. Marine Orders Part 15 simply says SOLAS is the standard to adopt.
It then flows on that all lesser documents under SOLAS (Circulars, Codes) become law under Marine Orders Part 15
SOLAS is primarily relevant to “ships” not boats
MO Part 15 says that the USL Code applies to vessels that are not “SOLAS” vessels. This relates to vessels up to 35 metres / 500GRT operating on intra and inter state voyages. USL Code : USL Code There is a need for a different standard for smaller commercial vessels rather than SOLAS– this is the Uniform Shipping Law Code (USL Code)
The USL Code was made by the Australian Transport Council in the 1970’s. It is a watered down version of IMO and Classification Society rules that made practical rules for small coastal vessels.
All States were involved in formulating the USL Code, and once finalised, all States made legislation enforcing the USL Code. Problems with the USL Code : Problems with the USL Code The formation of the USL Code did not include a review and update process so it became out of date.
The Code was inflexible because it was highly prescriptive.
The Code couldn’t deal with new designs, novel craft etc
The Code is ambitious because it tries to deal with a large range of vessels under one set of rules.
The Code is applied differently in States due to different interpretation of requirements.
The Code is applied differently in States due to political, legislative and local requirements.
This led to a Inter-Governmental Agreement in 1997 that agreed to review the USL Code using a new body called the National Marine Safety Committee. The NMSC / NSCV : The NMSC / NSCV The NMSC is gradually overhauling the USL Code and developing a new document called the National Standard for Commercial Vessels (NSCV).
The NSCV is designed to be more flexible and not outdate immediately.
The NSCV covers not only vessel design but operator competency and safety management. General philosophy of the NSCV : General philosophy of the NSCV Get to the heart of what is trying to be achieved in the standard.
Set requirements for safety based on risk assessment principles and cost benefit analysis.
Provide a performance statements (safety outcomes) that are the non-negotiable safety outcomes.
Provide prescriptive solutions to meet the safety outcome but also accept “equivalent solutions” where an alternative means to the prescriptive measure can still meet the safety outcome. The Fire Safety Section Development : The Fire Safety Section Development NMSC appoint a project leader and reference group.
A discussion paper is distributed defining problems with existing standard and examining fire casualties and identifying causes.
A draft standard is produced based on discussion paper and responses and is finalised by reference group.
A Regulatory Impact Statement is developed which describes the impacts, benefits costs that the proposed new standard will cause.
The RIS and draft standard are distributed for general consultation.
The reference group will consider the comment and propose a final draft of the standard.
The standard must then be endorsed by the NMSC and the ATC
The standard then still means nothing until States adopt it into legislation! Benefits of this approach: : Benefits of this approach: New technologies / materials can easily be accepted without changing the law.
Novel craft and design features can be used without changing the law.
Stakeholders understand what the standard is trying to achieve.
The standard stays workable and flexible for longer periods without review.
The Standard makes realistic requirements based on evidence received during risk assessments. Benefits of this approach : Benefits of this approach It provides a prescriptive solution that provides good guidance in most cases. This gives comfort to designers, builders and regulators. (Cheapest option also)
It allows for innovation providing a product, design or system can be rigorously proven to meet the safety outcome. This is the more expensive option and will only really be taken up where prescriptive solutions cannot be used or where large cost savings are derived from the alternative approach. Slide 13: SAFETY OUTCOMES OF FIRE SAFETY STANDARD:
Prevention of explosive combustion
Control risks of spillage of flammable liquids
Control risks of ignition by sources of heat or sparks
Prevention of exposure to the smoke and heat of fire
Prevent or delay the spread of fire
Protection of essential systems
Reliability of fire systems HOW IS RISK ACCOUNTED FOR? : HOW IS RISK ACCOUNTED FOR? Studies found fire risk (both probability and consequence) related to:
The nature of the space on the vessel – engine rooms and galleys have highest incidence of fire. Larger engine rooms are a greater risk/
The nature of the vessel operation – tankers and passenger carrying vessels have far higher consequence if fire occurs.
Distance from Coast determines the level of external support that can be relied upon. Vessels operating further from the coast need to have better fire safety. Vessel Risk Categories : Vessel Risk Categories Four fire risk categories are defined as follows—
Fire Risk Category I (lower risk)
Fire Risk Category II (moderate risk)
Fire Risk Category III (higher risk)
Fire Risk Category IV (highest risk) Risk categories of spaces on vessels : Risk categories of spaces on vessels High Risk
Escape and Evacuation routes
Where doubt exists or compartment is multi use – higher risk level applies Slide 19: Examples- Machinery spaces with IC engines, boiler spaces, carriage dangerous goods, flammable goods. Limits are set on magnitude. Slide 20: Examples – Low power machinery spaces, electrical switchboard rooms, galleys, fuel pumping equipment etc Slide 21: Examples – sleeping rooms, mess rooms, pantries, toilets, public rooms Slide 22: Table 27 —Fire-fighter’s outfits for sea-going vessels KEY:
Two sets are for the use of a rescue party. The third is available for backup person should the rescue party get into difficulties.
It is assumed that vessels operating in sheltered waters will have ready access to shore-based fire fighting personnel, see Part A of this standard for guidance on safety obligations and Part E for emergency preparedness. Slide 23: Table 7 — Structural Fire Protection for Fire Risk Category I Examples of fire safety systems / measures : Examples of fire safety systems / measures