Incident Report

Subject:           USCG - Harmonization of Standards for Fire Protection, Detection, and Extinguishing Equipment; Proposed Rule

Date of Email report:   Tue 14/01/2014

Report Detail:

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The Coast Guard proposes to amend its regulations for certain design and approval standards for fire protection, detection, and extinguishing equipment on inspected and uninspected vessels, outer continental shelf facilities, deep-water ports, and mobile offshore drilling units. The proposed amendments would harmonize Coast Guard regulations with appropriate national and international consensus standards; address advances in fire protection technologies and standards; update Coast Guard approval processes for fire detection and alarm systems; and revise Coast Guard regulations for other types of equipment or components, such as spanner wrenches, non-metallic pipes, and sprinkler systems. These proposed changes are necessary to ensure Coast Guard regulations remain current and address advances in technology.

Executive Summary


Purpose of the Regulatory Action
This proposed regulatory action is necessary to update Coast Guard regulations pertaining to certain design and approval standards for fire detection and alarm systems, fire extinguishers, and other fire prevention equipment used on inspected and uninspected vessels, Outer Continental Shelf (OCS) facilities, deep-water ports, and mobile offshore drilling units (MODUs). The proposed updates would harmonize our regulations with national and international industry consensus standards, and incorporate other advances in fire protection technologies and standards.

The basis of this notice of proposed regulatory action is the Secretary of Homeland Security's regulatory authority under the following statutes. Section 1333 of Title 43, United States Code (U.S.C.) mandates the issuance of safety equipment regulations on OCS facilities; 46 U.S.C. 3306 mandates the issuance of fire-fighting material and equipment regulations for Coast Guard inspected vessels and the issuance of structural fire protection and equipment regulations for small passenger vessels; 46 U.S.C. 3703 mandates fire-fighting equipment and material regulations for vessels carrying liquid bulk dangerous cargoes; 46 U.S.C. 4102 authorizes marine safety equipment regulations for fire extinguishers, life preservers, engine flame arrestors, engine ventilation, and emergency locating equipment on uninspected vessels, and authorizes regulations, after consultation with the Towing Safety Advisory Committee, for fire protection and suppression measures on towing vessels; 46 U.S.C. 4302 authorizes safety equipment such as fire-fighting equipment regulations for recreational vessels; and 46 U.S.C. 4502 mandates fire extinguisher regulations for some uninspected commercial fishing vessels and authorizes safety equipment regulations for certain other uninspected commercial fishing vessels. Section 1509 of Title 33, U.S.C., authorizes the Coast Guard to promulgate regulations for safety equipment relating to the promotion of safety of life and property in deep-water ports. The Secretary of Homeland Security has delegated these statutory authorities to the Coast Guard through Delegation No. 0170.1.

Under the statutory authorities listed above, the Coast Guard is authorized to develop and maintain standards for fire protection, detection, and extinguishing equipment on inspected and uninspected vessels, OCS facilities, deep-water ports, and MODUs. The Coast Guard implements these authorities through regulations specified in Table 1. Table 1 lists the subchapters in Titles 33 and 46 of the Code of Federal Regulations (CFR) affected by this proposed regulatory action (collectively referred to as “affected subchapters”), and provides a breakdown of each subchapter by subject matter.

CFR title       Subchapter      Parts   Topic  
33      N       140-147 Outer Continental Shelf Activities.    
33      NN      148-150 Deep-water Ports.      
46      C       24-28   Uninspected Vessels.   
46      D       30-39   Tank Vessels.  
46      F       50-64   Marine Engineering.    
46      H       70-89   Passenger Vessels.     
46      I       90-105  Cargo and Miscellaneous Vessels.       
46      I-A     107-109 Mobile Offshore Drilling Units.
46      J       110-113 Electrical Engineering.
46      K       114-124 Small Passenger Vessels Carrying more than 150 Passengers or with Overnight Accommodations for more than 49 Passengers.
46      L       125-139 Offshore Supply Vessels.       
46      N       140-149 Dangerous Cargoes.     
46      Q       159-165 Equipment, Construction and Material Specifications and Approval.      
46      R       166-169 Nautical Schools.      
46      T       175-187 Small Passenger Vessels (Under 100 Gross Tons (GT)).   
46      U       188-196 Oceanographic Research Vessels.
Table 1

Summary of the Major Provisions of the Proposed Regulatory Action

The major proposed provisions of this regulatory action harmonize Coast Guard regulations with national and international industry consensus standards and update Coast Guard regulations to incorporate advances in fire protection technology for specific types of fire protection, detection, and extinguishing equipment. Provisions are discussed below and are grouped by equipment type or topic.

Fire detection and alarm systems:

  • Provide vessels with the option to meet either the applicable International Convention for the Safety of Life at Sea, 1974 (SOLAS) and the International Maritime Organization (IMO) Fire Safety Systems (FSS) Code requirements, or updated Coast Guard regulations for the design and installation of fire detection and alarm systems. These proposed changes would provide vessel owners and/or operators and designers greater flexibility in fire detection and alarm system design for U.S. domestic vessels.
  • Consolidate and update the fire detection and alarm system requirements in 46 CFR subchapter H (passenger vessels). These changes would also affect 46 CFR subchapters C, I, K, and T vessels where the regulations refer to subchapter H for fire detection and alarm system requirements. The consolidation of these requirements would make it easier for industry to locate and meet these requirements. The proposed updates reflect advancements in the fire detection and alarm systems industry, which include development of digital technology and modern seamless electronic technology for the much larger land-based market. The Coast Guard would not require retrofitting of currently installed systems, but would require any modifications to installed systems or new installations to comply with the updated requirements after a21/2year compliance period.
  • Revise Coast Guard approval processes for fire detection and alarm systems by allowing manufacturers of fire detection and alarm systems equipment the option of seeking approval for an entire system or an individual device; making approval processes easier for manufacturers by allowing some approval tests to be completed by an approved third party nationally recognized testing laboratory (NRTL); and requiring the use of the most current and widely used national consensus standards for approval of fire detection and alarm systems, as specified by this rulemaking. These revisions would allow for an easier replacement of individual devices and open the market to small manufacturers or to those dedicated to making components but not producing all components necessary for a complete detection system. They would also provide manufacturers more flexibility and options for choosing a laboratory; and align our regulations with the most up-to-date national consensus standards that are already widely used by the fire detection industry.


Fire extinguishers:

  • Replace the Coast Guard's weight-based rating system for fire extinguishers with the Underwriters Laboratory (UL) performance-based rating system. Adopting the national industry standard rating system would streamline the selection, inspection, and approval processes for marine fire extinguishers.
  • Revise maintenance requirements for fire extinguishers by adopting National Fire Protection Association (NFPA) 10 “Standard for Portable Fire Extinguishers” (2010 Edition), which requires certified personnel to conduct annual fire extinguishing equipment maintenance. NFPA 10 distinguishes between monthly inspections (a visual check) and annual maintenance (a thorough inspection of materials and components, and associated repairs). Vessel crewmembers could continue to perform monthly inspections, however, a certified person would be required to conduct annual maintenance. This proposed change would align Coast Guard regulations with the current industry practice of having annual maintenance performed by commercial servicing companies.
  • Codify use of UL standards for testing and labeling of fire extinguishers. These standards provide detailed, technical requirements for construction, performance, testing, packaging, and marking of the specific type of extinguisher. This proposed change would align Coast Guard regulations with current industry practice.
  • Reduce the number of spare portable fire extinguishers required on vessels traveling domestic routes. This change is proposed because of the proposed enhanced maintenance requirements that would result in more reliable spares, as well as making new spares more easily obtainable.

Other fire protection equipment:

  • Require small passenger vessels to carry spanner wrenches for fire hydrants that use 1.5-inch diameter hoses. This proposed requirement for small passenger vessels is consistent with spanner wrench carriage requirements for other vessel types, and is necessary to ensure that fire hoses can be replaced and deployed as needed.

Fire protection equipment approvals:

  • Add new specification subparts in 46 CFR subchapter Q to address existing and new approval series for fire protection equipment and components required for use on SOLAS ships. The new approval series would codify the standards and procedures currently used by industry to obtain Coast Guard approval for fire protection equipment and components required on SOLAS ships. The new approval series would set forth design, construction, testing, and performance requirements for the affected equipment and components satisfying SOLAS requirements.
  • Codify an alternative path to Coast Guard approval through an existing Mutual Recognition Agreement (MRA) to which the U.S. is a party, allowing for Coast Guard approvals of certain fire protection equipment issued by another nation that is party to the MRA. This proposed change would reduce manufacturer costs and burdens associated with duplicative testing and evaluation for multiple national approvals.

Additional Documentation:

Harmonization of Standards for Fire Protection, Detection, and Extinguishing Equipment; Proposed Rule