Government consults on new fire safety regulations for ships

Ron Alalouff examines proposed regulations to improve fire safety on ships.

Fitting fire detection and suppression on cabin balconies and introducing a water mist lance for container ships are two of the proposals for new merchant shipping regulations out for consultation.

The government consultation is on the Merchant Shipping (Fire Protection) Regulations 2023, which would replace previous regulations and implement updated fire protection requirements of the International Convention for the Safety of Life at Sea 1974 (SOLAS).

The main objective of the regulations is to further improve fire protection on ships. The regulations will contain what is known as an ‘ambulatory’ reference provision, to ensure that future amendments to Chapter II-2 of SOLAS are automatically given direct effect in UK law, without the need for new regulation.

SOLAS Chapter II-2 contains provision for structural fire protection, fire detection and fire extinction on ships. This includes prevention of fire and explosion, suppression of fire, escape from fire, operational requirements, alternative design and arrangements, and other specific requirements. SOLAS Chapter 11-2 is supplemented by the Fire Safety Systems (FSS) Code and the Fire Testing Procedures (FTP) Code, all of which are amended from time to time in the International Maritime Organisation (IMO).

The proposed regulations will implement amendments made to SOLAS Chapter 11-2 which – for ships constructed before 1 July 2012 – include:

• fitting fire detection and suppression – or fitting detection and restricted fire risk furniture and surfaces – on cabin balconies
• adding another valve to the CO2 flooding fire suppression system, and for tanker ships to carry an oxygen measuring meter and a portable gas detector
• adding an audible alarm and a visual or other device to the self-contained breathing apparatus of firefighters’ outfits, and including a minimum of two portable radios for firefighters
• introducing a water mist lance capable of penetrating a container wall and producing water mist inside a confined space, on ships that carry containers above the weather deck
• container ships that are designed to carry five or more tiers of containers on or above the weather deck to carry mobile water monitors.

Amendments for new ships (constructed on or after 1 July 2012) include provisions to:

• increase the amount of sulphur dioxide allowed to be produced by carpets
• introduce a requirement for a safety centre on board
• add scuppers from spaces above or on the bulkhead deck
• ensure scuppers cannot become blocked and to ensure sufficient pumping and drainage capacity for those located below the bulkhead deck
• require tankers to have a fixed hydrocarbon gas detection system
• require an evacuation analysis for ro-ro passenger ships and other ships carrying more than 36 passengers
• remove the fire regulation exemptions for UK class XI and XII vessels.

The proposed regulations apply to all passenger vessels on international and non-international voyages (except for passenger ships operating solely in internal waters) and all cargo vessels of 500GT and over on international and non-international voyages – with some limited exceptions. The aim is to maintain a high standard of safety and to remove barriers to trade by ensuring a consistent standard of safety for fire protection on ships.

See the full list of proposed amendments

Enforcement
The Maritime and Coastguard Agency (MCA) is the UK’s regulatory authority and enforcement relies on a range of civil and criminal remedies. The most appropriate approach is determined by matters such as the importance of the requirement being breached, the gravity of the contravention, and the effect of the contravention on third parties. The general approach is to use civil sanctions wherever possible before resorting to criminal ones.

The consultation is open until 23.45 on Monday 12 September 2022. The government’s aim is to publish an overview of the responses and the MCA’s comments by November 2022, and to lay draft regulations in the autumn to come into force at the end of the year or early in 2023.

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