PREFERRED: Company to identify testing frequency within TSMS. During the annual survey the surveyor visually inspects system components and has a crew member perform a function test with the vessel safely secured at a dock, fleet, or mooring.
ALTERNATIVE: During annual survey the surveyor visually inspects system components. If vessel is underway and not able to secure at a dock, fleet, or mooring, a function test WILL NOT be performed. If documentation can be provided showing fuel shutoff valves have been tested as indicated in the TSMS, the surveyor can accept this as objective evidence of successful function testing. If there is no documentation of testing IAW the companies TSMS the surveyor will issue a finding that successful function testing was not able to be performed due to operating conditions and that there was no current documentation of testing as required by the TSMS. The anticipated corrective action plan from the vessel operator would be to have system function tested within 30 days and documentation of same provided to TVIB as objective evidence.
In either case, if the visual inspection of the Fuel Shutoff valves reveals a deficient condition, a finding will be issued and may affect the vessel’s ability to operate until a successful function test is completed to the satisfaction of the attending surveyor.
IN ALL CASES: A non-operational Fuel shutoff valve is a major non-conformity, which requires notification to TVIB within 24 hours (real-time is preferred).
NOTE: A valve is a device not a system. The operation of the valve does not act to suppress the fire. §142.240(a) specifically references “machinery shutdowns”, which requires testing every 12 months. TSMS testing frequency should identify testing frequency IAW either of the below associated references:
ASSOCIATED REFERENCES:
- §142.240 (a): All portable fire extinguishers, semi-portable fire-extinguishing systems, fire-detection systems, and fixed fire-extinguishing systems, including ventilation, machinery shutdowns, and fixed fire-extinguishing system pressure-operated dampers on board the vessel, must be inspected or tested at least once every 12 months, or more frequently if otherwise required by the TSMS applicable to the vessel.
- Table 46 CFR 143.245 (b): identifies “All other essential systems” as having a testing frequency of at least once every 3 months.
- §136.110 includes systems for suppression of fire as an essential system.
Portable fuel containers are commonly found on towing vessels. They are routinely used for fueling auxiliary equipment such as dewatering pumps, fire pumps, and auxiliary boats.
Subchapter M § 142.225 discusses the storage of flammable or combustible products, but there are other considerations in Part 147 of Subchapter N, which is probably the best place to start evaluating the question above.
Subchapter N: 46 CFR §147.1(b) – Applicability for Part 147 (Hazardous Ships’ Stores) indicates “This part applies to all vessels listed in 46 U.S.C. 3301…”. The U.S.C. 3301 includes “(15) towing vessels”. So, we know it is appropriate and acceptable to apply the requirements of § 147.45 (Flammable and combustible liquids) to a Subchapter M towing vessel.
46 CFR §147.45(f) specifies that fuel may be stored in a portable safety container meeting UL 30, UL 1313, or UL 1314. Standard plastic consumer-use fuel containers are not allowed.
You may store portable safety container(s) in any of the three locations:
- A storage cabinet meeting UL 1275 or FM 6050; and
- A storage room (i.e., paint locker) that is free of ignition sources; and
- An open location designated by the master (see § 147.45(g))
ADDITIONAL CONSIDERATIONS:
- A location designated by the master should be identifiable through signage, TSMS reference(s), and crew knowledge. It is also advisable to ensure the designated storage location adequately secures the portable safety containers from movement due to vessel maneuvers and environmental conditions.
- Refilling portable safety containers onboard the vessel requires a drip pan of adequate size and that a 10-B:C (former B-I) fire extinguisher be within 9.75 feet of the refilling location (see § 147.45(i)).
46 CFR 142.330(a)(7)
QUESTION:
What is required as evidence of a fire detection system being certified and inspected by a registered professional engineer (PE) or National Institute for Certification in Engineering Technologies (NICET) Level IV fire alarm engineering technician?
RESPONSE:
Commonly referred to as a PE Letter, auditors, surveyors, or Coast Guard inspectors will ask for documentary evidence of the certification and inspection of the vessel’s installed fire detection system. This documentation should adequately document the certification and inspection of the system. The content and layout of these letters vary among the individuals that make these attestations. TVIB has communicated with the TVNCOE, and various PE/NICET individuals, and reviewed multiple versions of these letters. While no specification for the content of these letters can be pointed to, we have been able to identify what a towing vessel owner/operator should reasonably expect to see in these letters.
Expected content of PE/NICET letters for an installed fire detection system:
- Vessel Name and Official Number
- Date of Inspection
- A statement that the system complies with 46 CFR 142.330 or individually lists each of the requirements under §142.330
- Identify the control panel make/model and serial number
- A list of smoke and/or heat detectors installed throughout the vessel including the make/model and location and/or a basic diagram indicating the same
- A letter produced on the letterhead of the PE/NICET that bears the printed name, signature, and stamp of the PE/NICET
WHAT TO DO IF THE PE/NICET LETTER DOES NOT CONTAIN THE ABOVE INFORMATION:
It is not required to have your PE/NICET letter reissued. However, at such time any change or modification to the system is performed a new PE/NICET letter is required so that the system is certified and inspected to verify compliance. This would be the time to discuss with your hired PE/NICET your expectations for their letter.
