TVIB News FAQ Category: 46 CFR Part 142 – Fire protection

What are the signage requirements for a CO2 fixed fire-extinguishing system?

Fixed fire-extinguishing carriage requirements are discussed in 46 CFR 142.315, but one must step through a few other citations to identify the signage requirements for a CO2 fixed fire-extinguishing system.

The term “Fixed fire-extinguishing system” is defined in §136.110 which includes a carbon dioxide system meeting requirements of 46 CFR subpart 76.15 and 46 CFR 78.47-9 and 78.47-11.  These citations are where you find the signage requirements.

Controls [§76.15-10(h)]

Complete, but simple operating instructions to be posted at or near all pull boxes, stop valves, and cylinder storage room.

System Schematic Diagram [§76.15-10(h)]

If cylinder storage is not within the space to be protected, the controls instructions must include a schematic diagram of the system and instructions detailing alternate methods of discharging the system should the manual release or stop valve controls fail to operate.

Control Valve to Branch Lines [§76.15-10(h)]

Each must be marked to indicate the related space served.

Carbon Dioxide Alarms [§78.47-9]

Each alarm must be conspicuously marked: “WHEN ALARM SOUNDS VACATE AT ONCE. CARBON DIOXIDE OR CLEAN AGENT BEING RELEASED.”.

Spaces Storing CO2 Cylinders [§78.47-11(a)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. VENTILATE THE AREA BEFORE ENTERING. A HIGH CONCENTRATION CAN OCCUR IN THIS AREA AND CAN CAUSE SUFFOCATION.”.

Spaces Protected by CO2 [§78.47-11(b)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. WHEN ALARM OPERATES OR WINTERGREEN SCENT IS DETECTED, DO NOT ENTER UNTIL VENTILATED. LOCK OUT SYSTEM WHEN SERVICING.”.  *

Spaces Into Which CO2 Might Migrate [§78.47-11(c)]

Each entrance to space must have a sign indicating: “CARBON DIOXIDE GAS CAN CAUSE INJURY OR DEATH. DISCHARGE INTO NEARBY SPACE CAN COLLECT HERE. WHEN ALARM OPERATES OR WINTERGREEN SCENT IS DETECTED VACATE IMMEDIATELY.”.  *

* Wintergreen Scent Note [§76.15-60]

Each carbon dioxide extinguishing system installed or altered after July 2013, must have an approved odorizing unit to produce the scent of wintergreen, the detection of which will serve as an indication that carbon dioxide gas is present in a protected area and any other area into which the carbon dioxide may migrate.  “Altered” means modified or refurbished beyond the maintenance required by the manufacturer’s design, installation, operation and maintenance manual.  If the system does not include wintergreen odorizing unit, the reference to wintergreen scent may be omitted from signage.

What are my options for reviewing the fuel shutoffs required under §143.260 during an annual survey?

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.

What are my options for storing portable fuel containers onboard a Subchapter M towing vessel?

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)).