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.