Circular Letter
MSC/Circ.1120

UNIFIED INTERPRETATIONS OF SOLAS CHAPTER II-2, THE FSS CODE, THE FTP CODE AND RELATED FIRE TEST PROCEDURES

(2 June 2004)

 

1. The Maritime Safety Committee, at its seventy-eighth session (12 to 21 May 2004), with a view to providing more specific guidance for vague expressions such as "to the discretion of the Administration", which are open to different interpretations contained in IMO instruments, approved the unified interpretations of SOLAS chapter II-2, the FSS Code, the FTP Code and related fire test procedures prepared by the Sub-Committee on Fire Protection, as set out in the annex.

 

2. Member Governments are invited to use the annexed unified interpretations as guidance when applying relevant provisions of SOLAS chapter II-2, the FSS Code, the FTP Code and related fire test procedures to fire protection construction, installation, arrangements and equipment to be installed on board ships on or after 1 July 2004 and to bring the unified interpretations to the attention of all parties concerned.

 

ANNEX.

UNIFIED INTERPRETATIONS OF SOLAS CHAPTER II-2, THE FSS CODE, THE FTP CODE AND RELATED FIRE TEST PROCEDURES

INTERPRETATIONS OF VAGUE EXPRESSIONS AND OTHER VAGUE WORDING WITH REFERENCES TO SOLAS CHAPTER II-2, AS AMENDED BY RESOLUTION MSC.99(73)

 

 

SOLAS

Chapter II-2

Interpretation or reference

Part

Regulation

Application

A

1.3.2

Examples of repairs, alterations and modifications

 

1. Example of substantial alteration of the dimensions of a ship:

 

Lengthening by adding a new midbody; the new midbody should comply with chapter II-2 of SOLAS 1974, as amended.

 

2. Example of substantial alteration of the passenger accommodation spaces:

 

A vehicle deck converted to passenger accommodation spaces; new accommodation spaces should comply with chapter II-2 of SOLAS 1974, as amended.

 

3. Example of substantial increase of a ship's service life:

 

Renewal of passenger accommodation spaces on one entire deck; renewed accommodation spaces should comply with chapter II-2 of SOLAS 1974, as amended. However, in this case, means of escapes in the areas not subject to renewal are not required to be reviewed in the light of new requirements.

A

3.1

Devices in pantries or isolated pantries containing no cooking appliances

 

Pantries or isolated pantries containing no cooking appliances may contain:

 

.1 coffee automats, toasters, dish washers, microwave ovens, water boilers, induction heaters and similar appliances each of them with a maximum power of 5 kW; and

 

.2 electrically heated cooking plates and hot plates for keeping food warm each of them with a maximum power of 2 kW and a surface temperature not above 150C.

 

A dining room containing such appliances should not be regarded as a pantry.

 

This interpretation also covers regulations 9.2.2.3.2.2(9), 9.2.2.4.2.2(3), 9.2.3.3.2.2(3) and 9.2.4.2.2.2(3).

A

3.2.1

3.2.2

Application of "light-weight constructions"

 

Light-weight constructions (honeycomb type, etc.) of steel or equivalent material may be used as non load-bearing internal "A" class division in accommodation and service spaces provided they have successfully passed the relevant standard fire test according to the FTP Code.

 

These light-weight constructions should not be used as an integral part of main fire zone bulkheads and stairway enclosures on passenger ships.

A

3.9.9

Explanations to communication systems

 

The communication systems here mean only internal communication systems, which are required by the regulations.

 

A

3.10

Adhesives in C class construction

 

Adhesives used in the construction of the C class divisions are not required to be non-combustible; however, they are to have low flame-spread characteristics.

A

3.18

Explanation for control stations

 

1. Main navigational equipment includes, in particular, the steering stand and the compass, radar and position-finding equipment.

 

2. Steering gear rooms containing an emergency steering position are not considered to be control stations.

 

3. Where in the regulations of chapter II-2 relevant to fixed fire-extinguishing systems there are no specific requirements for the centralization within a control station of major components of a system, such major components may be placed in spaces which are not considered to be a control station.

 

4. Spaces containing, for instance, the following battery sources should be regarded as control stations regardless of the battery capacity:

 

.1 emergency batteries in separate battery room for power supply from black-out till start of the emergency generator;

 

.2 emergency batteries in separate battery room as reserve source of energy to radio installation;

 

.3 batteries for start of the emergency generator; and

 

.4 in general, all emergency batteries required in pursuance of regulation II-1/42 or II-1/43.

A

3.45

Devices in main pantries, pantries containing cooking appliances and galleys

 

1. Main pantries and pantries containing cooking appliances may contain:

 

.1 coffee automats, toasters, dish washers, microwave ovens, water boilers, induction heaters and similar appliances each of them with a power of more than 5 kW; and

 

.2 electrically heated cooking plates and hot plates for keeping food warm each of them with a maximum power of 5 kW. This interpretation also covers regulations 9.2.2.3.2.2(13) and 9.2.2.4.2.2(9).

 

2. Spaces containing any electrically heated cooking plate or hot plate for keeping food warm with a power of more than 5 kW should be regarded as galleys.

B

4.2.1.4

Use of fuel oil having a flashpoint of 43C or less and crude oil or slop for tanker boilers

 

1. Machineries and piping systems for the usage of fuel oil having a flashpoint of 43C or less should comply with the following:

 

.1 provisions for the measurement of oil temperature should be provided on the suction pipe of oil fuel pump;

 

.2 stop valves and/or cocks should be provided to the inlet side and outlet side of the oil fuel strainers; and

 

.3 pipe joints of welded construction or of circular cone type or spherical type union joint should be applied as much as possible.

 

2. Reference is made to IACS requirement M 24 Requirements concerning use of crude oil or slop as fuel for tanker boilers.

 

B

4.2.2.3.4

Controls for remote operation of the valve for emergency generator fuel tank

 

The wording separate location does not mean separate spaces.

B

4.2.2.4

4.2.3.1

Position of air pipe outlets

 

Air pipes from oil fuel tanks or heated lubricating oil tanks should be led to a safe position on the open deck. They should not terminate in any place where a risk of ignition is present. Air pipes from unheated lubricating oil (including hydraulic oil) tanks may terminate in the machinery space, provided that the open ends are so situated that issuing oil cannot come into contact with electrical equipment or heated surfaces.

B

4.2.4

Arrangements for other flammable oils

 

The second sentence of regulation 4.2.4 is not applicable to hydraulic valves and cylinders located on weather decks, in tanks, cofferdams, or void spaces.

B

4.4.1

Electric Radiators

 

Reference is made to IEC Publication 60092 - Electrical installations in ships.

B

4.4.2

Waste receptacles

 

This regulation is not intended to preclude the use of containers constructed of combustible materials in galleys, pantries, bars, garbage handling or storage spaces and incinerator rooms provided they are intended purely for the carriage of wet waste, glass bottles and metal cans and are suitably marked.

B

4.4.3

Surface protection of insulation

 

The fire insulation in such spaces can be covered by metal sheets (not perforated) or by vapour barrier glass cloth accurately sealed at the joint.

B

4.5.1

Construction of cofferdams and prohibition of containment of cargo, wastes and goods

 

The expression cofferdam means, for the purpose of this regulation, an isolating space between two adjacent steel bulkhead or decks. The minimum distance between the two bulkheads or decks should be sufficient for safe access and inspection. In order to meet the single failure principle, in the particular case when a corner-to-corner situation occurs, this principle may be met by welding a diagonal plate across the corner (see figure of regulation 4.5.1 in the appendix). No cargo, wastes or other goods should be contained in cofferdams.

B

4.5.1.1

Separation of cargo oil tanks

 

Pump-rooms intended solely for ballast transfer need not comply with the requirements of regulation 4.5.10. The requirements of regulation 4.5.10 are only applicable to the pumprooms where pumps for cargo, such as cargo pumps, stripping pumps, pumps for slop tanks, pumps for COW or similar pumps are provided.

 

B

4.5.2.2

Gastightness test for navigation bridge external doors and windows

 

The navigation bridge external doors and windows which are located within the limits of regulation 4.5.2.1 should be tested for gastightness. If a water hose test is applied, the following may be taken as a guide:

 

- nozzle diameter: minimum 12 mm;

- water pressure just before the nozzle: not less than 0.2 N/mm2; and

- distance between the nozzle and the doors or windows: maximum 1.5 m.

B

4.5.3.4.1.3

Area classification and selection of electrical equipment

 

1. Areas on open deck, or semi-enclosed spaces on open deck, within a vertical cylinder of unlimited height and 6m radius centred upon the center of the outlet, and within a hemisphere of 6m radius below the outlet which permit the flow of large volumes of vapour, air or inert gas mixtures during loading/discharging/ballasting are defined as Zone 1. Permitted electrical equipment:

 

- Certified safe type equipment for Zone 1.

 

2. Areas within 4 m beyond the zone specified in 1 above are defined as Zone 2. Permitted electrical equipment:

 

- Certified safe type equipment for Zone 1;

- Equipment of a type, which ensures the absence of sparks, hot spots during its normal operation;

- Equipment having an enclosure filled with a liquid dielectric, the application, or encapsulated;

- Pressurized equipment; and

- Equipment specifically designed for Zone 2 (for example type n protection in accordance with IEC 60079-15).

 

Note:

Zones 1 and 2 are those defined in IEC Publication IEC 60092 Electrical installations in ships - Part 502: Tankers - Special features

B

4.5.3.4.1.4

Reference to IEC 60092-502

 

Electrical equipment fitted in compliance with IEC Publication 60092 - Electrical installations in ships - Part 502: Tankers - Special features is not considered a source of ignition or ignition hazard.

B

4.5.5.3.3

Meaning of closed ullage system

 

Closed ullage system means a system which allows cargo measurement without breaking the integrity of the tank.

B

 

 

 

 

 

B

4.5.6.1

Location of outlets and reference to MSC/Circ.677 and MSC/Circ.731

 

1. The outlets mentioned in regulation 4.5.6.1 should be located in compliance with regulation 4.5.3.4.1.3 as far as the horizontal distance is concerned.

 

2. Refer to MSC/Circ.677, as amended by MSC/Circ.1009 - Revised standards for the design, testing and locating of devices to prevent the passage of flame into cargo tanks in oil tankers, and to MSC/Circ.731 - Revised factors to be taken into consideration when designing cargo tank venting and gas-freeing arrangements.

 

B

4.5.10.1.2

Emergency lighting

 

Where the lighting in cargo pump-rooms can be commonly used as the emergency lighting, this lighting should be interlocked with the ventilation systems. However, this interlock should not prevent operation of the emergency lighting in case of the loss of the main source of electrical power.

B

4.5.10.1.3

Monitoring the concentration of hydrocarbon gases in cargo pump-rooms on oil tankers

 

1. Sequential sampling is acceptable as long as it is dedicated for the pump room only, including exhaust ducts, and the sampling time is reasonably short.

 

2. Detection positions are the zones where air circulation is reduced (e.g. recessed corners).

B

4.5.10.1.4

Bilge level monitoring devices

 

Bilge high-level alarms are acceptable as an alternative means for the level monitoring devices.

B

5.2.2.4

Location of ventilation controls in category A machinery spaces

 

In machinery spaces of category A, controls to close off ventilation ducts and pipes should be installed with due regard to the hot gases produced by a fire in the space concerned.

B

5.3

6.2

Materials used on passenger ships for bulkheads of accommodation spaces as defined in regulation 3.1

 

With respect to materials and components used for bulkheads in accommodation spaces, as defined in regulation 3.1, see tables for regulations 5.3 and 6.2 in the appendix.

B

5.3

6.2

Fire protection materials for cargo ships

 

With respect to materials and components used for bulkheads in accommodation spaces, as defined in regulation 3.1, see tables for regulations 5.3 and 6.2 in the appendix.

B

5.3.1.1

Meaning of cold service systems

 

Cold service is understood to mean refrigeration systems and chilled water piping for air-conditioning systems.

B

5.3.2.2

Calorific value

 

Reference is made to the recommendations published by the International Organization for Standardization, in particular, Publication ISO 1716:2002 on Determination of the heat of combustion.

B

5.3.2.4

Application to materials used on surfaces of bulkheads, ceilings and linings

 

Surfaces referred to in regulation 5.3.2.4 are those of bulkheads, decks, floor coverings, wall linings and ceilings as appropriate. The requirements described within these regulations are not meant to apply to plastic pipes, electric cables, and furniture.

 

B

6.2

Application to materials used for bulkheads and on surfaces of bulkheads, ceilings and linings

 

Surfaces referred to in regulation 6.2 are those of bulkheads, decks, floor coverings, wall linings and ceilings as appropriate. The requirements described within these regulations are not meant to apply to plastic pipes, electric cables, and furniture.

C

7.8.3

Degree of protection and audibility of two-way portable telephone apparatus used in special cargo spaces

 

1. On ships provided with special category spaces, ro-ro spaces or cargo spaces for the carriage of dangerous goods, the two-way portable telephone apparatus should be of certified safe type for use in zone 1 areas as defined in IEC Publication 60079 - Electrical Apparatus for Explosive Gas Atmospheres.

 

2. Two-way portable telephone apparatus should be audible from most parts of the ship. As a minimum, they should be audible where the fire patrol makes their rounds such as key box locations and the routes specified on fire patrol checklist. If necessary, extra antennas should be fitted to obtain effective communication.

C

8.2

Equally effective local ventilation closing arrangements for control stations

 

Equally effective local closing arrangements means that in case of ventilators these should be fitted with fire dampers or smoke dampers which could be closed easily within the control station in order to maintain the absence of smoke in the event of fire.

C

8.3.3

Location of ventilation controls in category A machinery spaces

 

In machinery spaces of category A, controls to close off ventilation ducts and pipes should be installed with due regard to the hot gases produced by a fire in the space concerned.

C

8.4

Construction and location of draught stops

 

1. Any of the following methods of construction may be used to construct draught stops:

 

.1 the extension of the "B" Class bulkhead, ceiling or lining;

 

.2 the extension of the "C" Class bulkhead, ceiling or lining;

 

.3 1 mm thick minimum steel sheet, stiffened where necessary, intermittently welded to the ship's structure and the top profile of the bulkhead, or fastened mechanically to the ceilings or linings;

 

.4 non-combustible board type material fastened mechanically to the ship's structure, bulkheads, ceilings or linings; or

 

.5 non-combustible mineral wool insulation, not less than 20 mm in thickness, faced on each side with expanded metal mesh, the mesh on one side being attached to the ship's structure, or expanded metal mesh may be fitted on one side and non-combustible cloth (glass-cloth) on the other side of mineral wool insulation. Other equivalent arrangements may be accepted.

 

2. Draught stops are not required in public spaces with open ceilings (perforated ceilings) with openings of 40% or more.

 

C

8.5

Arrangement of exhaust fans for smoke extraction systems

 

The application of this regulation does not imply the arrangement of additional exhaust fans other than those normally dedicated to the space considered, if these latter fans are of sufficient size to meet the required capacity.

C

9.2.2.1

Main vertical zones and horizontal zones

 

If a stairway serves two main vertical zones, the maximum length of one main vertical zone should be measured from the far side of the main vertical zone stairway enclosure. In this case, all boundaries of the stairway enclosure be insulated as main vertical zone bulkheads and access doors leading into the stairway should be provided from the zones (see figures 1 to 4 for regulation 9.2.2.1 in the appendix). However, the stairway should not be included in calculating the size of the main vertical zone if it is treated as its own main vertical zone.

C

9.2.2.2.2.1

Construction of extended bulkhead behind continuous ceilings or linings

 

The extension of the bulkhead should be made of non-combustible material and the construction of the extension should correspond to the fire class of extended bulkhead. If the extended bulkhead is of B-0, then the extension may be made of thin steel plates of 1 mm thickness and tightened (e.g. with mineral wool). Alternatively, B-0 class extensions may be constructed of a suitably supported mineral wool (density at least 100 kg/m3, thickness at least 50 mm).

C

9.2.2.2.3

Bulkheads within a main vertical zone

 

Refer to MSC/Circ.917

C

9.2.2.3.2.2 (7)

Electrical distribution boards

 

Distribution boards may be located behind panels/linings within accommodation spaces including stairway enclosures, without the need to categorize the space, provided no provision is made for storage. If distribution boards are located in an identifiable space having a deck area of less than 4 m2, this space may be categorized in (7), according to regulation 9.2.2.3.2.2, or (5), according to regulations 9.2.2.4.2.2, 9.2.3.3.2.2 and 9.2.4.2.2.2

C

9.2.2.3.2.2 (7)

Devices in diet kitchens

 

Diet kitchens (containing no open flame) should be in compliance with the interpretation for pantries as stated under regulation 3.1.

C

9.2.2.4.2.2 (5)

Electrical distribution boards

 

Distribution boards may be located behind panels/linings within accommodation spaces including stairway enclosures, without the need to categorize the space, provided no provision is made for storage. If distribution boards are located in an identifiable space having a deck area of less than 4 m2, this space may be categorized in (7), according to regulation 9.2.2.3.2.2, or (5), according to regulations 9.2.2.4.2.2, 9.2.3.3.2.2 and 9.2.4.2.2.2.

 

C

9.2.2.4.5

Construction and arrangements of saunas

 

The space categories mentioned in regulation 9.2.2.3.4.1 should be replaced, when applying this regulation, by (5), (7) and (10).

C

table 9.3

table 9.4

Interpretation of machinery spaces having little or no fire risk

 

For the definition of machinery spaces having little or no fire risk in footnote "f" see regulation 9.2.2.3.2.2 (10).

C

9.2.3.1.1.3

Increased area of public spaces

 

The area of public spaces may be permitted to increase up to 75 m2.

C

9.2.3.2.4

Increased area of public spaces

 

The area of public spaces may be permitted to increase up to 75 m2.

C

table 9.5

table 9.6

Interpretation of machinery spaces having little or no fire risk

 

For the definition of machinery spaces having little or no fire risk in footnote "i" see regulation 9.2.2.3.2.2 (10).

C

9.2.3.3.2.2 (5)

Electrical distribution boards

 

Distribution boards may be located behind panels/linings within accommodation spaces including stairway enclosures, without the need to categorize the space, provided no provision is made for storage. If distribution boards are located in an identifiable space having a deck area of less than 4 m2, this space may be categorized in (7), according to regulation 9.2.2.3.2.2, or (5), according to regulations 9.2.2.4.2.2, 9.2.3.3.2.2 and 9.2.4.2.2.2.

C

9.2.3.3.5

Construction and arrangements of saunas

 

The space categories mentioned in regulation 9.2.2.3.4.1 should be replaced, when applying this regulation, to categories (5), (7) and (10).

C

9.2.3.4.1

Construction of protected stairways

 

The required protection of stairways penetrating more than a single deck can be achieved by:

 

.1 a stairway enclosure allowing access from one stair to a superimposed stair within such enclosure, the entrances to which should consist self-closing "A" class fire doors at each deck level (see figure 1 of regulation 9.2.3.4.1 in the appendix); or

 

.2 a stairway enclosure enclosing the stairs only, in combination with self-closing "A" class fire doors at each deck-level and at each end of a stair. No requirements apply to the stairs except that they should be of steel frame structure or be made of equivalent material (see figure 2.1 of regulation 9.2.3.4.1 in the appendix); or

 

.3 stairways that penetrate only one single deck should be protected, at a minimum, at one level by at least B-0 class division and self-closing doors (see figure 2.2 of regulation 9.2.3.4.1 in the appendix).

 

C

9.2.3.4.1

Construction of dumb-waiters

 

Dumb-waiters are to be regarded as lifts.

C

9.2.4.2.2.2 (5)

Electrical distribution boards

 

Distribution boards may be located behind panels/linings within accommodation spaces including stairway enclosures, without the need to categorize the space, provided no provision is made for storage.

 

If distribution boards are located in an identifiable space having a deck area of less than 4 m2, this space may be categorized in (7), according to regulation 9.2.2.3.2.2, or (5), according to regulations 9.2.2.4.2.2, 9.2.3.3.2.2 and 9.2.4.2.2.2

C

9.2.4.2.7

Construction and arrangements of saunas

 

The space categories mentioned in regulation 9.2.2.3.4.1 should be replaced, when applying this regulation, by (5), (7) and (10).

C

table 9.7

table 9.8

Interpretation of machinery spaces having little or no fire risk

 

For the definition of machinery spaces having little or no fire risk in footnote "e" see regulation 9.2.2.3.2.2 (10).

C

9.3.1

Reference to resolution A.753(18)

 

Reference is made to resolution A.753(18) - Guidelines for the application of plastic pipes on ships.

C

9.3.4

Prevention of heat transmission by insulation and structural details for drainage

 

1. Details of measures to be adopted for avoiding heat transmission at intersections and terminal points of insulation of decks or bulkheads are given in figures 1 and 2 of regulation 9.3.4 in the appendix.

 

Alternative details may be accepted provided that the effectiveness of such design is verified by an appropriate test in the same manner as those specified in the FTP Code.

 

2. In the case where the lower part of insulation has to be cut for drainage, the construction should be in accordance with the structural details as given in figure 3 for regulation 9.3.4 in the appendix.