The different fire safety regulations in SOLAS chapter II-2 have been analysed with the intention to identify
important factors that could be necessary to address when using FRP elements in ship
structures. These factors are described in the following paragraphs. Each of the
regulations with prescriptive requirements (regulations 4 to 23) starts with a
purpose statement. Each purpose statement consists of a regulation objective and one
or several regulation functional requirements. The purpose statements have been
reproduced for each regulation followed by comments on how a ship with FRP elements
may challenge the regulation. The regulations are not only investigated based on
potential deviations and how these may have an effect on safety but also in a
broader sense, i.e. how a ship with FRP composite structures could affect the
regulations' purpose statements or envisioned purpose.
Note that this investigation of the regulations is not complete and may not cover all
relevant effects on fire safety for a certain design and arrangements with FRP
composite structures. The intention is for these guidelines to be developed,
concretized and updated based on the regulations. In particular, some of the
regulations could be investigated in more detail and from different
perspectives.
3.1 Regulation 1 – Application
There are currently no comments to this regulation with regard to FRP composite.
3.2 Regulation 2 – Fire safety objectives and functional
requirements
Paragraph 2 states a number of functional requirements which are embodied
in the regulations of the fire safety chapter in order to achieve the fire safety
objectives set out in paragraph 1. In particular, the third functional requirement
(regulation 2.2.1.3) requires restricted use of combustible material. The fire
safety objectives and the functional requirements can be achieved by ensuring
compliance with all prescriptive requirements in parts B, C, D, E and G or by
alternative design and arrangements which comply with part F (regulation 17).
Approval in accordance with regulation 17 still requires that the alternative design
and arrangements meet the fire safety objectives and the functional requirements but
allows doing so in a different way than in accordance with the prescriptive
requirements.
In evaluating the achievement of the fire safety objectives and the functional
requirements from a broad perspective, it may be stated that a ship with FRP
elements may achieve some better and some worse than a traditional design. The focus
on safety of human life in the fire safety objectives makes it topical to address
not only the safety of passengers, but also the safety of firefighters and crew.
Consideration of the functional requirements especially indicates that risks from
adding combustible materials need to be accounted for.
3.3 Regulation 3 – Definitions
From the definitions in this regulation a few details may be useful to recapitulate
with regard to FRP composite:
-
3.2 From the definition of "A" class divisions it should be noted that
such divisions are described to be constructed of "steel or other equivalent
material" and that they should be so constructed as to be capable to
preventing the passage of smoke and flame to the end of the one-hour
standard fire test.
-
3.4 From the definition of "B" class divisions it should be noted that
such divisions are described to be constructed of "approved non-combustible
materials" and that they should be so constructed as to be capable to
preventing the passage of smoke and flame to the end of the first half hour
of the standard fire test.
-
3.10 From the definition of "C" class divisions it should be noted
that such divisions are described to be constructed of "approved
non-combustible materials" and that no other requirements apply.
-
3.33 From the definition of non-combustible material it should be
noted that such material is described to neither burn nor to give off
flammable vapours in sufficient quantity for self-ignition when heated to
approximately 750°C.
-
3.43 From the definition of steel or other equivalent material it
should be noted that the phrase refers to any non-combustible material
which, by itself or due to insulation provided, has structural and integrity
properties equivalent to steel at the end of the applicable exposure to the
standard fire test. Therefore, there are requirements regarding
non-combustibility as well as structural and integrity properties. Note that
the former is not limited in time but the latter requirements need only be
achieved until the end of the applicable exposure of the standard fire test.
An aluminium alloy with appropriate insulation is used to exemplify an
equivalent material to steel.
-
3.47 From the definition of a standard fire test it is
described to be a test in which specimens of the relevant bulkheads or decks
are exposed in a test furnace to temperatures corresponding approximately to
the standard time-temperature curve.
3.4 Regulation 4 – Probability of ignition
Purpose statement:
The purpose of this regulation is to prevent the ignition of combustible materials or
flammable liquids. For this purpose, the following functional requirements shall be
met:
-
.1 means shall be provided to control leaks of flammable liquids;
-
.2 means shall be provided to limit accumulation of flammable vapours;
-
.3 the ignitability of combustible materials shall be restricted;
-
.4 ignition sources shall be restricted;
-
.5 ignition sources shall be separated from combustible materials and
flammable liquids; and
-
.6 the atmosphere in cargo tanks shall be maintained out of the explosive
range.
Comments:
1 Using combustible materials for structures is not in conflict with the objective of
this regulation. However, it states to aim at preventing the ignition of combustible
materials. Looking at the prescriptive requirements, they prevent the occurrence of
fire by restricting ignition sources and some combustibles. Mainly fuels and the
handling of highly flammable substances are concerned, but also a few miscellaneous
items in enclosures. Most are ignition sources and the only actual combustible
material concerned is primary deck coverings. If applied within accommodation,
service or control spaces or on cabin balconies, they shall not readily ignite
(regulation 4.4.4). This requirement may seem a bit illogical since a primary deck
covering is the first layer fitted on a deck, used to smooth out unevenness, and
covered by a floor construction. It is rather the surface of the floor construction
which may be exposed to a potential ignition source. Furthermore, the requirement
implies the primary deck coverings should have low flame-spread characteristics,
which is a requirement that fits better in regulation 5. However, apart from this
requirement, there are no other prescriptive requirements to be found on how the
ignitability of combustible materials shall be restricted, as stated amongst the
functional requirements in the purpose statement.
2 New hazards may be introduced where FRP composite is used close to significant
ignition sources, such as exhaust pipes or other high-temperature surfaces. It may
be argued that this challenges the functional requirement on separation of ignition
sources from combustible materials. Due to assumptions regarding the use of
non-combustible structures, this safety function is not clearly stated in
prescriptive requirements of this regulation. It is nevertheless important to
identify ignition sources and ensure that FRP composite surfaces are properly
protected.
3 It may be argued that leaving combustible FRP composite surfaces unprotected is not
in line with the functional requirement concerning restricted combustibility.
However, this rather concerns ignition sources and easily ignitable (e.g. by a small
flame) combustibles and flammable substances whilst combustible materials which have
restricted ignitability, such as FRP composite, are managed in regulation 5. It is
noted that an IMO test method for evaluation of restricted ignitability of products
does not exist.
3.5 Regulation 5 – Fire growth potential
Purpose statement:
The purpose of this regulation is to limit the fire growth potential in every space
of the ship. For this purpose, the following functional requirements shall be
met:
-
.1 means of control for the air supply to the space shall be provided;
-
.2 means of control for flammable liquids in the space shall be provided;
and
-
.3 the use of combustible materials shall be restricted.
Comments:
1 This regulation oversees materials and other items in spaces with the intention to
limit the fire growth potential. Looking at the functional requirements, neither of
the first two is affected by use of FRP elements in ship constructions. However, the
third functional requirement must be taken into account as it states that the use of
combustible materials shall be restricted. The definition of a non-combustible
material is given in regulation 3.33 and defines it as a material that neither burns
nor gives off flammable vapours when heated to 750°C. For example, vinyl ester,
which is often used as resin in FRP composite, will give rise to pyrolysis gases
above 500°C.
2 In the prescriptive requirements, use of non-combustible and combustible materials
is primarily managed in paragraph 3. Except interiors and furnishings, the
requirements concern linings, grounds, draught stops, ceilings, faces, mouldings,
decorations, veneers, insulation materials, partial bulkheads, etc. These are also
the materials that will govern the growth phase of a fire, together with, for
example, luggage and other loose fittings. In general, all surfaces and linings in
accommodation and service spaces must fulfil requirements of a maximum calorific
value of 45 MJ/m2, a maximum volume of combustible material and have low
flame-spread characteristics according to the FTP Code. However, since the
regulations assume that the bulkhead plate behind any wall construction is steel,
there are no requirements regarding the materials behind the wall construction.
3 The requirements in this regulation could be claimed to apply to surfaces of any
sort. Therefore, if the same approved materials for linings, grounds, draught stops,
ceilings, faces, mouldings, decorations, veneers, etc. are used in a ship with FRP
composite constructions as in a traditional (prescriptive) design, it could be
claimed that the design complies with the prescriptive requirements in regulation 5.
This would generally not increase the fire growth potential in the spaces in the
initial stages during evacuation. However, if the FRP composite surfaces are left
uncovered or if divisions are constructed with combustible FRP composite just
underneath surfaces of low flame-spread characteristics, it can be argued that the
surface laminate in fact represents the surface lining, to which requirements
regarding low flame-spread characteristics and maximum volume of combustible
material apply; the requirement on maximum calorific value would then apply to the
core. With this reasoning all of these requirements would generally be deviated.
4 As mentioned above, thermal insulation may be used to provide structural integrity,
which will also protect the combustible FRP composite surfaces from fire
involvement, e.g. for 60 minutes. In this case the FRP composite will not add to the
fire growth potential in the space within the first hour of a fire having the same
intensity as a standard fire test curve.
5 As mentioned above, this regulation covers materials and other items in spaces with
the intention to limit the fire growth potential. All discussions above have
considered internal spaces. Since external surfaces on ships are typically made up
of painted steel there has not been any reason to regulate this matter. This is
another example of where the FRP composite goes beyond the steel-based regulations.
Making exterior surfaces in combustible FRP composite will affect the fire growth
potential and could cause vertical fire spread between decks, which is a hazard that
must be addressed on these ships. Hazardous exterior surfaces could for example be
protected to achieve low flame-spread characteristics or be protected with drencher
system. An indirect way to manage the problem is to use fire rated windows, which
could avoid fire spread.
3.6 Regulation 6 – Smoke generation potential and toxicity
Purpose statement:
The purpose of this regulation is to reduce the hazard to life from smoke and toxic
products generated during a fire in spaces where persons normally work or live. For
this purpose, the quantity of smoke and toxic products released from combustible
materials, including surface finishes, during fire shall be limited.
Comments:
1 Similarly to regulation 5, the prescriptive requirements of regulation 6 mostly
concern enclosures. All materials involved in a fire will contribute to the
production of toxic smoke but during the first stages of a fire it is mainly the
exposed surface that will contribute to the generation and toxicity of smoke. This
regulation generally controls exposed surface finishes and primary deck
coverings.
2 FRP composites could either be covered with approved surface materials or left
unprotected. In spaces where the FRP composite is left unprotected, it could be
difficult to fulfil regulation 6.2.1. Furthermore, if an approved surface material
is used on the FRP composite, it may be argued that the regulations are predicated
on that a non-combustible material is used for the ship structures that are
underneath. The generation and toxicity of smoke may, depending on the construction,
therefore not be limited to the same extent as in a prescriptive design during an
enclosure fire.
3 When scrutinizing regulations 5 and 6, it is important to realize that both
regulations manage smoke production but where the latter mainly has to do with the
individual material characteristics, it could be said that regulation 5 manages so
that an unlimited area of combustible materials does not catch fire and produce
smoke and that regulation 6 manages the potential of each square meter that can be
involved in a fire.
4 Thermal insulation may be used to protect the combustible FRP composite surfaces
from becoming involved in a fire. For the time that the construction is thermally
protected, the FRP composite will not add to the generation or toxicity of the
produced smoke. In the event of a fire lasting long enough to involve the FRP
composite divisions, an increased generation and toxicity of smoke could be argued
to occur, in comparison with a steel ship. This will depend on the selection of
plastic materials. For instance, PVC is known to release highly toxic hydrochloric
acid (HCl) during combustion.
5 It is hard to predict whether the smoke generation and toxicity at a given time
would be worse in a ship with FRP elements compared to a steel ship depending on the
insulating capacity of the construction. If thermal insulation is used to protect
the FRP composite, fire spread will likely be delayed. It could be noted that when a
fire starts to involve the protected FRP composite divisions, conditions will
already have been uninhabitable for a while. An increased smoke generation or
toxicity could be hazardous to persons on the embarkation deck depending on wind
direction.
6 Fires on open deck and involving exterior surfaces in FRP composite could also be
affected by the smoke generation and toxicity. However, this problem may not be as
relevant when considering exteriors, since smoke management is not critical.
3.7 Regulation 7 – Detection and alarm
Purpose statement:
The purpose of this regulation is to detect a fire in the space of origin and to
provide for alarm for safe escape and firefighting activity. For this purpose, the
following functional requirements shall be met:
-
.1 fixed fire detection and fire alarm system installations shall be suitable
for the nature of the space, fire growth potential and potential generation
of smoke and gases;
-
.2 manually operated call points shall be placed effectively to ensure a
readily accessible means of notification; and
-
.3 fire patrols shall provide an effective means of detecting and locating
fires and alerting the navigation bridge and fire teams.
Comments:
In general, use of FRP composite does not present any deviations from prescriptive
requirements. However, the functional requirements give reason to oversee the need
for detection. Considering the first regulation functional requirement, there is no
reason to believe that significantly less smoke is produced by FRP composites than
organic materials in general. However, since the fire growth potential in some areas
may be affected, there may also be an additional need for detection. For areas where
non-insulated FRP elements are used, it is particularly critical to provide early
activation of an extinguishing system with quick detection. It may therefore be
relevant with faster or more reliable smoke detection or to provide it in additional
areas of the ship, possibly even in open spaces or void spaces. The potential
increased need for detection should be considered in the fire risk assessment and
depends on how FRP composite is used.
3.8 Regulation 8 – Control of smoke spread
Purpose statement:
The purpose of this regulation is to control the spread of smoke in order to minimize
the hazard from smoke. For this purpose, means for controlling smoke in atriums,
control stations, machinery spaces and concealed spaces shall be provided.
Comments:
As discussed in 3.6 (regulation 6 – Smoke generation potential and toxicity) the
amount of smoke generated in a fire test with FRP composite structures (glass fibre
reinforced polyester with PVC core) was only slightly larger than that from a fire
in a steel ship. If this is the case for the alternative design and arrangements
being evaluated, this would indicate that the current requirements for control of
smoke spread could be met.
3.9 Regulation 9 – Containment of fire
Purpose statement:
The purpose of this regulation is to contain the fire in the space of origin. For
this purpose the following requirements shall be met:
-
.1 the ship shall be divided by thermal and structural boundaries;
-
.2 thermal insulation boundaries shall have due regard to the fire risk of
the space and adjacent spaces; and
-
.3 the fire integrity of the division shall be maintained at openings and
penetrations.
Comments:
1 This regulation prescribes main vertical and horizontal zones and, where necessary,
internal bulkheads to be made up by divisions of "A" class standard. "A" class means
that steel or other equivalent material shall be used. Regulation 3.43 defines steel
or other equivalent material as a non-combustible material which, by itself or by
insulation provided, has structural and integrity properties equivalent to those of
steel at the end of the standard fire test. Unprotected FRP composite generally
ignites when exposed to significant fire but could for example be combined with
thermal insulation in order to gain fire integrity comparable with "A" class
standard. Tests have demonstrated that the temperature rise at the unexposed side of
a FRD60 (cf. HSC Code) division will be as low as 45°C after
60 minutes of fire exposure (temperature rise and integrity test in accordance with
the standard test for bulkheads and decks, see the Test procedures for
fire-resisting divisions of high-speed craft (MSC
45(65)). This low conduction of heat will prevent heat from being
transferred long distances through the ship structure, which may be a fire risk in
conventional ships.
2 The low conductivity of a FRD60 division can also give rise to a faster fire
development within the enclosed space, equivalent to an insulated aluminium
structure or a heavily insulated steel structure (e.g. "A-60" class). When
insulation or any protective surface layer is deteriorated and the surface
temperature of the FRP composite reaches its ignition temperature, the FRP composite
will start contributing to the fire, which could also accelerate the fire
development if additional oxygen is available.
3 Specific fire integrity and insulation requirements for internal decks and
bulkheads depend on a classification made of the spaces and are given in tables in
regulation 9. The way spaces are assigned fire categories may need to be
reconsidered, in particular for spaces with added fire load by exposed untreated FRP
composite. This includes open decks.
4 If FRP composite is used on open deck, all connections between interior and
external spaces must be reconsidered. Design of windows, doors and ventilation
systems may, for example, need to be reconsidered due to the potential external fire
hazards, i.e. due to potential spread of smoke and fire into the ship or out to
external surfaces.
5 Regarding penetrations in fire-resisting divisions, doors, pipes, window frames,
etc. are generally also required to be non-combustible when penetrating "A" class
divisions. The integration of such penetrations into an FRP composite division must
be documented by fire tests or potentially by engineering judgement. The integration
of doors, windows, cable glands, ducts, fire dampers and pipes in FRP composite fire
divisions has been successfully demonstrated in tests.
6 A robust integration of the insulation systems onto an FRP composite fire division
is crucial. The effect of voids between insulation and the composite structure could
be further evaluated. Essential systems in a fire situation, such as sprinkler
systems, piping and ducts, must have a fastening/support system that is designed not
to fail in case of a fire.
3.10 Regulation 10 – Firefighting
Purpose statement:
The purpose of this regulation is to suppress and swiftly extinguish fire in the
space of origin. For this purpose the following requirements shall be met:
-
.1 fixed fire-extinguishing systems shall be installed, having due regard to
the fire growth potential of the spaces; and
-
.2 fire-extinguishing appliances shall be readily available.
Comments:
1 The first functional requirement states that the fixed fire-extinguishing systems
shall have due regard to the fire growth potential of the space. It is only if the
fire growth potential differs significantly that it is necessary to take into
account FRP composites when designing the fire-extinguishing systems. In most cases,
fire growth in the FRP composite will not be dimensioning for the fire-extinguishing
system since more rapid fire developments can generally occur in other combustibles
and since the size of a fire depends on the oxygen supply. The fire pump capacity
and pressure requirements should therefore generally not need to be changed.
However, since early extinguishment is important, it may still be suitable to
oversee the firefighting systems and that extinguishment is managed properly.
2 It may also be necessary to consider fire-extinguishing systems and equipment in
additional places of a ship with FRP composite constructions. If exterior surfaces
are made of FRP composite they may need to be protected in order to prevent an
enclosure fire from spreading to the exteriors if a door or window is left open or
broken, e.g. by a sprinkler above the openings. It may also be relevant to install
drencher systems covering essential parts of the hull or exteriors of
superstructure, if there is a risk of fire spread or deterioration of structural
performance.
3 Even though the purpose statements and prescriptive requirements of this regulation
only cover fire-extinguishing systems and appliances, it is in the context of the
regulation title also relevant to consider effects on manual firefighting routines.
There are a few significant differences:
-
.1 First and foremost, the need to perform defensive boundary cooling from
the outside of a fire enclosure is removed. It is instead important to have
an offensive strategy to provide direct cooling of the fire. Boundary
cooling is a strategy that requires many resources without actually fighting
the fire, but mainly hindering fire spread. A much more efficient way to
fight a fire is to quickly reach inside the enclosure. With traditional
equipment this may not be possible due to the heat or risk of fire spread if
a door is opened. However, there is more suitable firefighting equipment
already in use, such as the Cutting Extinguisher or Fog Spear. Tests have
demonstrated that firefighting by such equipment through small holes in the
FRP composite boundaries is very effective. The holes may be pre-fabricated
or made by equipment on site. This will allow dampening the fire from
outside of the fire origin. Suitable equipment in combination with a
rerouting of firefighting resources relieved from boundary cooling to either
assist in active combat of the fire may increase both effectiveness and
efficiency.
-
.2 Furthermore, a fire which has taken root in the FRP composite may be
difficult to fully extinguish. This implies more resources will be needed to
keep watch over fire-scorched areas to ensure that the FRP composite does
not reignite. This may not significantly interfere with the critical stages
of taking control of the fire.
-
.3 Another aspect of how firefighting routines could be affected is that the
improved thermal resistance of FRP composite structures could imply
difficulties in finding the seat of the fire from adjacent compartments with
a commonly used thermal imaging camera.
-
.4 Routines regarding potential collapse must also be developed in order to
insure the safety of passengers and firefighting crew.
4 All in all, the ability to focus more resources on actively fighting the fire,
combined with the introduction of tools to cool hot fire gases from an adjacent
compartment could improve the efficiency and effectiveness of firefighting in ships
with FRP composite structures. In any case, effects on firefighting routines must be
taken into consideration when making ship structures in FRP composite.
5 Additional equipment for manual firefighting could also be necessary, e.g. in open
deck spaces surrounded by FRP composite surfaces.
3.11 Regulation 11 – Structural integrity
Purpose statement:
The purpose of this regulation is to maintain structural integrity of the ship,
preventing partial or whole collapse of the ship structures due to strength
deterioration by heat. For this purpose, the materials used in the ships' structure
shall ensure that the structural integrity is not degraded due to fire.
Comments:
1 This regulation intends to ensure that structural integrity is maintained in case
of a fire. After the purpose statement of the regulation, paragraph 2 of regulation
11 states that:
-
"The hull, superstructures, structural bulkheads, decks and deckhouses shall
be constructed of steel or other equivalent material. For the purpose of
applying the definition of steel or other equivalent material as given in
regulation 3.43, the 'applicable fire exposure' shall be according to the
integrity and insulation standards given in tables 9.1 to 9.4. For example,
where divisions such as decks or sides and ends of deckhouses are permitted
to have 'B-0' fire integrity, the 'applicable fire exposure' shall be half
an hour."
2 Structures shall thus be constructed of steel or other equivalent material, i.e.
any non-combustible material which, by itself or due to insulation provided, has
structural and integrity properties equivalent to steel at the end of the standard
fire test. This prescriptive requirement cannot be complied with if combustible FRP
composite structures are used. The existing fire tests within the FTP
Code for A and B class divisions are conducted over a period of up to 60
minutes. Structural and integrity properties equivalent to steel may be achieved for
such a time of fire exposure in the standardized test, for example if the FRP
composite is sufficiently insulated. However, unlike the requirements on structural
and integrity properties, the requirement on non-combustibility is not time-limited.
The fire tests do not assess the performance of the material after the end of the
test, nor when subject to load.
3 Insulated steel divisions may lose fire integrity after for example 60 min; not due
to strength deterioration by heat but due to possible fire spread to adjacent
compartments by heat transfer. A prolonged fire could involve and deteriorate an FRP
composite structure when thermal insulation or other means are no longer enough to
provide structural and integrity performance. A large enough fire could then bring
about a local collapse.
4 Steel generally loses its structural strength at about 400°C to 600°C and an
unstiffened FRP composite sandwich panel may lose bonding between core and laminate,
and thereby structural performance, when heated to about 150°C (or a temperature
where the bonding between core and laminate starts to soften). Improved structural
integrity of FRP composite structures may be achieved by use of e.g. stiffeners,
pillars or additional layers but steel ships have proved to be able to survive fire
for several days without progressive structural collapse occurring. This is
particularly important when considering that the ship shall retain safe areas for
the refuge of passengers (SOLAS regulation
II-2/21.5), including control stations to remain intact and habitable for
command and control activities necessary during an incident. This can for example
affect the measures required to achieve successful evacuation of the ship (cf. HSC Code). It is crucial that fire hazards introduced in case of a
long-lasting fire (lasting for more than 60 minutes) are addressed in the SOLAS
regulation
II-2/17 assessment.
5 Deviations from prescriptive requirements are found in regulation 11.4 if steel
(not "steel or other equivalent material") is not used for structures forming
crowns, casings and floor plating of machinery spaces of category A. Use of FRP
composite for such structures may need special consideration.
6 Further to the above, steel-FRP joints need to be assessed in detail to ensure that
structural fire integrity is achieved (see also section B.3.4 of appendix B).
3.12 Regulation 12 – Notification of crew and passengers
Purpose statement:
The purpose of this regulation is to notify crew and passengers of a fire for safe
evacuation. For this purpose, a general emergency alarm system and a public address
system shall be provided.
Comments:
There are no obvious challenges posed to this regulation by the use of FRP composite.
However, a public address system may be indirectly affected if special instructions
must be made to avoid passengers to reside in certain areas where there is a risk of
collapse. An exterior fire could also affect the possibility of using certain
exterior areas or life-saving appliances.
3.13 Regulation 13 – Means of escape
Purpose statement:
The purpose of this regulation is to provide means of escape so that persons on board
can safely and swiftly escape to the lifeboat and liferaft embarkation deck. For
this purpose, the following functional requirements shall be met:
-
.1 safe escape routes shall be provided;
-
.2 escape routes shall be maintained in a safe condition, clear of obstacles;
and
-
.3 additional aids for escape shall be provided as necessary to ensure
accessibility, clear marking, and adequate design for emergency
situations.
Comments:
1 This regulation aims to provide means for persons to safely and swiftly escape a
fire, assemble and proceed to their embarkation station. Considering the
prescriptive requirements, regulation 13.3.1.3 requires all stairways in
accommodation spaces, service spaces and control stations to be of steel frame
construction or other equivalent material sanctioned by the Administration. If they
are made of FRP composites they need to be evaluated in the fire safety analysis.
The same applies to stairways and ladders in machinery spaces (regulation 13.4.1).
However, such constructions are generally not considered in other materials than
steel, even on ships in FRP composite. It may be noted that safe havens and escape
ways manufactured from composites are used in the offshore industry.
2 In order to achieve safe escape routes, regulation 13 requires fire integrity and
insulation in several places, referring to values in regulation 9 (tables 9.1 to
9.4). A sufficiently insulated FRP composite division could be claimed to achieve
these requirements (since non-combustibility is not required).
3 In an FRP composite structure the temperature on the unexposed side could, due to
the high insulation capacity of the composite construction, be very low even after
60 minutes of fire. The heat from a fire will therefore to a larger extent stay in
the fire enclosure and not easily be transmitted to adjacent spaces. This could be
advantageous in an escape situation.
3.14 Regulation 14 – Operational readiness and maintenance
Purpose statement:
The purpose of this regulation is to maintain and monitor the effectiveness of the
fire safety measures the ship is provided with. For this purpose the following
functional requirements shall be met:
-
.1 fire protection systems and firefighting systems and appliances shall be
maintained ready for use; and
-
.2 fire protection systems and firefighting systems and appliances shall be
properly tested and inspected.
Comments:
The functional requirements are not affected by use of FRP composite. The fire
protection systems and firefighting systems and appliances must be maintained ready
for use and should be properly tested and inspected on a ship with FRP composite
structures, as on any ship. Even if the regulation may be directly applied and no
deviations are posed, the content covered by this regulation may be affected.
Depending on the alternative design and arrangements, there may be a need for faster
extinguishment, increased capacity or improved reliability and consequently more
maintenance.
3.15 Regulation 15 – Instructions, onboard training and drills
Purpose statement:
The purpose of this regulation is to mitigate the consequences of fire by means of
proper instructions for training and drills of persons on board in correct
procedures under emergency conditions. For this purpose, the crew shall have the
necessary knowledge and skills to handle fire emergency cases, including passenger
care.
Comments:
Except for the need for increased knowledge of firefighters considering strategies,
techniques, routines, etc. (see 4.10), there are no direct differences on a ship
with FRP composite structures in comparison with a traditionally built ship. In
similarity with regulation 14, the content covered by this regulation may be
affected depending on the systems considered in the alternative design and
arrangements.
3.16 Regulation 16 – Operations
Purpose statement:
The purpose of this regulation is to provide information and instructions for proper
ship and cargo handling operations in relation to fire safety. For this purpose, the
following functional requirements shall be met:
Comments:
There are no known challenges posed to this regulation for a ship with FRP composite
structures. In similarity with regulation 14, the content covered by this regulation
may nevertheless be affected depending on the solutions considered in the
alternative design and arrangements.
3.17 Regulation 17 – Alternative design and arrangements
Purpose statement:
The purpose of this regulation is to provide a methodology for alternative design and
arrangements for fire safety.
Comments:
The method described in regulation 17 (and MSC.1/Circ.1002, as amended by MSC.1/Circ.1552) and its suitability when assessing fire safety in FRP
composite constructions is discussed in appendix C to these guidelines.
3.18 Regulation 18 – Helicopter facilities
Purpose statement:
The purpose of this regulation is to provide additional measures in order to address
the fire safety objectives of this chapter for ships fitted with special facilities
for helicopters. For this purpose, the following functional requirements shall be
met:
-
.1 helideck structure shall be adequate to protect the ship from the fire
hazards associated with helicopter operations;
-
.2 firefighting appliances shall be provided to adequately protect the ship
from the fire hazards associated with helicopter operations;
-
.3 refuelling and hangar facilities and operations shall provide the
necessary measures to protect the ship from the fire hazards associated with
helicopter operations; and
-
.4 operation manuals and training shall be provided.
Comments:
Helicopter decks have previously been built with FRP composite materials on non-SOLAS
ships but will require special evaluations, including testing, and tailored
detection and extinguishment.
3.19 Regulation 19 – Carriage of dangerous goods
Purpose statement:
The purpose of this regulation is to provide additional safety measures in order to
address the fire safety objectives of this chapter for ships carrying dangerous
goods. For this purpose, the following functional requirements shall be met:
-
.1 fire protection systems shall be provided to protect the ship from the
added fire hazards associated with carriage of dangerous goods;
-
.2 dangerous goods shall be adequately separated from ignition sources;
and
-
.3 appropriate personnel protective equipment shall be provided for the
hazards associated with the carriage of dangerous goods.
Comments:
None of the prescriptive requirements are likely to be affected by use of FRP
composite constructions. However, there may be reason to evaluate potential hazards
from leakage of dangerous goods onto an FRP composite deck, not only from a fire
perspective. Certain dangerous goods may for example cause the FRP composite to
deteriorate if they come in contact. These and other hazardous non-fire related
scenarios must be considered. With regard to fire, the time to collapse may change
due to a potentially larger fire involving combustible surrounding exterior FRP
composite surfaces.
3.20 Regulation 20 – Protection of vehicle, special category and ro-ro
spaces
Purpose statement:
The purpose of this regulation is to provide additional safety measures in order to
address the fire safety objectives of this chapter for ships fitted with vehicle,
special category and ro-ro spaces. For this purpose, the following functional
requirements shall be met:
-
.1 fire protection systems shall be provided to adequately protect the ship
from the fire hazards associated with vehicle, special category and ro-ro
spaces;
-
.2 ignition sources shall be separated from vehicle, special category and
ro-ro spaces; and
-
.3 vehicle, special category and ro-ro spaces shall be adequately
ventilated.
Comments:
This regulation describes requirements for ventilation, alarm and detection systems,
fire-extinguishing equipment and structural requirements for spaces with vehicles.
In passenger ships carrying more than 36 passengers, the boundary bulkheads or decks
of the ro-ro space are by regulation 20.5 required to achieve A-60 (with some
exceptions where the structural fire protection can be reduced to A-0). This cannot
be achieved if such divisions are made of FRP composite. Furthermore, even if not
required by prescriptive requirements, it may prove necessary to better address the
first regulation functional requirement by passive or active measures, e.g. by an
additional active fire-extinguishing system on exterior surfaces. For ro-ro spaces
which are not of special category, the fire safety requirements are different and in
generally considered less stringent.
3.21 Regulation 21 – Casualty threshold, safe return to port and safe
areas
Purpose statement:
The purpose of this regulation is to establish design criteria for a ship's safe
return to port under its own propulsion after casualty that does not exceed the
casualty threshold stipulated in paragraph 3 and also provides functional
requirements and performance standards for safe areas.
Comments:
Passenger ships constructed on or after 1 July 2010 having a length of 120 m or above
or having three or more main vertical zones, shall comply with this regulation.
However, FRP composite may be used in superstructures of the ship. In any case, it
may be relevant to evaluate e.g. whether the definition of the casualty threshold in
regulation 21.3 is appropriate for ships in FRP composite. Furthermore, structural
integrity is important to consider (see section 3.11) when considering safe areas
for the refuge of passengers (regulation 21.5), including control stations to remain
intact and habitable for command and control activities necessary during an
incident.
3.22 Regulation 22 – Design criteria for systems to remain operational after a
fire casualty
Purpose statement:
The purpose of this regulation is to provide design criteria for systems required to
remain operational for supporting the orderly evacuation and abandonment of a ship,
if the casualty threshold, as defined in regulation 21.3, is exceeded.
Comments:
Passenger ships constructed on or after 1 July 2010 having a length of 120 m or above
or having three or more main vertical zones, shall comply with this regulation.
However, FRP composite may be used in superstructures of the ship. In any case, it
may be relevant to evaluate, e.g. whether there are additional hazards from the
potential fire size and potential smoke production from FRP structures with regard
to evacuation and abandonment.
3.23 Regulation 23 – Safety centre on passenger ships
Purpose statement:
The purpose of this regulation is to provide a space to assist with the management of
emergency situations.
Comments:
Passenger ships constructed on or after 1 July 2010 shall have a safety centre on
board complying with the requirements of this regulation. From the safety centre all
fire safety systems should be available, such as ventilation systems, alarm systems,
fire detection and alarm systems, fire and emergency pumps, etc. In general, this is
not affected by the FRP composite construction material, but it may be necessary to
consider collapse when determining the location of the safety centre.