How fire safety on ships is covered in SOLAS

Malcolm Latarche
Malcolm Latarche

14 January 2017

The very first version of SOLAS was far more concerned with life-saving than with fire and quite lacking in dealing with the subject fire on board vessels other than to say that there should be a system of fire patrols and that the ship should be equipped with pumps sufficient to direct ‘two powerful jets of water’ at any fire.

There was also a requirement to carry a smoke hood and safety lights. Over the years and due to some high-profile disasters at sea involving fire, the issue of fire gradually grew to become probably the second most important aspect of ship safety covered by the IMO.

While the SOLAS conventions of 1914, 1929, 1948 and 1960 did contain fire safety requirements, they proved inadequate for passenger ships. In the 1960s, a series of fires aboard international passenger ships highlighted many problems and, as a result, many changes were incorporated into the 1974 SOLAS Convention.

Amendments to SOLAS through the 1970s and 1980s gave fire a Chapter of its own (Chapter II-2). In 1992, the Sub-Committee on Fire Protection began a comprehensive revision of the chapter as it was felt that the adoption of various sets of amendments at different times had made it difficult to use and implement. Technological advancements and lessons learned from accidents, since the chapter’s last revision in 1981, required new provisions to be added and for existing requirements to be modified. However, the outcome of this eight-year effort resulted in more than just a “user friendly” amalgamation of the latest amendments, but an entirely new structure for SOLAS chapter II-2.

Fire scenario process

Fire is covered in several ways within SOLAS with these falling into three very separate areas. The first is the construction of the vessel and the materials used, the second is fire risks and hazards relating to cargoes carried and the third is related to fire detection and fire-fighting systems and equipment.

The new structure focused on the “fire scenario process” rather than on ship type, as the previous SOLAS chapter II-2 was structured. Thus, the regulations start with prevention, detection, and suppression following all the way through to escape. The revised SOLAS chapter II-2 had a new part E; that deals exclusively with human element matters such as training, drills and maintenance issues and a new part F; that sets out a methodology for approving alternative (or novel) designs and arrangements.

The new Chapter II-2 only applied fully to ships built after it came into force in 2002 however some aspects were also agreed to be applied to existing ships. Of the measures that affected existing vessels, most had a date by which the ship would have to comply or the measures did not apply unless repairs, alterations, modifications and outfitting to existing systems took place. All of the dates laid out in the new requirements have since passed so all ships should now meet the latest rules.

In addition, to make the revised SOLAS chapter II-2 more user friendly, specific system- related technical requirements have been moved to the new International Fire Safety Systems Code and each regulation has a purpose statement and functional requirements to assist port and flag States. Some of the original technical provisions were transferred from the Convention to the International Fire Safety Systems (FSS) Code, and many others are spelled out in greater detail in the Code. Following the addition of a new final chapter on fixed hydrocarbon gas detection systems in 2007, the 2015 edition of the FSS Code consists of 16 chapters but a new chapter was agreed at MSC 95 and adopted at MSC 97 which brings the total to 17.

Each addresses specific systems and arrangements, except for chapter 1 which contains a several definitions and also general requirements for approval of alternative designs and toxic extinguishing media.

  • Chapter 1 General
  • Chapter 2 International shore connections
  • Chapter 3 Personnel protection
  • Chapter 4 Fire extinguishers
  • Chapter 5 Fixed gas fire-extinguishing systems
  • Chapter 6 Fixed foam fire-extinguishing systems
  • Chapter 7 Fixed pressure water-spraying and water-mist fire-extinguishing systems
  • Chapter 8 Automatic sprinkler, fire detection and fire alarm systems
  • Chapter 9 Mixed fire detection and fire alarm systems
  • Chapter 10 Sample extraction smoke detection systems
  • Chapter 11 Low-location lighting systems
  • Chapter 12 Fixed emergency fire pumps
  • Chapter 13 Arrangement of means of escape
  • Chapter 14 Fixed deck foam systems
  • Chapter 15 Inert gas systems
  • Chapter 16 Fixed hydrocarbon gas detection systems
  • Chapter 17 Foam fire-fighting appliances for the protection of helicopter facilities

In order to complement the FSS Code, and to assist in type approval of materials used in ship construction, the IMO has also published a document known as Fire Test Procedures (FTP Code). The FTP Code was first published at the same time as the FSS Code. Both have since been amended to take into account technology changes and desirable changes.

Keeping a watch

As mentioned above part E of SOLAS chapter II-2 deals exclusively with human element matters such as training, drills and maintenance issues.

This section does not concern itself with the actual training that seafarers have to do undergo as part of their certification process but with the organisational and practical aspects as regards individual ships. As part of the STCW Code, the IMO has prepared a series of three model courses for seafarers undergoing training at sure training establishments. These are:

  • Model Course 1.20 – Fire Prevention & Fire Fighting
  • Model Course 2.03 – Advanced Fire Fighting
  • Model Course 3.05 – Survey of Fire Appliances

With so many different documents covering fire safety regulations, it is far beyond the scope of this guide to fully detail all the requirements. However, reference to the main SOLAS text and to the other documents mentioned here should give any operator or crew member sufficient information to understand the requirements under most situations.

In addition to these documents, fire safety should be one of the main subjects covered in the ship owner or operator’s safety management system. Because of that they should have been subject to both internal and external audit and deemed fit for purpose. As with all matters relating to the ISM Code they should be subject to regular review involving both ship and shore personnel.

January 2016 saw some new rules coming into effect in a number of areas concerned with safety. These include;

  • amendments to SOLAS regulations II-2/4, II-2/3, II-2/9.7 and II-2/16.3.3, to introduce mandatory requirements for inert gas systems on board new oil and chemical tankers of 8,000dwt and above, and for ventilation systems on board new ships; related amendments to the International Code for Fire Safety Systems (FSS Code) on inert gas systems.
  • amendments to SOLAS regulation II-2/10. This is in the form of new carriage requirements for water mist lance and mobile water monitors for new ships designed to carry containers on or above the weather deck and for the ships designed to carry five or more tiers of containers on or above the weather deck, respectively.
  • amendments to SOLAS regulation II-2/13.4, mandating additional means of escape from machinery spaces.
  • new SOLAS regulation II-2/20-1 Requirement for vehicle carriers carrying motor vehicles with compressed hydrogen or natural gas for their own propulsion, which sets additional requirements for ships with vehicle and ro-ro spaces intended for the carriage of motor vehicles with compressed hydrogen or compressed natural gas in their tanks as fuel.

A decade ago, only LNG carriers and a few small ferries were fuelled by LNG but it is now being heavily promoted as a cleaner alternative to fuel oil for all ship types. One impediment to its greater adoption has been the lack of an internationally agreed standard for fuel systems on ships powered by gas.

This has now been rectified following the adoption of the IGF Code at MSC 95 in 2015. The amendments caused by the adoption which previously existed as drafts include a new Part G in SOLAS chapter II-1 (Construction – Subdivision and stability, machinery and electrical installations) related to ships using low- flashpoint fuels, requiring such ships to comply with the IGF Code; and related amendments to SOLAS chapter II-2 (Fire protection, fire detection and fire extinction), covering to the use of fuel with a low flashpoint. Further amendments update the form of safety certificates, to include reference to the new Part G. Two additional amendments to SOLAS were also adopted at MSC 95:

  1. SOLAS regulation II-2/4 was amended to allow existing ships that were approved to use oil fuels with flashpoint less than 60°C, for example fuel oils less than 60°C but not less than 43°C in emergency generators, to continue using such oil fuels after the IGF Code came into effect on 1 January 2017. This allowance is accepted provided that the ship is not converted to use low-flashpoint fuels, or does not commence the use of low-flashpoint fuels that are different from that which it was previously approved to use, after entry into force of the IGF Code on 1 January 2017. At present, the requirements for low-flashpoint fuel oils (residual or distillate fuel oils) with a flashpoint less than 60°C are under development for future inclusion in the IGF Code.
  2. SOLAS Part F Regulation 55 was revised to account for the IGF Code requirement that ships using other low-flashpoint fuels (methanol, propane, butane, ethanol, hydrogen, dimethyl ether, etc.) need to comply with the functional requirements of the Code through the alternative design regulation based on an engineering analysis. Operationally-dependent alternatives are not permitted. The adopted Code includes several significant provisions which were previously agreed at MSC 94 with the exception of the provision for risk assessment application criteria which was refined at MSC 95. The Committee clarified that, for ships using natural gas as fuel (part A-1 of the IGF Code) and complying with the detailed prescriptive requirements contained within the Code, a risk assessment need only be conducted where specifically required by the applicable prescriptive parts of the IGF Code.

New regulation V/3 (MSC.396(95)) and corresponding sections to Parts A (MSC.396(96)) and B of the 1978 STCW Convention containing training and qualifications of personnel that work on ships subject to the IGF Code were adopted. Criteria was included to ensure that certain personnel, with training and experience acquired for liquefied gas tankers, receive recognition towards the new mandatory training and qualification requirements specified in the Convention for ships subject to the new IGF Code.