New U.S. Coast Guard Fire Protection Requirements for Recreational Vessels
For over 200 years, the United States Coast Guard (USCG) has been upholding its mission “to ensure our Nation’s maritime safety, security and stewardship.” A primary component of this mission is the creation, maintenance, and enforcement of safety standards for the marine community.
A fire at sea can quickly translate into a worst-case scenario for mariners and passengers. The USCG provides significant guidance in the Code of Federal Regulations (CFR) related to marine fire protection. The overarching intent is to ensure each vessel within its purview is adequately protected in the event of a fire.
What are the new requirements?
On April 20, 2022 the USCG promulgated a new final rule (33 CFR 175) that amends the fire-extinguishing equipment regulations “for recreational vessels that are propelled or controlled by propulsion machinery.” Additionally, the new rule also relieves owners of recreational vessels “from certain inspection, maintenance, and recordkeeping requirements that are more suited for commercial vessels” found in 46 CFR. In separating the requirements, the USCG established the fire equipment regulations for recreational vessels in 33 CFR 175, subpart E.
One of the more prominent changes is the removal of the requirement that portable fire extinguishers on recreational vessels comply with NFPA 10. The USCG found the recordkeeping requirements of NFPA 10 too specific and burdensome for recreational boat owners and operators. The new requirement simply stipulates that portable fire extinguishers must be in “good and serviceable” condition. The USCG believes that applying this performance requirement versus the rigid specification requirements of NFPA 10 will make it simpler and less expensive to maintain fire protection equipment on recreational vessels. The new regulations maintain the intent of NFPA 10—that portable fire extinguishers must be in good working order in the event of a fire.
Within the standard, the specific requirements for portable fire extinguishers are primarily based on vessel length, differing for vessels less than vs. greater than 65 feet (20m). The requirements also vary according to the presence of a fixed fire protection system.
The table below outlines the minimum number of portable fire extinguishers for recreational vessels up to 65 feet in length.
The conditions in which portable fire extinguishers must be supplied are described in the following graphic and table.
Conditions that typically (under normal conditions) do not require fire extinguishers include:
- Bait wells
- Glove compartments
- Buoyant flotation material
- Open-slatted flooring
- Ice chests
For recreational vessels greater than 65 feet in length, the standard requires portable fire extinguishers based on gross tonnage.
For these vessels, there is also a separate requirement for fire extinguishing equipment to be available in the machinery space, e.g., the engine room.
- For each 1000 bhp of the main engine(s), one 20-B fire extinguisher must be installed (up to a maximum of six required).
- For recreational vessels exceeding 300 gross tons, either one 160-B semi-portable fire extinguisher must be provided or a fixed fire suppression system must be installed.
The new standard allows older fire protection equipment that was previously approved but is now insufficient for the new requirement to continue without upgrade or replacement, provided it is in good working order (conditions apply). However, any new equipment or replacements must meet the new standard.
What does all of this mean?
The new regulations are undoubtedly welcomed by recreational vessel owner/operators who are now relieved from the onerous reporting requirements of NFPA 10. But there is also relief from the fire extinguisher requirements when a fixed fire suppression system is installed in the machinery space(s) for vessels of 65 feet or less. The standard requires far fewer portable fire extinguishers when a fixed system is utilized.
The new requirements also mandate a 160-B semi-portable fire extinguisher or fixed system in the machinery spaces of vessels exceeding both 65 feet of length and 300 gross tons. A 160-B rated semi-portable fire extinguisher consists of a 50 lb. (or larger) wheeled unit which may remain portable on its wheels or be permanently affixed to the bulkhead.
Choosing the 160-B semi-portable fire extinguisher is problematic aboard a vessel for a number of reasons. First, if it is to remain portable, i.e., on its wheels, it will be difficult to move and maneuver on the vessel. Additionally, when not in use, it must be stowed carefully to prevent if from rolling while the vessel is underway. And, if it is permanently affixed, its range of use is limited by the hose length which is typically only 50 feet (15m) long.
A far better option is choosing a fixed fire suppression system. Fixed systems are always on duty, are rated for the risk they protect, do not require human interaction, and are generally extremely effective when designed, installed, and maintained correctly. They are also safer because they do not require personnel to enter the hazard area to attack the fire.
An excellent choice for the protection of recreational vessels is the Stat-X® fire suppression system. Enclosed machinery spaces onboard a vessel are the ideal environment for Stat-X as its total-flooding system can rapidly suppress Class A (surface), Class B, and Class C fires. Once discharged, the agent remains suspended for up to ten minutes providing effective reflash protection. Further, the compact system installs easily, takes up no floor space, and requires minimal maintenance.
In addition to its effectiveness, Stat-X is safe for both personnel and the environment. Many fire suppression agents are facing regulatory pressure from environmental and government agencies because they have ozone-depletion and global-warming potential, or they contribute to a growing PFAS concern. Moving forward, nearly all fluorine-based fire suppression chemicals are likely to be phased down or banned altogether due to their environmental properties or safety related concerns. Similarly, once popular marine fire suppression agent, CO2, is no longer used as commonly, because it is not safe for protection of normally occupied spaces.
Stat-X poses none of these risks. It is environmentally friendly, has zero atmospheric life (non-persistent), and is safe to use in normally occupied areas. With Stat-X, regulatory certainty is piece of mind. You will not be face costly system/agent replacement in the future and/or potential fines from enforcement agencies
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Sources
[1] All tables and graphics were sourced from 33 CFR 175