ASTM Seminar on Fire Testing for SOLAS and Navy … · ASTM Seminar on Fire Testing for SOLAS and Navy Vessels U.S. Coast Guard Approval Process By . Louis Nash. Lifesaving and Fire
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United States Coast Guard ASTM Seminar on Fire Testing for SOLAS and Navy Vessels U.S. Coast Guard Approval Process By Louis Nash Lifesaving and Fire Safety Division Office of Design and Engineering Standards
Louis NashLifesaving and Fire Safety DivisionOffice of Design and Engineering Standards
Presenter
Presentation Notes
Good morning. My objective is to give you a framework to aid in understanding the following four presentations. While the title of my talk is our approval process, I am going to concentrate on the FTP Code and that part of the U.S. Coast Guard’s approval process related to the FTP Code.
United States Coast Guard
U.S. Coast Guard Approval ProcessOutline
Respective role of IMO and USCG
FTP Code revision process
Schedule for Phase-in of 2010 FTP Code
Effect on existing approvals - Q&A
USCG type-approval process
Relation of FTP Code parts to USCG Approval Series
Q&A (followed by FTP Code annexes)
Presenter
Presentation Notes
I will give a brief sketch of the evolution of maritime safety regulation as a lead in to an explanation of the roles played by International Maritime Organization and the U.S. Coast Guard. Then I will explain how this revision of the FTP Code occurred from the US perspective. Next we will cover the implementation schedule for the 2010 FTP Code, and expected effect on existing approvals. Then I will cover our approval process for FTP Code related products and attempt to provide you with the correlation between the USCG approval series and the FTP Code Parts.
United States Coast Guard
U.S. Coast Guard Approval ProcessRegulatory Evolution
1838 Steamboat inspections by Court-appointed inspectors
1852 Steamboat Act – inspections by Dept. of Treasury
1871 Steamboat Inspection Service
Presenter
Presentation Notes
Going to sea has always been hazardous. Throughout history, countries have provided aids to navigation and rescue services. Most of the early regulations for marine trade dealt with taxes, customs, and border control. Eventually, individual countries developed national regulations to address the safety of the vessels and crews. In the US, it was the steam boilers and the growing size of vessels that led to national safety-oriented regulations. In the early 1800s, there were a series of boiler explosions with large losses of life. The explosion of the SS ORONOKO took 130 lives in 1838. The same year, the US District Courts were authorized to appoint inspectors to perform inspections of steamboats. Over the years, the inspection scheme was modified and expanded. The increasing regulation of maritime commerce by individual countries created problems addressing foreign vessels entering one’s ports. The vessels had to contend with different and possibly conflicting requirements. The ports had to consider whether the foreign vessels presented a hazard to the port and to its citizens.
United States Coast Guard
U.S. Coast Guard Approval ProcessRegulatory Evolution
1912 RMS TITANIC
1914 International Convention for the Safety of Life at Sea
The War to End all Wars
1929 2nd International Convention for the Safety of Life at
Do you remember the tale of the RMS TITANIC? Afterwards, thirteen countries met in 1914 to develop an international agreement. This agreement fell victim to World War I. In 1929, eighteen countries met for a second convention. This ad-hoc development of international agreements changed with the establishment of the United Nations in 1945. Fairly quickly, the concern over international shipping led the UN to form the Inter-governmental Marine Consultative Organization. It met for the first time in 1959. That organization was renamed the International Marine Organization (IMO) in 1982.
United States Coast Guard
U.S. Coast Guard Approval ProcessInternational Maritime Organization (IMO)
International Convention for Safety of Life at Sea (SOLAS)
Presenter
Presentation Notes
The establishment of IMO created an international institution for governments to continuously negotiate minimal acceptable standards for international maritime trade. IMO is not a consensus standards organization; it does not hold public meetings. Governments and those organizations with observer status send delegations to the meetings. U.S. Coast Guard participation is under the authority of the U.S. Department of State. The effort has grown from 18 countries in 1929 to 170 member states today. In addition, there are non-voting observers to provide advice and comment. This has resulted in multiple international agreements. Some of these are for vessels trading in the Caribbean Sea, for Mobile Offshore Drilling Units, for fishing vessels, and for cargo vessels less than 500 gross tons. Not all of the agreements or treaties have been ratified by all member states. The agreement, which is the basis of this seminar, is the International Convention for Safety of Life at Sea which is better know as SOLAS.
United States Coast Guard
U.S. Coast Guard Approval ProcessMaritime Regulatory Roles
International Convention for Safety of Life at Sea (SOLAS)
International Code for Fire Safety Systems (FSS Code)
International Code for Application of Fire Test Procedures (FTP Code)
IMO as a forum
Administrations as enforcers
Flag State
Port State
Presenter
Presentation Notes
When SOLAS references another code, such as the FSS Code and FTP Code, in a requirement, those codes are mandatory for vessels subject to SOLAS. [CLICK] IMO serves as a forum for developing and formalizing agreements. It has no enforcement authority. [CLICK] Governments are responsible for enforcement; each government identifies an administration responsible for enforcement. The U.S. administration is the U.S. Coast Guard. Every vessel on the high seas is supposed to fly the flag corresponding to its nationality. The flag state administration (or its designated agent) issues certificates to the vessel certifying compliance with SOLAS. Every country has the authority as a port state to verify that the certificates are valid and to audit compliance.
United States Coast Guard
U.S. Coast Guard Approval ProcessFTP Code Revision
January 2005 - Proposed to IMO by Japan
January 2006 – FP 50 establishes 1st correspondence group
February 2007 – 1st Working Group meeting
January 2008 – 2nd Working Group meeting
February 2009 – 3rd Working Group meeting
Presenter
Presentation Notes
The FTP Code also evolved piecemeal. IMO first started developing resolutions on recommended fire test procedures as guidance for the Administrations. In 1992, IMO decided SOLAS should specify the test procedures. However, they did not want to reopen discussions going back to the 1980s. So the first FTP Code specified different IMO resolutions with some modifications. That FTP Code and the amendments to SOLAS went into effect in July 1998. Less than 7 years after implementation, Japan proposed that the FTP Code be revised. This revision was to reflect the various interpretations agreed to by IMO, the issue of and revisions to ISO standards, and the changes to SOLAS with regard to the High-Speed Craft Code. Raising the level of safety was not a stated goal for the revision. The Subcommittee on Fire Protection meets one week a year. At its 50th meeting, it established the first intersessional correspondence group for revising the FTP Code. The report of the correspondence group then fed into the working group that met concurrently with the subcommittee the following year.
United States Coast Guard
U.S. Coast Guard Approval ProcessFTP Code Revision
IMO Correspondence Group USCG
US correspondence group
Presenter
Presentation Notes
The first Intersessional Correspondence Group had representatives of fourteen member governments and two nongovernmental organizations. The USCG established a U.S. correspondence group of industry, laboratories, and academia to aid in formulating the U.S. positions. When we got a round of questions and proposals, we distributed it to our group, collected the feedback, formed a position or proposal, and sent the US input to the IMO coordinator. After several rounds, the IMO Correspondence Group had to submit a written report to IMO by a deadline which permitted the report to be translated and distributed before the next Subcommittee meeting. ----------- 1st CG: Argentina, China, Denmark, Finland, France, Italy, Japan, Republic Of Korea, Netherlands, Norway, Poland, Sweden, United Kingdom, United States. International Organization For Standardization (ISO) International Chamber Of Shipping (ICS)
United States Coast Guard
U.S. Coast Guard Approval ProcessFTP Code Revision
IMO Correspondence Group USCG
US correspondence groupIMO Working Group
Presenter
Presentation Notes
This report fed into the working group at that meeting. At the Subcommittee meeting, they would initiate another cycle by establishing another intersessional correspondence group. This process was repeated for three cycles. The draft code was then cleaned up by a drafting group at FP 54 in April 2010. ----------- 1st CG: Argentina, China, Denmark, Finland, France, Italy, Japan, Republic Of Korea, Netherlands, Norway, Poland, Sweden, United Kingdom, United States. International Organization For Standardization (ISO) International Chamber Of Shipping (ICS)
United States Coast Guard
U.S. Coast Guard Approval Process2010 FTP Code Implementation
Adopted 3 December 2010
Publish in March 2012 by IMO
Becomes effective 1 July 2012
1-year grace period to transition test equipment
New test procedures are mandatory on 1 July 2013
Presenter
Presentation Notes
It took 6 years to revised the code. The 2010 FTP Code was adopted by IMO on the third of December of 2010. The new code is expected to be available for purchase from IMO this coming March. The code becomes effective in July 2012. There is a one-year grace period during which products may be tested to either the current test procedures or the new procedures. All approval tests must use the new procedures starting July 1st of 2013.
United States Coast Guard
U.S. Coast Guard Approval ProcessEffect on Approvals
Minimal effect overall
Approvals continue to be for 5 years
May renewed without retesting
No changes in product
Test report is not more than 15 years old at renewal
Retesting must use test procedures in effect at renewal
Interpretation of Administration
QUESTIONS
Presenter
Presentation Notes
In general, the 2010 FTP Code will have a minimal effect on existing approvals except for those relying on test reports from 1997 and 1998. Under the new FTP Code, approvals based on testing to the previous code or the new code may be renewed per normal procedures provided that not more than 15 years has elapsed from testing. Then, one must retest using the approval test procedures in effect at the time of renewal. Theoretically, it is possible that a product may have an approval life up to 20 years without retesting. However, approvals are generally issued after the approval tests have been conducted. So the report is more than 5 years old at first renewal, more than 10 at the second, and more than 15 at the third. So in practice, I would suggest that you expect no more than 15 years of approval based on an approval test. This also applies to new approvals issued under the new code. The old code was less than 30 pages, but referenced a number of IMO resolutions. The MSC circular containing the new code is 207 pages but includes the test procedures. So we have 207-page document with a lot of compromises developed by people with different native languages. While the new code does identify options subject to the discretion of the Administration, I can assure you that there is plenty of opportunity in the document for puzzlement, clarifications, and further interpretation. Click - QUESTIONS
United States Coast Guard
U.S. Coast Guard Approval ProcessApproval Types
Type approval
Good for 5 years
May be renewed
Product appears on approved equipment lists
Case-by-case approval
Used to provide regulatory flexibility
Test report must be less than 2-year old
Approval is specific to a vessel
Issued only by the Flag Administration or its agents
Presenter
Presentation Notes
There are two types of approvals. The test requirements are the same for both types of approval. The preferred type is Type Approval whose documentation is an approval certificate. This approval is not specific to a given vessel. The validity of the approval is public information. Lists of approved equipment provides a cleared shopping lists for buyers. The case-by-case approval is a review of the product for use on a specific vessel. The test requirements are the same. This should be thought of as the testing and approval of individual lots. The review must be repeated and an approval issued for each vessel. It also must be carried out by the flag administration or its designated agents. The remainder of my presentation is for the type approval as issued by my office.
United States Coast Guard
U.S. Coast Guard Approval ProcessReason for Approvals
Type Approval Plan Review
Field Inspection
Presenter
Presentation Notes
Why are there type approvals? It is an efficient division of labor intended to facilitate complying with the regulations. The U. S. Coast Guard approves materials and equipment as part of the marine inspection program. The approval process reviews the item and test reports to determine whether the item complies with the regulations. Success results in a approval certificate not connected with any particular vessel. The plan reviewer for a vessel only needs to check that the item is approved and that the plans show that the approved item is used in the proper manner. The field inspectors used the approved plan and the approval certificate to ensure the vessel is built or equipped per the regulations.
United States Coast Guard
U.S. Coast Guard Approval ProcessApproval Basics
U.S. Coast Guard does not charge for issuing approvals
Manufacturer responsible for cost associated with laboratory
Cost of testing
Cost of follow-up service
Independent laboratory acceptable to U.S. Coast Guard
Meets 46 CFR 159.010
USCG will accept test report for review
Is not an agent of USCG
http://cgmix.uscg.mil
Presenter
Presentation Notes
We do not charge for reviewing requests, issuing approvals, and renewing approvals. The manufacturer is responsible for paying the laboratory. In choosing a lab, I suggest that you consider the life cycle costs; that is the cost associated with approval tests and that for 15-years of follow-up program. The laboratory must be an independent laboratory acceptable to the U.S. Coast Guard. You can find a list of these laboratories on the Coast Guard Marine Information Exchange known as CGMiX on the internet. These laboratories have been accepted per the Code of Federal Regulations with a scope of acceptance specifying the approval series. These laboratories do not work for us. We do not control their costs or schedule.
United States Coast Guard
U.S. Coast Guard Approval ProcessApproval Basics
Certificate of Approval is valid for 5 years.
Specific product
Manufacturing location
Product can not be changed without prior written agreement of change.
Must have valid approval when manufactured.
Once installed, may remain in service as long as it is serviceable.
Presenter
Presentation Notes
A certificate of approval has a 5-year life unless it is terminated or revoked. It is for a specified product made at specified locations. The approved product may not be changed without written agreement. The approval must be valid when the product is made and marked. Once the approved product is placed in service, the product may remain is service as long as it remains serviceable. So expiration of approval does not require removal of the product except when the product has an expiration date such as life-raft rations or we terminate the approval for safety reasons.
United States Coast Guard
U.S. Coast Guard Approval ProcessFollow-up Program
Navigation And Vessel Inspection Circular No. 02-06
Performed by the laboratory conducting the approval tests
At least an annual audit
Requires an annual performance test
Presenter
Presentation Notes
All U.S. Coast Guard type approvals involving the FTP Code require a follow-up program. As a minimum, the laboratory must make at least one annual visit to monitor production and select a sample for annual verification testing. Our requirement is a minimum that the laboratory may exceed as they see necessary. We did not create a rigid program as each laboratory has different resources and experiences to draw upon. The goal of the program is to keep honest people honest and to catch the inadvertent changes from unobserved changes in raw materials, production issues, and wear and tear on equipment.
United States Coast Guard
U.S. Coast Guard Approval ProcessType Approval Process
Identify the appropriate approval series for the product
Choose an independent laboratory
Acceptable to USCG
Scope includes that approval series
Laboratory selects test specimens and audits production
Laboratory conducts tests and develops follow-up program
Manufacturer responsible for submitting request for approval
USCG reviews request and issues approval
Presenter
Presentation Notes
The first step, and sometimes the most confusing, is to determine the appropriate approval series for the product. Once you know the approval series, you can identify the available laboratories from our database CGMix. [CLICK] The laboratory you choose will make a site visit and select test specimens. [CLICK] While the request may be made by either the manufacturer or the laboratory, it is the manufacturer’s responsibility to ensure the request is made. The request for type approval should identify the product and approval series, contain contact information, and be accompanied with test reports and follow-up documentation. However, things do not always go as we would want them.
United States Coast Guard
U.S. Coast Guard Approval ProcessPitfalls
Told lab you wanted USCG approval after testing is complete.
Went to a laboratory not on our list for that approval series.
They want what for follow-up?
Waited too long after testing to request approval.
Your intended customer will not accept the approval.
Paid for admission to the party to find an empty room.
Did not talk to us.
Presenter
Presentation Notes
These are some of the common pitfalls. After you have a successful test, you ask the lab to send the results to the Coast Guard. Remember the part where the lab selects the sample. You get to start over. [click] So you did not use a accepted laboratory. The reviewer will say no without even reading the report. [click] So you found out the cost of follow-up after testing. We do not control cost. Not our problem. Please do your homework. [click] We have had a few cases where companies have completed testing and then waited over two years to request approval. We end up denying the request due to the age of the report. [click] You jump through all the hoops and the customer says no. There is no such thing as an IMO approval that is good throughout the world. Please determine the nationality (that is the flag) of the vessel you are hoping to sell to. All of the very large cruise liners are foreign flag. Also, sometimes the purchasers are using the FTP Code tests as buying specifications, and not to comply with regulations. [click] I can not advise you as to whether there is a market. If you jump through the hoops, we issue an approval. Please conduct your market analysis. [click] We encourage questions before testing. If you are in doubt, please ask. The laboratories will do the best they can, but marine approval testing is not their main business. Failure to obtain approval should be due to flunking the tests, not the process.
United States Coast Guard
U.S. Coast Guard Approval ProcessFTP Code related Approval Series
Grouping Series Parts164.109 Non-combustible material 1 & 5
Construction&barriers
164.105 Deck assembly (IMO)164.107 Structural insulation164.108 Bulkhead panels164.110 Structural ceiling164.136 Fire doors164.137 Windows164.138 Penetration seals164.139 Dampers164.207 Fire-resisting division for
high speed craft164.146 Fire door control systems
1, 3 & 5
11
1 & 4
Presenter
Presentation Notes
My goal here is not death by Power Point. I just to give you some idea of which FTP Code tests that you may be interested in for the following presentations. The current code and the revised code are organized such that all of the tests are in Annex 1 of the FTP Code. Annex 1 is broken into Parts 1 through 11. Each Part is a test method. Non-combustible materials are tested to Part 1. However, SOLAS permits low-flame spread adhesives to be used so items such as honey comb panels may have the adhesive tested for surface flammability under Part 5. If your product is a fire barrier or fire insulation, then you are interested in Part 1 for noncombustibility, Part 5 for flammability of the adhesive, and Part 3 for the furnace test. But for High-Speed Craft, Part 11 is Part 4 only applies to fire door control systems which must continue to operate in case of a fire. We have had exactly only one approval for fire door control systems, and that one expired three years ago.
United States Coast Guard
U.S. Coast Guard Approval ProcessFTP Code related Approval Series
Grouping Series Parts
Surface Finishes
164.106 Primary deck coverings164.112 Interior finish164.117 Floor coverings164.201 Fire restricting materials for
If your product is a surface finish such as veneers, wall paper, and carpets, you are interested in Part 2 for smoke and toxicity and Part 5 for surface flammability. Please note that Part 5 applies to primary deck coverings under the new code. There is no Part 6 in the new code. It was merged into Part 5. You may also be interested in Part 10 if your market is high-speed craft. For furnishings, there is a different part for each series. Plastic piping and gratings are not SOLAS items, but the requirements for those items can involve Part 2 for smoke and toxicity and Part 5 for surface flammability.
United States Coast Guard
U.S. Coast Guard Approval ProcessResources
Lifesaving and Fire Safety Division (CG-5214) http://www.uscg.mil/hq/cg5/cg5214/
U.S. Coast Guard Maritime Information eXchange http://cgmix.uscg.mil
Almost everything you need to know about approved items under the purview of my division can be found at the division’s website. This includes how to obtain approval, requirements, and links to other sources of information. It is often used by us when researching a topic and answering questions. You can find list of approved equipment and accepted laboratories at CGMIX. The purpose of this website is to make Coast Guard maritime information available on the public internet in the form of searchable databases. The approved equipment database is updated weekly. A central email address has been set up for all request and inquiries. Your request will be logged and routed to an available subject matter expert. This should alleviate some of the problem of rotating and deployed personnel. (click) Thank you for your attention. Are there any questions?
U.S. Coast Guard Approval ProcessAnnexes of the FTP Code
Annex 1 - Fire test procedures
Annex 2 - Products which may be installed without testing
and/or approval
Annex 3 - Fire protection materials and required approval
test methods
Table 1 – HSC and PV > 36 passengers
Table 2 – Cargo ships
Annex 4 - Interpretation of SOLAS chapter II-2,
regulations 5.3 and 6.2 (MSC/Circ.1120)
Presenter
Presentation Notes
Annex 1 contains the test procedures with acceptance criteria, divided into Parts that we previously discussed. Annex 2 contains exemptions and exceptions which I will discuss in the next slide. Annexes 3 and 4 are explanatory material, that is they serve as an aid in understanding the requirements. Annex 3 contains table for correlating the product with the FTP Code Parts. It has one table for passenger ships carrying more than 36 passengers and high speed craft. Annex 4 provides a clean-up version of the drawings in MSC/Circ.1120. This annex is useful for understanding the terms used in SOLAS and FTP Code for parts of a bulkhead.
United States Coast Guard
U.S. Coast Guard Approval ProcessAnnex 2 of the FTP Code
Inherently noncombustible materials do not need testing.
Noncombustible materials do not need to be tested to Part 2 and Part 5
Very good performance in Part 5
Exempt from Part 2
Exempt from limitation on calorific content (ISO 1716)
Fire-restricting materials (Part 10) for HSC deemed to comply with Part 2
Presenter
Presentation Notes
Items that obviously noncombustible do not need testing or approval certificate. There is no need to prove that steel and glass are noncombustible.
United States Coast Guard
Annex 4 of FTP Code
Presenter
Presentation Notes
United States Coast Guard
U.S. Coast Guard Approval ProcessResources
Lifesaving and Fire Safety Division (CG-5214) http://www.uscg.mil/hq/cg5/cg5214/
U.S. Coast Guard Maritime Information eXchange http://cgmix.uscg.mil
Almost everything you need to know about approved items under the purview of my division can be found at the division’s website. This includes how to obtain approval, requirements, and links to other sources of information. It is often used by us when researching a topic and answering questions. You can find list of approved equipment and accepted laboratories at CGMIX. The purpose of this website is to make Coast Guard maritime information available on the public internet in the form of searchable databases. The approved equipment database is updated weekly. A central email address has been set up for all request and inquiries. Your request will be logged and routed to an available subject matter expert. This should alleviate some of the problem of rotating and deployed personnel. (click) Thank you for your attention. Are there any questions?
