Misunderstanding exists across parts of Shipping regarding the application of a part of the International Maritime Organization, Safety of Life at Sea, Fire Safety Systems (IMO SOLAS FSS) Code; the need for crew to test the contents of their CO2, FM-200® & NOVEC™ 1230 Gaseous Extinguishing Systems in between the periodic inspection, maintenance and certification intervals. These periodic inspections are conducted annually or biennially, and only by an Accredited Service Agent i.e. an external Marine Servicing Company. As stated above, the reason the IMO requires crew to test for contents in-between these is that the “ship sails alone”; it must act as its own emergency fire service
A ship’s gaseous extinguishing system typically comprises between 200 and 600 cylinders each containing 45KG of CO2 under high 720 psi/ 49 bar pressure. (Other suppressant clean agents such as FM-200® and Novec 1230 gas suppression system are becoming more widely used.) One of the highest probabilities of discharge occurs during their maintenance. Some marine service companies estimate that 20% of a ship’s CO2 cylinders have discharged or partially leaked their contents at some point in their lifetime. Taking CO2 systems through as an example, although random checks may be suitable in some sectors, it is worth remembering that because the normal design concentration of CO2 of 34-72 v/v % is above the nearly immediate acute lethality level, these systems have an extremely narrow safety margin. As these systems work through oxygen dilution rather than the chemical disruption of the catalytic combustion chain (which is the case with other clean agents), insufficient oxygen levels during an accidental discharge may allow a situation to spiral out of hand. Yet although this poses high levels of risk to the service companies and the crew, because gaseous extinguishing systems are highly pressurized, the risk of leaking and discharging is accepted as part of their use and this is shown in the regulations that demand their upkeep e.g. IMO SOLAS FSS Ch5. 184.108.40.206:
“Means shall be provided for the crew to safely check the quantity of the fire extinguishing medium in the container”
Often this is misunderstood, this code specifically states that the crew must test their extinguishing installations in between the periodic inspection, maintenance and certification. Only having the annual inspection by accredited marine servicing companies is not enough – the crew must take responsibility for its own fire protection. However, what must be noted is that the crew are often not trained or certified to shut-down, dismantle, weigh and re-install the gaseous cylinders – the traditional method.
Using an ultrasonic liquid level indicator is the only way that the crew can safely test their CO2 without disturbing them. If marine companies implemented the IMO SOLAS FSS codes by testing safely and quickly (just 30-60 seconds per cylinder) by using liquid level indicators and marine servicing companies were able to do their work without allowing for time pressures, then marine safety would be far safer.
Bad industry practice is unacceptable when fire risk may have catastrophic results due to risk to life, downtime in operation due to ship safety and repair work and incalculable reputational damage. The crew, cargo and vessel must be protected when at sea because it is it’s own fire brigade without accessibility to typical emergency services. This is a call to respond to regulations with a rigorous attitude, to go above and beyond, to provide security of life and infrastructure