1. Introduction
The amendments include specifications and editorial changes to the regulations concerning fire protection for cargo ships and passenger ships. The amendments enter into force on 1 January 2024. See the notes to each provision for more information about the amendments.
2. Consultation
The proposed amendments were circulated for review from 21 June to 10 September 2023. We received consultative statements from the Norwegian Directorate of Fisheries, the Norwegian Hull Club, the Norwegian Union of Marine Engineers, the Ministry of Climate and Environment and the Ministry of Justice and Public Security. None of the statements included comments.
3. Background for the amendments
Resolution MSC.484(103) and MSC.457(101) lay down amendments to the International Code for Fire Safety Systems (FSS Code) chapters 9 and 15. The resolutions enter into force on 1 January 2024.
The amendments were negotiated in the relevant IMO committees and adopted in plenary at the IMO Marine Safety Committee (MSC). In cooperation with the industry, Norway developed positions and participated in the negotiations. The industry should be well aware of these amendments through information from special interest organisations and the Norwegian Maritime Authority (NMA).
The MSC has adopted amendments to the FSS Code through the resolutions MSC.457(101) and MSC.484(103). Three provisions on inert gas systems in the FSS Code chapter 15 and one provision in the FSS Code chapter 9 have been amended.
The FSS Code has been implemented in Norwegian legislation by reference in the Fire Protection Regulations. Once the Code is amended, the Regulations will need to be amended accordingly. This is the sole amendment to the Fire Protection Regulations, but the NMA would like to clarify the amendments made to the Code. Furthermore, the NMA has looked at the lifebuoy configuration that is required in small fishing vessels, making adjustments applicable to cargo ships of 8 to 15 metres in overall length.
4. Notes on the provisions
Comments to the amendment provisions are specified below.
4.1 Resolution MSC.484(103)
In the FSS Code chapter 9, paragraph 2.1 is amended by adding a new paragraph 2.1.8:
"2.1.8 In cargo ships and on passenger ship cabin balconies, where an individually identifiable system is fitted, notwithstanding the provisions in paragraph 2.1.6.1, isolator modules need not be provided at each fire detector if the system is arranged in such a way that the number and location of individually identifiable fire detectors rendered ineffective due to a fault would not be larger than an equivalent section in a section identifiable system, arranged in accordance with paragraph 2.4.1."
The amendment is a specification of existing legislation. The amendment allows for the ship, under specific circumstances, not to have isolator modules at each fire detector.
4.2 Resolution MSC.457(101)
The wording of the FSS Code chapter 15 paragraph 2.2.3.2.1 is amended to read "The inert gas main may be divided into two or more branches downstream of the non-return devices required by paragraph 2.2.3.1."
The FSS Code chapter 15 paragraph 2.2.3.2.6 reads:
"Arrangements shall be provided to enable the inert gas main to be connected to an external supply of inert gas. The arrangements shall consist of a 250 mm nominal pipe size bolted flange, isolated from the inert gas main by a valve and located downstream of the non-return valve. The design of the flange should conform to the appropriate class in the standards adopted for the design of other external connections in the ship's cargo piping system."
The amendments are of an editorial nature. The term "downstream of" is technically correct in pipe discussions. The previous wording, "forward of", may be mistaken as referring to the direction of the vessel or similar. Hence, the convention has been amended.
The amendments enter into force on 1 January 2024.
5. Administrative and financial implications
As mentioned, the NMA assumes that the parties that relate to the FSS Code on a daily basis are familiar with the discusses amendments. Furthermore, the resolutions will not result in financial implications for the parties, since the amendments are primarily of an editorial nature. Consequently, the NMA anticipates that the amendments will incur minor costs for the industry. The authorities and the industry will need to adapt to the legislative control. Nevertheless, as control and certification are already conducted in accordance with the FSS Code, the amendments fall under a well-established control and inspection regime. The administrative consequences will therefore not be big.