The risks of the “ungoverned space” & how to mitigate

Coltraco Ultrasonics is aware of that there is failure to fully implement the regulations. Coltraco supply Marine Servicing companies globally share anecdotes - that at any one time the average merchant vessel in non-UK port visits has over 20% of its CO2 cylinders empty on inspection plus another 10-20% which have contents loss and also know that occasionally marine “servicing companies” unintentionally leave it disabled.

This is a result of the time pressures that are placed upon marine servicing companies. It is well known that vessels are kept at the dock for a minimum amount of time, which reduces time for repairs and thus efficiency without compromise of safety is key. Most marine servicing companies only have 4 hours on a vessel in a port to test up to 600 cylinders. It is known that it takes 15 minutes for a 2 person team to shutdown, dismantle and weigh a single CO2 cylinder, which is equal to 16 cylinders in 4 hours. Yet despite this, every CO2 cylinder on the vessel receives a “tested and certified sticker” and the CO2 & marine CO2 systems is certified and a certificate is issued.

This is the “ungoverned space” in the shipping industry in marine fire protection. Those in the shipping industry do understand that they must hydrostatically test its CO2 cylinders every 10 years (sometimes 5).  Many just do not unless the marine servicing companies demand it – which they often can because the regulation for it exists. However, it is not the hydrostatic testing that matters. The number of cylinders that fail that test is very low, unless they are heavily corroded which the monthly crew inspection under IMO SOLAS FSS Code Ch 5 should have spotted years before it became in such a condition.

Fire System Designers routinely apply an excess of 20% to the design concentration required in the CO2 system to account for safe limits in the space being protected, which has merit in a new system. This is only has meaning when the space is fully compartmented and sealed fully, which a new vessel probably is.

Figure 1: Room Integrity Explained by the Standard P&I Club

However, the excess of 20% does not account for an ageing ship and an ageing fire system, coupled with the weaker compartmentation capability as seals degrade. The fire system itself will degrade at the same pace as the vessel, but with the obvious exception that an older fire system rarely tests itself fully and therefore when it actuates, it has to cope with a one off “burst” of pressure at the time of the fire event.

This risk is amplified by the misunderstanding of the technical operator of the vessels and ships’ officers and crew.  The technical operators understand what the CO2 & marine CO2 systems is designed to achieve but does not understand its physical properties sufficiently enough to maintain it at sea, in between the statutory certification check or able to spot the signs of its future failure before it may be required to attack the fire.

Any vessel with a Marine Gaseous Extinguishing system needs to consider 3 factors :

  • Unless compartmentation exists the gas will not be able to concentrate
  • Unless the contents exists in sufficient quantity design concentration will not occur
  • The pipework and flanges must be tested to be free of corrosion-generated particulates which block the nozzles and must be tested to be able to withstand the shock of gas discharge on actuation

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