SOLAS Requirements for Weather Deck Fire Detection & Fire Monitors

fire detection, fire monitor, Fire Protection, fire suppression, FSS Code, passenger ship, Regulations, ro-pax, Ro-Ro, SOLAS, Unifire, Weather Deck

INTRODUCTION

This article explains the requirements of ro-ro passenger ships to protect the weather deck with fire detection and fire monitors. As a general rule, the SOLAS Convention applies to passenger ships on international voyages. This includes ro-ro passenger (ro-pax) ships world-wide. These regulations are governed by the International Maritime Organization’s (IMO’s) Maritime Safety Committee (MSC). Each year, the MSC meets to approve and adopt the SOLAS regulations. June 2023 marked the 107th meeting, so called MSC 107.

New SOLAS Chapter II-2/20 regulations & FSS Code sections were approved at MSC 107 in June, 2023 (and are subject to adoption at MSC 108 in May, 2024). This chart explains the current and new requirements for fire detectors and fire monitors to be installed on weather decks.

This article sets out:

1) the current requirements for existing ships and all ships built before January 1, 2026; and

2) the newly approved requirements (subject to adoption at MSC 108 in May, 2024), which will apply to all ships built before January 1, 2026, and to all new build ships starting January 1, 2026.

This article is organized in four parts.

Part I, below, discusses the requirements currently in force as of the writing of this article (July 2023).

Part II, below, discusses the newly approved regulations as they will soon apply to existing ships and ships built before January 1, 2026.

Part III, below, discusses the newly approved regulations as they will apply to all ships built on or after January 1, 2026.

Lastly, Part IV provides a brief re-cap and concluding remarks.

PART I: CURRENT SOLAS II-2/20 REGULATIONS

As of the writing of this article in July, 2023, the following Interim Guidelines (MSC.1/CIRCULAR.1615, 26 June, 2019) currently applies to ro-ro passenger (ro-pax) ships:

“2.4 Fire detection on weather decks: A fixed fire detection and fire alarm system should be provided for weather decks intended for the carriage of vehicles. The fixed fire detection system should be capable of rapidly detecting the onset of fire on the weather deck. The type of detectors, spacing, and location should be to the satisfaction of the Administration, taking into account the effects of weather, cargo obstruction and other relevant factors. Different settings may be used for specific operation sequences, such as during loading or unloading and during voyage, in order to reduce the false alarms.
MSC.1/CIRCULAR.1615, 26 June, 2019

3.4 Fixed fire-extinguishing measures on weather decks: Additional fire-extinguishing measures such as fire monitors and drainage systems may be considered on weather decks. Remotely controlled fire monitors may allow for safe operation of the monitors, but where suitable, manually operated fire monitors may also be used.”
MSC.1/CIRCULAR.1615, 26 June, 2019

While this language does not specifically mandate the use of fire detection or fire monitors, it is clear that they are recommended. Although existing ships that do not currently have fire detection and fire monitors protecting their weather decks are not technically in direct violation of MSC.1/CICULAR.1615, they may still be subject to civil liability for failure to take reasonable measures to protect the passengers and their property. It is therefore highly recommended that ship operators take immediate action to protect the weather decks with fire detection and fire monitors. Moreover, they should do so in compliance with the newly-adopted regulations discussed below in order to avoid further costs associated with bringing them into compliance, which will be required by January 1, 2028 (subject to adoption in May, 2024, at MSC 108).

Furthermore, we recommend that ro-ro passenger ship operators, when planning to outfit the weather decks with fire detection and fire monitors, comply not only with the minimum requirements of SOLAS II-2/20, but also with the new recommendations of the LASH FIRE project. LASH FIRE is a new 3-year study to make further recommendations to the IMO and the Maritime Safety Commission subcommittee.

These new LASH FIRE recommendations are likely to be considered for yet further changes to the SOLAS and FSS Code to improve fire safety on, among other things, the weather decks of ro-ro passenger ships. The LASH FIRE recommendations are made by a consortium of international experts, including Unifire AB, and based on scientific fire tests. See: “Weather deck fire monitors: LASH FIRE insights in light of anticipated new SOLAS requirements“, International Fire Fighter, 02-03-2023. See also webinar on weather deck fire suppression https://youtu.be/u9NX8cDL88Y.

PART II: NEW SOLAS II-2/20 REGULATIONS – ALL SHIPS BUILT BEFORE JANUARY 1, 2026

The following new SOLAS II/2/20 Paragraph 6.2.3 will soon apply to existing ships and all ships built before 1 January 2026. It will require that the weather deck be protected by fixed fire detection and fire monitors.

Passenger ships with vehicle, special category or ro-ro spaces constructed before 1 January 2026 shall comply with the requirements of paragraphs 6.2.3 not later than the first survey after 1 January 2028. The relevant paragraphs read:

Fire Detection

“2.4 Fire detection on weather decks: A fixed fire detection and fire alarm system should be provided for weather decks intended for the carriage of vehicles. The fixed fire detection system should be capable of rapidly detecting the onset of fire on the weather deck. The type of detectors, spacing, and location should be to the satisfaction of the Administration, taking into account the effects of weather, cargo obstruction and other relevant factors. Different settings may be used for specific operation sequences, such as during loading or unloading and during voyage, in order to reduce the false alarms.
MSC.1/CIRCULAR.1615, 26 June, 2019

Fire Monitors

For passenger ships built before 1 January 2026, a fixed water-based fire-extinguishing system based on monitor(s) shall be installed in order to protect areas on weather decks intended for the carriage of vehicles. Monitors shall be located in positions which ensure unobstructed protection of vehicles in the area on the weather deck intended for carriage for vehicles, as far as practicable. Operation of monitors shall be ensured by safe access ways or remote control not to be impaired by a fire in the area protected by that monitor. Capacity of each monitor shall be at least 1,250 L/min. The Administration may permit lower flow rates when the required rate is not practical given the size and arrangement of the ship. The Administration may also permit alternative arrangements for ships that have already installed a fixed water-based fire-extinguishing system based on monitor(s) prior to 1 January 2026.

SOLAS II/2/20, Paragraph 6.2.3

The result of this new regulation is that ship owners and operators should begin soon planning for and installing fixed fire detectors and must install fire monitors to protect the weather decks of all ro-ro passenger ships that are not already so protected. And while they must comply by January 1, 2028, delaying action only will result in interim risk to the lives of passengers and safety of the ship, as well as potential civil liability in the event of a fire.

PART III: NEW SOLAS II-2/20 REGULATIONS – ALL SHIPS BUILT ON OR AFTER JAN 1, 2026

MSC 107 approved amendments to SOLAS Chapter II-2 and the FSS Code in June, 2023. The new amendments are expected to enter in to force on 1 January 2026, subject to adoption by MSC 108 (May 2024).

The following three Paragraphs relate to weather deck and structural fire protection for ro-ro passenger (ro-pax) ships built on or after January 1, 2026.

FIRE DETECTION & FIRE ALARM SYSTEMS

New SOLAS II-2/20 Paragraph 4.1.4 reads,

In passenger ships, a fixed fire detection and fire alarm system shall be provided for the area on the weather deck intended for the carriage of vehicles. The fixed fire detection system shall be capable of rapidly detecting the onset of the fire anywhere on the area. The type of detectors and their spacing and location shall be to the satisfaction of the Administration, taking into account the effects of weather conditions, cargo obstruction and other relevant factors. Different settings may be used for specific operation sequences, such as during loading or unloading and during voyage, in order to reduce the false alarms.
New SOLAS II-2/20 Paragraph 4.1.4 (approved at MSC 107, subject to adoption at MSC 108 in May, 2024)

FIRE EXTINCTION

New SOLAS II-2/20 Paragraph 6 reads, in relevant part,

The requirements of paragraph 6.2 shall apply to ro-ro passenger ships constructed on or after 1 January 2026. Passenger ships with vehicle, special category or ro-ro spaces constructed before 1 January 2026 shall comply with the requirements of paragraphs 6.2.3 not later than the first survey after 1 January 2028.)”

6.2 Fixed water-based fire-extinguishing on weather decks intended for carriage of vehicles

6.2.1 In passenger ships, a fixed water-based fire-extinguishing system based on monitor(s) shall be installed in order to cover weather decks intended for the carriage of vehicles. The monitor(s) shall comply with the provisions of the Fire Safety Systems Code.
New SOLAS II-2/20 Paragraph 6 (approved at MSC 107, subject to adoption at MSC 108 in May, 2024)

STRUCTURAL FIRE PROTECTION

New SOLAS II-2/20 Paragraph 5.3 reads,

5.3 Arrangement of weather deck intended for the carriage of vehicles

5.3.1 Appropriate arrangements shall be made so that a fully developed fire on weather decks intended for the carriage of vehicles does not endanger:

.1 stowage areas for survival craft;

.2 embarkation stations and assembly stations including access to these; and

.3 accommodation spaces, control stations and normally occupied service spaces in superstructures and deckhouses adjacent to the weather deck.
New SOLAS II-2/20 Paragraph 5.3 (approved at MSC 107, subject to adoption at MSC 108 in May, 2024)

PART IV: SUMMARY & CONCLUSIONS

Current regulations governing existing ro-ro passenger (ro-pax) ships, and those built before January 1, 2026, recommend, but do not mandate, that the weather decks be protected by fire detection and remote control fire monitors.

New SOLAS regulations, approved in June 2023, which are expected to be adopted in May 2024, will apply to all ships built before January 1, 2026, to require that the weather decks of ro-ro passenger (ro-pax) ships be protected by fire detection and remote control fire monitors. It also will require that they be in compliance by January 1, 2028. Details are set out in newly-approved FSS Code.

The new regulations, will also apply to all ships built on or after January 1, 2026, to require that the weather decks of ro-ro passenger (ro-pax) ships be protected by fire detection and remote control fire monitors. It also will require that they be in compliance by January 1, 2026. Details are set out in newly-approved FSS Code.

The LASH FIRE research project is an international research project aiming to significantly reduce the risk of fires on board ro-ro ships. The project is running from September 2019 to August 2023. The new research and findings will be presented to the IMO for consideration for yet further improvements to the SOLAS regulations and FSS Code. The LASH FIRE recommendations are consistent with, but go beyond, the newly-approved SOLAS regulations discussed above.

In order to comply with the current and newly-approved SOLAS regulations, it is strongly recommended that ro-ro passenger ship operators and stakeholders take immediate measures to identify and install fire detection and fire monitors for the protection of the weather decks and structures. Moreover, it is recommended that they do so not only in minimum compliance with the newly-approved regulations, but also with best practices as informed by the LASH FIRE research project. This is important for several reasons:

LASH FIRE provides the latest tests, studies and recommendations for best-practices in weather deck fire detection and fire suppression, taking into account state-of-the-art equipment and recently-conducted, unique fire tests thereof;
LASH FIRE recommendatiosn will be considered for further adoption to the SOLAS regulations and FSS Code and, if adopted, implementing them now will save significant time and investment; and
The latest technology, and in particular, fully autonomous fire monitor systems, are likely to significantly improve fire safety well beyond the newly-approved regulations, and at little additional cost.

It is important to note that ship operators, as common carriers, owe a duty to their passengers to protect them from fire and other hazards. These duties go beyond and are irrespective of regulations. For this reason, it is incumbent upon ship operators to carefully consider the best practices in managing a potential fire on the weather deck and other areas of the ship. Current state-of-the-art technology exists, which combines fire detection and fire suppression for the autonomous suppression in seconds of a fire breaking out (see: https://unifire.com/firerescue1-2023-07-05/) . These systems, as well as other recommendations of the LASH FIRE research project, should strongly be considered when designing a system for weather deck protection.

For more information about the current and new regulations governing weather deck fire safety on ro-ro passenger ships, contact Unifire AB. Unifire offers fire detection and fire suppression systems for weather deck fire safety and is an expert in not only the requirements of the applicable regulations, but also in best-practices and minimizing the consequences of fire should one break out.

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