Marine Recommendation M05-05

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Reassessment of the Responses to Marine Safety Recommendation M05-05

Design, Inspection, and Testing of the CO2 System

Background

On the morning of 12 May 2003, while en route from Horseshoe Bay, British Columbia, to Langdale, British Columbia, the Queen of Surrey, with 318 passengers and 137 vehicles on board, suffered a diesel oil fire on its No. 2 main engine. The engine room was evacuated and sealed, and carbon dioxide (CO2) gas was released into it. Although immediate failure of the CO2 distribution manifold allowed some of the gas to escape, enough reached the engine room to extinguish the fire. The vessel was then towed to the Langdale ferry terminal, where the passengers disembarked. There were no fatalities.

The Board issued the safety recommendation on 09 February 2006.

Board Recommendation M05-05 (09 February 2006)

When designed, maintained and tested appropriately, CO2 fixed smothering systems are highly effective in containing and extinguishing fires that have become too large or dangerous to fight using direct-attack methods. Should the activation of a fixed smothering system fail to extinguish a fire, and other firefighting methods are ruled out, the passengers and crew may find themselves in a high-risk situation. In recognition of the crucial protection afforded to spaces deemed to be at high risk of fire, the Board is concerned that, without adequate design requirements to prevent accidental leakage and discharge, and without test procedures to demonstrate continued structural and functional integrity, subsequent failures of fixed fire-extinguishing systems during emergencies may place vessels, crew, passengers and the environment at undue risk. The Board therefore recommended that:

The Department of Transport, in conjunction with other stakeholders, review Canadian and international marine regulations respecting fixed fire-extinguishing systems to ensure that their design, maintenance, inspection, and testing regimes effectively demonstrate continued structural and functional integrity.

M05-05

Response to M05-05 (09 May 2006)

The Minister of Transport, Infrastructure and Communities agrees with this recommendation. It is evident, from the post-incident inspections that the initial installation of the CO2 system was not in keeping with good marine practice and engineering. One of the results of this less than satisfactory initial installation was an acceleration of the deterioration of the system and some of its components.

As part of the regulatory reform regime initiative, Transport Canada will review international marine regulations and standards respecting fixed fire-extinguishing system design, maintenance, inspection and testing. The goal of this review will be aimed at determining whether the proposed Fire Safety Regulations, will involve additional requirements in order to address potential deficiencies that may arise with fixed smothering system installations. The review will assess all aspects of maintenance, testing, and inspections in order to demonstrate continued structural and functional integrity. These regulations are scheduled to come into force in 2007.

Board Assessment of Response to M05-05 (31 October 2006)

The goal of TC's commitment to review international marine regulations and standards respecting fixed fire-extinguishing systems is to determine whether additional requirements will be needed to address potential deficiencies in the domestic regulations. TC has not indicated how it will address deficiencies in international regulations identified in the report and subsequent failures of fixed fire-extinguishing systems during emergencies may continue to place vessels, crew, passengers and the environment at undue risk.

TC's planned action, when completed, will substantially reduce the deficiencies associated with domestic regulations. However, the planned action does not address deficiencies in international regulations, identified in the recommendation.

Therefore, the assessment is assigned Satisfactory in Part.

Response to M05-05 (June 2008)

TC's update, dated June 2008, indicated that TC continues to review requirements and will determine whether the proposed Fire Safety Regulations will involve additional requirements in order to address potential deficiencies that may arise with fixed smothering system installations. The review will assess all aspects of maintenance, testing, and inspections in order to demonstrate continued structural and functional integrity. The proposed Fire Safety Regulations are expected to be pre-published in Part I of the Canada Gazette in the Fall 2008.

Board Assessment of Response to M05-05 (September 2008)

No substantial change to address the safety deficiency since the last reassessment. Follow-up information indicated that the proposed Fire Safety Regulations are expected to be pre-published in Part I of the Canada Gazette in the Fall 2009.

Therefore, the assessment of the response remains at Satisfactory in Part.

Response to M05-05 (November 2009)

TC's update, dated November 2009, indicated that it will determine whether the proposed Vessel Fire Safety Regulations will involve additional requirements in order to address potential deficiencies that may arise with fixed smothering system installations. This will include a review to assess all aspects of maintenance, testing, and inspections in order to demonstrate continued structural and functional integrity.

The proposed Vessel Fire Safety Regulations are anticipated to be prepublished in Part I of the Canada Gazette in the spring 2010.

Board Assessment of Response to M05-05 (May 2010)

TC has yet to determine whether the proposed Vessel Fire Safety Regulations will involve additional requirements in order to address potential deficiencies that may arise with fixed smothering system installations. If, however, TC implements action to address the design, maintenance, inspection, and testing regimes to effectively demonstrate continued structural and functional integrity, the deficiencies associated with the domestic regulations should be substantially reduced. It is now anticipated that the proposed regulations will be pre-published in the Canada Gazette, Part I, in the summer of 2010.

Therefore, the assessment of the response remains as Satisfactory in Part.

Response to M05-05 (December 2010)

TC's December 2010 update indicated that the proposed Vessel Fire Safety Regulations will incorporate, by reference, SOLAS Chapter II-2.  As required by  SOLAS, fixed fire extinguishing, systems must meet the requirements of the Fire Safety System Code (FSS Code). SOLAS also requires all systems to be maintained, tested and inspected according to the guidelines published by IMO in MSC/Circ.850 Guidelines for the Maintenance and Inspection of Fire-Protection Systems and Appliances. The proposed Vessel Fire Safety Regulations are anticipated to be prepublished in Part I of the Canada Gazette in the second quarter of 2011.

Board Assessment of Response to M05-05 (March 2011)

If the proposed actions to address the design, maintenance, inspection, and testing regimes of fixed fire fighting and extinguishing  systems are fully implemented, the deficiency will be substantially reduced or eliminated.

Therefore, the assessment of the response is changed to Satisfactory Intent.

Response to M05-05 (December 2011)

The proposed Vessel Fire Safety Regulations incorporate, by reference SOLAS Chapter II-2, as amended from time to time.  Regulation 10 (Fire Fighting) requires that fixed fire extinguishing systems must meet the specification of the Fire Safety System Code (FSS Code) for design and installation. 

Continued structural and functional integrity of fixed fire extinguishing systems will require that all systems to be maintained tested and inspected according to the guidelines published by the International Maritime Organization in MSC/Circ.850 Guidelines for the Maintenance and Inspection of Fire-Protection Systems and Appliances.

The proposed Vessel Fire Safety Regulations are anticipated to be pre-published in the Canada Gazette, Part I in the 1st Quarter of 2012.

Board Assessment of Response to M05-05 (March 2012)

Once the proposed Vessel Fire Safety Regulations are fully implemented, the deficiency will be substantially reduced or eliminated.

Therefore, the assessment of the response remains as Satisfactory Intent.

Response to M05-05 (December 2012)

Transport Canada considers that this recommendation has been met.

The proposed Vessel Fire Safety Regulations incorporate by reference SOLAS Chapter II-2, as amended from time to time. Regulation 10 requires that fixed fire extinguishing systems must meet the specification of the Fire Safety System Code (FSS Code) for design and installation.

Continued structural and functional integrity of fixed fire extinguishing systems will be promoted through Regulation 14 which requires all system to be maintained, tested and inspected according to the guidelines published by the International Maritime Organization in MSC/Circ.850 Guidelines for the Maintenance and Inspection of Fire-Protection Systems and Appliances.

The proposed Vessel Fire Safety Regulationsare anticipated to be pre-published in the Canada Gazette, Part I in the 1st quarter of 2013.

Board assessment of response to M05-05 (March 2013)

Once the proposed Vessel Fire Safety Regulations are fully implemented, the deficiency will be substantially reduced or eliminated. Therefore, the assessment of the response remains Satisfactory Intent.

Next TSB action

The TSB will monitor the proposed action. The deficiency file is assigned Active status.