Legislation & Changes in Fire-Fighting Treatments on Board Yachts

New legislation has been put in place by the International Maritime Authority since October 2012. The new clause governs the fire safety standards applicable for all textiles onboard of any marine vessel. Essentially, the new regulations stipulate that adequate protection must be accorded to various furnishing fabrics inside any boat, such as upholstery, carpets, bed sheets, draperies, and curtains. The new set of enforcements is to ensure that these textiles do not inadvertently aid the spread of fire onboard the vessel.

With the new legislation, the requirement has become more stringent. Fire and flame retardant fabrics will now need more than a pass from the IMO FTP Code of Practice in order to be recognized as being fire safe. The applicator of the fire retardant process needs to be an approved supplier of Flame Retardant treatment services. The process and practice of the applicator would be put under tight scrutiny of a Notified Body appointed by the Maritime and Coastguard Agency (MCA), to make sure that these are consistent with the standards published in the MCA MGN453. Moreover, test samples need to be submitted to an International Maritime Organization (IMO) approved lab to make sure all procedures conform to the IMO 2010 FTP Code, and these procedures include ten cleaning cycles of the test sample before any testing commences.

Since the industry is fragmented, naturally a number of service providers emerged after the announcement of the new legislations, each providing specialized services on its expertise. More established companies that are able to get Approved status from the Large Yacht Code (LY2) are able to issue certification directly to new or existing boats, as a mark that these vehicles are constructed in compliance with the Large Yacht Code, which incorporates fire retardant criteria for textiles.

Some companies (usually smaller ones) are active in more niche areas. For example, there are plenty of service providers that specialize in the MCA MGN453 and the IMO FTP Code of Practice. They are often approved vendors from the respective bodies and they can provide vessel owners with certifications with regards to fire retardant treatment.

If you are a marine vessel owner, it makes sense to secure this certification from approved suppliers. You don’t want to take chance as far as fire safety is concerned. The life of your passengers, crew and yourself are definitely worth more than whatever premium these approved suppliers may ask over the non-approved suppliers. Remember, it doesn’t pay to get a non-approved supplier for fire safety assurance. You would never get peace of mind with this engagement.

How Approved Suppliers Can Help You

The assurance from approved suppliers is significant. First off, they are certified and audited by the industry authority, so you know that these names are the trusted names in the industry. Secondly, fire retardant treatment may involve a wide variety of products and procedures (due to the different mechanical and chemical properties which exist in different kinds of materials, e.g. cotton fabric may have to be treated differently from a wool scarf), and within the confines of your yacht, there are bound to be items made of different materials, so you can be rest assured that an approved supplier will have all the means to deal with your different contents inside your vessel.

As an additional note, it probably makes more sense to engage a Large Yacht Code certified supplier so that the company can issue a valid certificate for the entire marine vessel, in compliance with both LYC and MCA MGN 453. This way, the owner does not have to deal with individual accredited bodies.

The safety factor on textiles used inside a boat aside, approved vendors also guarantee that treated materials will not change the look or feel of these items. There is no chance that your favorite sofa or attire will lose any of its original appeal after treatment.

What Has Changed?

The October 2012 legislations brought about some changes to the existing MCA MGN 453 codes in areas that correspond to Fire and Flame Retardant Fabric Application. The changes related to service providers are:

1. Stricter accreditation and annual audit process for service providers
2. Technical experience and expertise in Textiles
3. A Declaration of Conformity must be issued to the yacht and the Flag Administration
4. Full and detailed documentation of treatment process
5. Product application process must be witnessed by a Nominated Body approved by the concerned authority
6. Verification on product application rates
7. Product should survive pre-conditioning treatment
8. Plant and facilities must undergo audit process
9. Audit on Service Providers Quality Manual to ensure traceability
10. A register of all trained and certified personnel employed by service providers
11. The certification on the vessel is to be valid for no more than 2 years, ideally for one year.

Key Points From the New Code

Broadly speaking, the new MCA Approval Procedures follow the convention on flame retardant materials employed by any vessel under the jurisdiction of the MCA LCY Code. Compliance is strict as they have to adhere to either the prevailing 2010 IMO FTP code or the process must conform to the requirements as stated by the MGN 453 codes. The new code does not make any provision for other approvals from other standard boards like EN or BS standards (European or British). Such alternative approvals (EN and BS included) are not held up to have the same standards as issued by the MCA.

The cut off date was set at 1 October 2012. Service providers had to prove that they are in compliance with these new Procedures by that date. Upon the expiry of that date, any Service Provider that provided fire retardant application on floor coverings, upholstery materials, suspended textile materials, and bedding components onboard UK or Red Ensign Group flag MCA LCY Code certified vessels, must seek approval and certification with regards to these new Procedures.

Without exception, any treatment process that deals with upholstered furniture, vertically supported textiles and films, and bedding components has to conform to the criteria as spelt out in Parts 7, 8 and 9 of the 2010 IMO FTP Code.

Applicators need to make sure that the fire retardant treatment products they apply are consistent with the documented instructions. Only trained and certified persons from the Service Providers, or any approved agents, can perform this treatment.

For vessels that have been put into service, service providers must do their best to identify the material composition. This, for example, could be achieved by getting in touch with the ship builder/material supplier. Alternatively, samples could be extracted out for necessary testing, with practicality in mind, or by seeking verification from experts in the textile field.

A Declaration of Conformity is expected from the concerned Service Provider, confirming that all materials and textiles documented onboard have been treated in accordance to the tested samples that have been approved. The service provider also needs to furnish 4 signed copies for this purpose; the 4 copies go to:

• the customer (ship builder or owner),
• the vessel and to be kept on-board at all times,
• the Flag Administrator as a form of survey records,
• the Service Provider for keep sake.

Repeat treatments should happen not later than 24 months after the last treatment, and this treatment is to be declared under the Conformity (Part 3) requirement. However, when there is regular cleaning on the treated materials, then the retreatment process may have to be paced closer after each treatment. As a rule of thumb, a frequency of a 12 month cycle is often considered good enough, or at the discretion of the concerned Service Provider.

With the new laws in place, make sure that your marine vessel conforms to the new laws making is safe for your family and friends to travel the seas with you.