The USCG's interim rule on fire protection equipment for towing vessels requires modification to avoid unnecessary and costly burdens on owners of existing towing vessels, AWO told the USCG. Reiterating its support for the basic suite of equipment and procedural requirements contained in the interim rule ? a general alarm, fire detection system, internal communications system, remote fuel shutoff, and training and drill procedures for crewmembers ? AWO urged the USCG to modify the technical specifications for fire detection systems and fuel shutoff valves before the October 2001 deadline for installation of such equipment.
The interim rule requires a fire detection system be used for no other purpose, a mandate that will disallow the use of most fire detection systems currently used on towing vessels, AWO wrote. This requirement "is not necessary from a safety standpoint and will impose significant costs if vessel owners are required to replace reliable, functioning installed equipment."
AWO urged the USCG to permit the continued use of fire detection systems that, while connected to other engine room monitoring and alarm systems, employ separate circuitry and are subject to regular maintenance and testing in accordance with manufacturer's recommendations.
AWO also urged the USCG to modify the requirement to install a remote fuel shutoff valve on any fuel line subject to internal head pressure from fuel in a tank. While the USCG estimated installation of such equipment would cost approximately $2,500 per towing vessel, compliance will actually cost $2,500-$3,500 per tank, as much as $15,000-$28,000 for a typical towing vessel with six to eight fuel tanks in the spaces adjacent to the engine room, AWO said.
Agreeing that remote fuel shutoffs are a useful means of reducing fire risks, AWO urged the USCG to modify the provision and instead require a remote fuel shutoff on the day tank or storage tank that supplies fuel to the engines, plus any fuel line that contains a flexible hose connection to an engine.
AWO also commented on the USCG's forthcoming supplemental notice of proposed rulemaking, which will address the question of fixed fire suppression systems versus manual firefighting methods on towing vessels. Emphasizing the 1996 USCG Authorization Act's flexible mandate to require "a fire suppression system or other measures" of extinguishing an onboard fire, AWO urged the USCG to require fixed fire suppression systems on appropriate classes of new towing vessels only. Owners of existing towing vessels should not be required to retrofit a fixed system, but should have the option of employing manual firefighting measures and equipment as part of a holistic approach to fire prevention, detection and control, AWO wrote.