IMO Requirements/FTP Code May 2001

This is a summary of the requirements for flooring materials that are to be used for shipboard use. The requirements are broken down into two sections: one being the U.S. Coast Guard Requirements for use on ships that will sail in U.S. waters and the second section for ships that will sail in international waters. U.S. Coast Guard Requirements for U.S. Waters Reference: http://www.uscg.mil/hq/g-m/MSE4/sfpguideI.htm The requirements for U.S. Coast Guard for U.S. Waters are defined in the Code of Regulations, Title 46 CFR, Part 164 and further clarified in Navigation and Vessel Inspection Circular No. 9-97 (NVIC 9-97). This complete document is available on the U.S. Coast Guard Web site: www.uscg.mil/hq/g%2Dm/msec4/sfpguidei.htm. The requirements are broken into three sections including deck coverings, deck overlays and deck surface finishes. Primary Deck Coverings - Deck coverings are used specifically for the purpose of increasing the fire integrity of steel or equivalent materials. These deck coverings must be applied directly to the deck. Deck coverings are approved in accordance with 46 CFR 164.006. This test method includes three specific test criteria; namely limited organic content, limited smoke generation and fire resistance and integrity (similar to non-combustibility performance). Floor coverings are not considered deck coverings. Deck Overlays Deck overlays are used specifically for the purpose of leveling or creating a compatible surface in preparation for the final deck surface finish. Such materials may be used over the approved deck covering or applied directly to the deck when it is of an A-0 construction. Deck overlays are not intended to be used to insulate the deck as an approved deck covering nor are they intended to be exposed deck surface finishes. For this reason, any material may be used as an overlay as long as the combined thickness of combustibles that comprise the overlay generally does not exceed 1 cm. Otherwise the material used for the overlay should be noncombustible. Floor coverings are not considered deck overlays. Deck Surface Finishes Deck surface finishes are the final (exposed) surface of the deck. Examples include carpet, wood flooring, vinyl tile, etc. Such finishes may be used in any thickness regardless of space designation but will be included in the fire load if combustible. In spaces requiring fire resistant furnishings including corridors, stairways, type 5 or 5A spaces, the deck surface finish shall meet one of the following requirements for low flame spread and smoke generation: ?? ASTM E 84 flame spread not to exceed 75 and smoke developed not to exceed 100.

?? ASTM E-648 with a critical flux not less than 0.8 watts/cm, and meet E-662 with a specific optical density not to exceed 450 in both flaming and non-flaming mode ?? Meet IMO Resolution A.653(16) in accordance with FTP Code (Part 5), which includes smoke testing in accordance with Part 2 of the Code. Vinyl or wood flooring materials are commonly used as a deck surface finish in accommodation spaces. There are no thickness limitations but when fire resistant furniture and furnishings and approved finishes are required, the vinyl or wood deck surface finish shall meet the flame and smoke criteria stated above. For deck overlays and deck surface finishes, testing may be done for individual components or as a composite in the arrangement intended for actual installation. If tested individually, each component shall meet the same criteria. The Interior Finishes Section 164.012 currently does not include floor finishes. These must be approved under 164.006, or as noncombustible materials under 164.009. However, various vessel regulations contain an exemption for a layer of 3/8 inch of unapproved deck covering material for leveling and finishing purposes. There is currently no plans to change the U.S. Coast Guard requirements for domestic vessels! IMO Requirements for SOLAS Vessels Reference: http://www.uscg.mil/hq/g-m/MSE4/sfpguideII.htm Currently any vessels that is sailing in International waters or waters covered by SOLAS (Safety of Life at Sea) Convention is required to meet the SOLAS or IMO requirements as detailed in FTP Code (International Code for the Application of Fire Test Procedures). The new FTP Code became effective on 1 July 1998 and any new item or material submitted for approval after this date must meet these requirements. There is however a grandfather clause which allows approvals existing on 1 July 1998 to be used until 31 December 2003, although some approvals to older standards are grandfathered only until 1 July 2002. Any product approved as of 1 July 1998 could continue until the end of the grandfather period. The Fire Protection Requirements are broken into three areas which are reaction to fires, resistance to fires and special requirements for high speed crafts. The main concern for flooring is with reaction to fire. The IMO FTP Code defines primary deck covering as the first layer of a floor construction which is applied directly on top of the deck plating and is inclusive of any primary coat, anti-corrosive compound or adhesive which is necessary to provide protection or adhesion to the deck plating. This category (primary deck covering) has no counterpart in the CFR. Other layers above the primary deck covering are called "floor coverings."

Floor coverings and primary deck coverings must meet low flammability, as well as smoke density and toxicity requirements. However, primary deck coverings must meet the low flammability criteria of Part 6 of the FTP Code, while floor coverings must meet the low flammability criteria of Part 5 of the FTP Code. The difference is that primary deck coverings are tested on a steel substrate while floor coverings are tested on a representative substrate or the standard calcium silicate board referenced in IMO Res. A.653(16). Floor coverings and primary deck coverings must meet low smoke density and toxicity requirements (Part 2 of the FTP Code). Where a floor covering is required to be low flame-spread, all layers shall comply with part 5. If the floor covering has a multilayer construction, the Administration may require the tests to be conducted for each layer or for combination of some layers of floor coverings. The IMO flammability requirements for floor covering are as follows: Floor coverings Qsb Qt (Mj/m2) (MJ) = 0.25 = 2.0

CFE (kW/m2) = 7.0

qp (kW) = 10.0

Where CFE = Critical flux at extinguishment Qsb = Heat for sustained burning Qt = Total heat release qp = Peak heat release rate Smoke generation shall be conducted in accordance with ISO 5659:1992, Part2 and additional test procedures as described in Part 2 of the FTP Code. This test is run at irradiances of 25 kW/m 2 in the presence of a pilot flame, 25 kW/m 2 in the absence of a pilot flame and 50 kW/m 2 in the absence of a pilot flame. For materials used as floor covering, the D m shall not exceed 500 in any test. In addition the gas concentration shall not exceed the following limits: CO HCl HF NOx HBr HCN SO2 1450 ppm 600 ppm 600 ppm 350 ppm 600 ppm 140 ppm 120 ppm

All testing must be done at an approved laboratory and the manufacturing must be under a follow-up inspection by an acceptable third party (such as ISO 9000 Accreditation). Implementation of the FTP Code A. Domestic Service Vessels There are three options available for designers of vessels that engage solely in domestic voyages:

1. Complete Compliance with Title 46, Code of Federal Regulations 46CFR). The vessel must be constructed in compliance with the structural fire protection arrangements and type approval requirements in the 46CFR subchapter applicable to the vessel. The interpretations and construction standards in NVIC 9-97 continue to apply. Structural fire protection materials are required to have USCG type approval to 46CFR Part 164 standards. 2. Partial Compliance with Title 46, Code of Federal Regulations 46CFR). The vessel must be constructed in compliance with the structural fire protection arrangements in the 46CFR subchapter applicable to the vessel. The interpretations and construction standards in NVIC 9-97 continue to apply. Structural fire protection materials that are USCG type approved to the FTP Code may be used in lieu of 46CFR Part 164 type approved materials, as follows: Material 46 CFR 164 Approval Equivalent FTP Approval Series Series Deck coverings 164.006 (No equivalent) Interior finishes 164.012 164.112 3. Compliance with SOLAS and the FTP Code. The vessel may be constructed in compliance with the structural fire protection arrangements in Chapter II-2 of the SOLAS Convention using materials that are USCG type approved to the FTP Code. NVIC 9-97 does not apply. The interpretations listed in MSC Circular 847 may be used. B. International (SOLAS) Service Vessels Vessels intended for international service must now use structural fire protection materials that have been tested to the criteria in the FTP Code. Annex 3 of the FTP Code permits the continued acceptance of established test procedures and acceptance criteria for an interim period, to allow manufacturers adequate time to re-qualify their material to the new fire tests. The Coast Guard has, therefor, determined that existing type approved materials that have been tested to the criteria in 46 CFR 146 and have valid approval certificates are acceptable for use in the construction of SOLAS vessels with a keel laying date prior to 31 December 2003 as listed below: Material Primary deck coverings Interior finish (floor coverings) New FTP Code Approval Series 164.106 164.112 Existing type approval until 31 December 2003 (none) 164.012

The FTP Code allows interim use of existing materials that have been approved through prior established test procedures and acceptance criteria. It is the Coast Guards decision as the Administration, that materials previously accepted by: 1. Construction specifications; or

2. Testing to building construction test standards (NFPA, ASTM, UL) not listed in 46 CFR; or 3. Testing to IMO standards in effect prior to the FTP Code; or 4. Policy letter, plan review or other acceptance where a type approval certificate was not issued do not qualify as materials approved by established test procedures and acceptance criteria, and can no longer be used on the basis of their previous acceptance.

Paul Hough May 18, 2001