Fire protection in the subchapter M regime
Every mariner fears a fire aboard the vessel. If it goes unattended it can often be fatal and has sealed the fate of many a mariner. Only recently a fire aboard a large tanker of the Sri Lankan Coast burned out of control for a number of days. On the rivers this could potentially result in an environmental disaster that will quickly affect the neighboring communities as well as the waterway itself. Subchapter M ushers in a new era of safety with requirements for fire protection for vessels that will enable timely action to a fire.
Subchapter M under 46 CFR sets out requirements for fire protection for tow boats. Specifically, within 46 CFR 142. All firefighting equipment whether fixed or portable needs to be USCG type approved is being used abord the vessel. Alternates need to be equivalent and exempt. Vessels also are required to observe basic fire hygiene in that bilges, storage areas and void spaces are kept free of combustible and flammable materials. Combustible and flammable materials, such as paints and chemicals, should be stored in a designated locker when not in use and a fire extinguisher kept close by and available for use when needed.
Where fixed fire fighting systems may not be available, Subchapter M 46 CFR 142.226 requires that vessels greater that 79 feet in length, engaged on ocean or coastwise routes, to have available two firefighting outfits and two self-contained breathing apparatus that have at least 30 minutes supply of air. Personnel will need to be trained in all the fire fighting equipment on aboard as also those who will don the firefighting outfits and self-contained breathing apparatus are well versed in their use and limitations. Vessels should plan for an alternate for the designated personnel should there be an incident that prevents those designated from donning the outfits.
A fire axe should be accessible from the outside of the vessel superstructure. Subchapter M also lists the number of extinguishers that each vessel should carry as also the type of extinguisher. This varies by length of vessel for those under 65 feet and by tonnage for those over 65 feet. There are alternate arrangements in place for those vessels that have existing extinguishers should they be maintained in good condition. Subchapter M requires inspection and testing to be conducted at regular intervals and these vary with some checks being monthly and others annually. 46 CFR 142.240 gives further guidance on the specific requirements.
Finally, there is a requirement for drills to be conducted at least once a month. These must be conducted as if there were an actual emergency. While the equipment and training are meant to deal with contingency scenarios there is no substitute for good seamanship.
