What regulations affect my vessel?

The American Bureau of Shipping, (ABS) is a not-for-profit and non-governmental organization which acts as a self-regulating agency to the international marine industry. They are one of the worlds leading ship classification societies. Classification involves establishing and administering standards (rules) to determine the structural and mechanical fitness of ships and other marine structures for their intended purpose. There is no Coast Guard requirement that any vessel be classed, or classed with ABS. However, for vessels classed by ABS, the Coast Guard has a formal agreement ( see Navigation and Vessel Inspection Circular No. 8-86 ) to accept the plans review and inspection tasks performed by ABS for new construction or major modifications of U.S. flagged vessels.

The United States Coast Guard has statutory authority under the laws governing marine inspection to regulate, in order to promote the safety of life and property at sea, and to protect the marine environment. The standards to be applied by the ABS in approvals and inspection for the USCG in order of the precedence are the requirements of ( 1. ) SOLAS ( Safety of Life At Sea ) ( 2. ) United States Statutes and ( 3. ) USCG regulations.

The Code of Federal Regulations Title 46 Shipping Chapter 1, Coast Guard, Department of Transportation part 181 Fire Protection Equipment Subpart D Fixed Fire Extinguishing and Detection Systems requires fixed gas fire extinguishing systems aboard a vessel be approved by the Commandant, and meet certain basic requirements. All systems must be installed in accordance with the manufacturers approved manual for the design, operation, installation and maintenance of that system. The controls for systems must be located outside of the space protected by the system. Pull cables must be enclosed- no bare cable allowed. Any gas actuated valves ( discharge delay or stop valve ) must have a manual over-ride at such valve. Systems that use “kicker”, or pilot cylinders to activate the primary storage cylinders ( only when two or more agent cylinders ) must have at least two such pilot cylinders. The remote controls must not be located in a space that might be inaccessible in the event of a fire in the space protected by the system. Engine rooms that are over 6000 cubic feet and “normally occupied” must require two distinct operations to activate the system. Systems must have local manual release capability at the agent storage cylinders. A normally occupied or “manned” space must have the remote controls for releasing the agent at the primary exit from the space.

A “manned” space requires a discharge delay and alarm at least twenty seconds, or the time necessary to escape from the space, whichever is greater. The alarm must be powered by the extinguishing agent. If the engines or power ventilation serving the protected space draws air from within the space, a device must be provided to automatically shut down these devices before agent release.

If the engine room is under 6000 cubic feet the agent storage cylinders may be located in the protected space provided the system has automatic operation from heat actuators. If over 6000 cubic feet the agent cylinders must be located outside the protected space. A storage cylinder must be mounted so as to be accessible and capable of easy removal for recharging and inspection and provisions must be available for weighing each storage cylinder in place. Where subject to moisture, cylinders must be mounted at least two inches above the deck. Storage cylinder spaces must have doors that open outwards or be fitted with kickout panels installed in each door. As of January 1, 1994 vessels operating on an international voyage, subject to SOLAS requirements, are prohibited from installing fixed gas fire extinguishing systems containing halon. The United States banned the production of halon, and the Environmental Protection Agency placed significant restrictions on the servicing and maintenance of systems containing halon.

While vessels are not required to be “classed” by the USCG, the passenger vessel safety act of 1993 clarifies the criteria which determines when vessels are required to be certificated by the Coast Guard for passenger carriage. “The Act” also defines the terms “passenger vessel”, “small passenger vessel”, “uninspected passenger vessel”, “passenger for hire”, and “consideration”. All undocumented vessels equipped with propulsion machinery must be registered in the state of principal use. Some larger vessels may need to be documented. A document serves as a certificate of nationality and authorization for a specific trade. The Code of Federal Regulations include all of the lifesaving requirements for numerous vessel types and services. “Classification”, in this instance, refers to these various types of vessels and helps sort out all the various regulations that apply to each one. We refer to these various types of vessels as “Subchapter D”, for example, which are tank vessels. “Subchapter I” vessels, for example, are cargo ships. The “classification” begins with determining if the vessel is under or over 100 gross tons ( g.t. ). If under 100 g.t. the vessel is considered a “Subchapter C” vessel if it is a commercial (uninspected) fishing vessel.

Under 100 g.t. a vessel that is not chartered, with no passengers for hire, or chartered with no crew provided, twelve or less passengers is called a “recreational vessel”.

“Small passenger vessel” would be vessels under 100 g.t. that are chartered with no crew and thirteen or more passengers, or seven or more passengers with one for hire- chartered or not, or chartered with crew- seven or more passengers.

“Uninspected passenger vessel” These are not commercial fishing vessels, under 100 g.t. carrying six persons or less, one of whom is for hire, chartered or not or chartered with crew, six passengers or less (commonly referred as “six-pack”).

All the above types of vessels, under 100 g.t. and carrying 150 passengers or less or with overnight accommodations for 49 or less or six or more passengers including one for hire are referred to as “Subchapter T” vessels. If in addition to all the above the vessel participates in “international voyage” the vessel is considered “Subchapter K”.

Vessels over 100 g.t. that are chartered with no crew, with twelve passengers or less or not chartered with no passengers for hire are “recreational vessels” but are “Subchapter H” type, as are vessels carrying thirteen or more passengers, one for hire chartered or not, or chartered without crew- thirteen or more passengers (“passenger vessels”), or twelve or less passengers, one is for hire- chartered or not, or chartered with crew, twelve passengers or less (“uninspected passenger vessel”) or passenger carrying, over 100 g.t. on International voyage, or all other service, all “Subchapter H”.

All these types of vessels have particular requirements- go online at the Coast Guard’s web site and search for “finding regulations”. You can then link directly to the lifesaving system regulations in Title 46, CFR. These can be downloaded for free, and you only need to look up the ones that apply to your specific vessel type and it’s service.

USCG / Federal Requirements are mandatory for all U.S. flag vessels. The code specifies that all systems must be approved and the manufacturers installation manual will have the approval number included or it is not Coast Guard approved. That’s why foreign systems are not allowed, they’re not approved. The Coast Guard does participate in international treaties and organizations that recognize each others marine safety laws and regulations to deal with the international aspect of the marine business. Most of the regulations apply to maritime commerce and shipping. The sinking of the Titanic in 1912 was instrumental in producing the first International Convention for the Safety of Life at Sea (SOLAS). Eighteen nations participated in formulating the requirements for safety measures on cargo and passenger ships, and signed the final act in 1929, which is still evolving to this day. The International Maritime Organization (IMO) of the United Nations administers SOLAS and it is amended every four years. The current SOLAS convention includes ship stability, machinery, structures, as well as electrical, navigation, fire and other safety-related systems. Each participating country has some sort of national maritime safety administration that is responsible for ensuring that equipment on its ships meets the SOLAS requirements. In the U.S. it’s the USCG Commercial Vessel Safety Technical Organization. There is much being done to standardize and work towards these member countries accepting each other’s “approvals”. SOLAS is becoming an international standard. The Coast Guard issues SOLAS Safety Construction, Safety Equipment and MARIPOL Certificates for all U.S. flag vessels engaged in international service. (The Safety Construction Certificate may be issued by ABS on behalf of the Coast Guard for vessels classed by ABS upon request by the vessel owner) If your vessel carries more than twelve passengers and participates in international voyages, you must comply with SOLAS requirements. Vessel inspection regulations in Title 46, Code of Federal Regulations (CFR) generally embrace the inspection requirements of SOLAS 74/78. The U.S. chooses to inspect vessels annually to ensure that, from the aspect of safety of life, the subject vessel is fit for the service for which it is intended.

Here's a flow chart to use to check the classification of your vessel- use this as a guide to looking up the regulations that affect your vessel Here.