CG Clarifies Pre-Fire Plan Requirements
In a letter dated 3 June 2010, to MRA Director Captain Scott Powell, the U.S. Coast Guard (USCG) clarified its position on how a plan holder can comply with the pre-fire plan requirements found in 33 CFR Part 155 (Salvage and Marine Firefighting Requirements; Vessel Response Plans for Oil). The letter was in response to a request submitted by the MHR on behalf of MRA. In the response the USCG indicates that much more than just a fire control plan schematic is required if a plan holder chooses to use SOLAS as the option in meeting the pre-fire plan requirements:
“Simply put, the submission of a SOLAS fire control plan does not, in itself, satisfy the intent of 33 Code of Federal Regulations (CFR) Part 155.4035 (b) (1).
“A SOLAS fire control plan is only part of an acceptable pre-fire plan submission submitted to the Coast Guard. The supporting document discussed in SOLAS Chapter II-2, Regulation 15 must also be submitted if a vessel owner/operator chooses this pre-fire plan submission option. Supporting documents include; training manual(s), which may comprise several volumes; fire safety practices; instructions on firefighting procedures and activities; the meaning of ship's alarms; operation and use of firefighting systems and appliances; the operation and use of fire doors; the operation and use of fire and smoke dampers; and the escape system and appliances. The supporting documentation also provides the crew assignments, fire parties, onboard training and drills and additional requirements for passenger vessels.”
The USCG goes on to point out in the letter, the importance of the "marine firefighter" with specific regard to certifying a plan that can be implemented by a marine based firefighter to mitigate a potential fire:
“The purpose of the pre-fire plan acceptance by the marine firefighter is to ensure a coordinated and safe response in the event of a fire incident, not a verification of compliance with the SOLAS standards or any other standard. The marine firefighter resource provider is required to certify in writing that they find the plan acceptable and agree to implement it to mitigate a potential or actual fire.”
The USCG also indicated in the letter, that it will be up to the marine firefighting industry to set the standards regarding pre-fire plans but reserves the right to reject a plan that is not deemed as acceptable:
“When the pre-fire plan does not provide a sufficient level of confidence for the marine firefighting resource provider, it should not be accepted and the marine firefighting resource provider should request any additional information from the vessel owner/operator to make the plans acceptable. Only when the marine firefighting resource provider feels that sufficient information is obtained to make the plan acceptable, should the plan be certified as acceptable.”
The Frequently Asked Questions (FAQs) on the USCG website Homeport have been updated to reflect the guidance provided in the letter. The MRA is thankful to the USCG for the quick turnaround regarding this request. The MRA will be following up immediately with all of its clients, their plan writers and QIs regarding the next step in complying with the upcoming regulation.