INTERNATIONAL MARITIME ORGANIZATION

E
IMO

SUB-COMMITTEE ON FIRE PROTECTION FP 44/15

FIXED FIRE PROTECTION AND FIRE ALARM SYSTEMS

Comments on document MSC 71/20/5

Submitted by the International Council of Cruise Lines

SUMMARY
Executive summary: This paper comments on the proposal by the United States that smoke
detectors in cabins of passenger ships should be modified or replaced
to provide additional audible alarm and that fire screen doors should
close automatically upon activation of near-by smoke detectors.
MSC 71 directed that this agenda item be added to the agenda of
FP 44 for further discussion
Action to be taken: Paragraph 10
Related documents: MSC 71/20/5, MSC 71/20/15, FP 43/18, FP43/5, FP 43/5/2 and
MSC/Circ.816

1 This paper provides comments on document MSC 71/20/5 (United States) and additional
information related to the issue of locally sounding smoke alarms. It is submitted in accordance
with the provisions of paragraph 45.4 of the Guidelines on the organization and method of work
of the Maritime Safety Committee and the Marine Environmental Protection Committee and their
subsidiary bodies (MSC/Circ.816).

2 ICCL notes the proposal by the United States that smoke detectors in cabins of passenger
ships should be modified or replaced to provide additional audible alarms and that fire screen
doors should close automatically upon activation of near-by smoke detectors. ICCL also notes
and concurs with the general comments submitted by the International Chamber of Shipping, as
contained in document FP 43/5/2.

3 In reviewing the submission by the United States, we note that the recommendations are
made based upon fires onboard three ships that were not in compliance with the 1992 Fire Safety
Amendments to the 1974 Safety of Life at Sea Convention. Two of the instances referenced did
in fact serve as a basis for the 1992 amendments. Preliminary investigations regarding a more
recent fire onboard a vessel that does comply with the applicable 1992 amendments, indicate that
the fire safety system requirements of SOLAS worked properly and as expected. The crew was
also trained in accordance with STCW requirements and responded properly and professionally.

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4 STCW procedures for crowd management and good crisis management, in general, are
based on the fact that a vessel’s master and emergency response team are knowledgeable of the
situation and in control from the outset. An audible alarm in passenger areas, as yet unknown to
the bridge or the crew, could stimulate an undesired response by passengers that would make
situation control difficult at best. In the worse case scenario, it could result in improper and
uncontrolled response by the passengers that could be the cause of panic, injury or death. This is
particularly true if one considers that on a daily basis there are as many as 20 or more false
alarms as a result of the normal sensitivity of smoke detectors and their tendency to activate in
the presence of steam, aerosol sprays, and cigarette and cigar smoke. Also, the proposal does
not seem to be consistent with the philosophy throughout SOLAS that the crew, in order to
maintain control of the vessel and passengers in the event of an emergency, should operate
alarms and controls.

5 ICCL would like to inform the Sub-Committee that the current practice on board an ICCL
member operator’s vessel when a smoke detector enunciates on the bridge is to:

.1 immediately telephone the cabin or crew space in which the detector is located;

.2 immediately dispatch a crew member assigned to the cabin block or other alarm
location to physically enter the cabin or other space to ascertain its condition and
report back; and

.3 mount a full response in the event the telephone call or crew member confirms the
presence of a fire, when two or more detectors activate, or when the crew member
sent to investigate fails to respond within the specified amount of time.

6 The United States’ submission states that “National standards in the United States
currently include provisions for the local alarm feature and other functions such as the closing of
fire doors either by the activated detector or via a signal from the fire alarm control panel.”
While it is implied that this is a requirement for United States’ flag vessels, we have been
informed that these standards are related to the hotel and not the maritime industry. Because of
differing staffing levels and training levels, as well as other differences, it does not seem
appropriate to directly apply hotel standards to passenger ships.

7 Manufacturers of marine fire detection systems have indicated that in many instances, the
entire smoke detector head may need to be replaced contrary to the simple addition of a sound
emitting device to the existing head. In these instances the cost of the alteration could be up to
(U.S.) $250 per head or more than twice the average cost indicated in the MSC 71/20/5. The
costs of installation and software changes are additional.

8 There are several other details that must be considered in discussing this proposal. These
would include, but are not be limited to:

.1 the sound level of the alarm vis-a-vis the general alarm and public address system;

.2 the alarm’s interaction or connectivity to the public announcement system and the
ships general alarm;

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.3 the ability to silence and/or reset the alarm remotely; and

.4 general limitations of the smoke detection system.

9 ICCL continues to be concerned with the possibility of persons being injured as a result
of a sudden, unannounced and inadvertent closure of a heavy fire door. We are aware of at least
one past instance in which several passengers were injured when, due to an electrical fault, power
to the electromagnetic holdbacks was lost and fire doors closed without warning. Given this risk,
it is difficult to see significantly better protection in having fire doors closed “via a signal from
the fire alarm control panel” versus the current SOLAS regulation that calls for these doors to be
capable of being closed from a continuously manned location upon receipt of an alarm. We also
note that when a fire door or a series of fire doors is closed from the bridge control location, the
ventilation system may also be controlled. If a fire door were to closed as a result of a local
detector input, the action may interfere with the performance of local ventilation control systems.

Action requested of the Sub-Committee

10 The Sub-Committee is invited to consider the above comments and take action as
appropriate.

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