24
Commentary Paper on Fireman
Outfits On Board Tankers
V1 April 2024
Commentary Paper on Fireman
Outfits On Board Tankers
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© INTERTANKO 2024
While every effort has been made to ensure that the information contained in this publication is correct,
neither the authors nor INTERTANKO can accept any responsibility for any errors or omissions or any
consequences resulting therefrom.
No reliance should be placed on the information or advice contained in this publication
without independent verification.
Rev 1 – April 2024
1. INTRODUCTION
INTERTANKO Members have been sharing their experiences of the various deficiencies that have been issued
by Port State Control Authorities on firefighting outfits.
Examples of the deficiencies recorded include the following:
- “Firefighting outfits on board are of the fire proximity suit type and may not provide the wearer with
sufficient thermal protection from radiated heat if entering an enclosed space, including machinery
and accommodation spaces, where a fire is established. Close proximity clothing may be freely used for
protection when boundary cooling a fire or for search and rescue in an enclosed space without a fire.
Use of appropriate fireman suits is to be included in the safety manual.”
- “Firemen outfits (FO) do not comply to the minimum requirements. The FSS requires that an outer
surface shall be water resistant. Firemen outfits marked Y1 do not require testing for water resistance.
The only FO that offers proof it is water resistant is when it is a level 2, because the outer layer and
seams have been tested at least on 20Kpa for water resistance.”
- “Firemen Outfit not complying to minimum requirements. Firemen Outfit is marked as Y1 for water
penetration which means ‘as per manufacturers’ instructions should not be used where there is a risk of
water penetration’. SOLAS-FSS requires that “an outer surface shall be water-resistant’.”
- “For fire drills in accommodation areas, service spaces and engine room, the wrong safety equipment
is being used. Firemen outfits with Level 1 have limitations as to their use and are not suitable for risk
encountering in fighting fire and rescue from a fire ‘in structure’. Master instructed to use correct
equipment.”
- “Limitation and restriction for use of firemen outfits marked Y1 for water penetration are not included
in the fire training manual. Drills are done with inadequate equipment in the wrong places.”
Following INTERTANKO analysis and a careful review of SOLAS and EU MED requirements on the recorded
findings the following points are noted:
A. SOLAS
The International Maritime Organization (IMO) lays out the regulatory framework for maritime safety
conventions. Firefighters’ outfits should comply with SOLAS Regulation II-2/10 and FSS Code Chapter 3, which
require that “protective clothing shall be of material to protect the skin from the heat radiating from the fire
and from burns and scalding by steam. The outer surface shall be water-resistant”.
SOLAS and the FSS Code are not specific on testing standards.
Many conventions require flag States to ensure that the equipment complies with certain safety requirements
with regards to design, construction and performance standards of such marine equipment.
Manufacturers, with the aim to demonstrate compliance of their products with SOLAS & FSS Code requirements,
accompany their products with a type-approval certificate issued by an accredited organisation which verifies
compliance of the product with the applicable SOLAS and FSS Code requirements.
B. EU Marine Equipment Directive
The EU provides Directive 2014/90/EU on marine equipment with the objective of enhancing safety at sea and
to prevent marine pollution through the uniform application of the relevant international instruments relating
to marine equipment to be placed on board EU-registered ships.
INTERTANKO Commentary Paper on Fireman Outfits On Board Tankers (April 2024)
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The directive also requires such approved equipment to be marked with a ‘wheel mark’.
Commission Implementing Regulation (EU) 2023/1667 lays down the rules for the application of Directive
2014/90/EU. As per this implementing regulation, the fireman outfits provided onboard EU-flagged ships
should be compliant with EN469:2020 standards.
The EN469:2020 requirements provide the necessary safeguards to seafarers when firefighting.
Understanding of ‘Performance Level’ and ‘Performance Attributes’ as per EN496:2020
Performance Description
Performance Levels: EN469:2020 provides distinction between firefighting activities as follows:
- Level 1: is the lower requirement and specifies the minimum
requirements for clothing required for outdoor firefighting and their
support activities.
- Level 2: is the higher requirement and specifies the minimum
requirements for clothing required for firefighting and rescue during
structural firefighting operations.
Performance Attributes: Further, the fireman suits are graded as per their ‘performance attributes’ as
follows:
• X (flame- and heat-resistant). As per the previous version EN469:2005 X
was further divided to Xr (Radiation) and Xf (Flame)
• Y (Protection against water penetration)
• Z (Water vapour resistance)
NOTE: The distinction between Level 1 and Level 2 clothing is restricted to the requirements for heat and flame
(X1 or X2- Heat and Flame).
For all other attributes (Y and Z) the requirements for Level 1 and Level 2 are considered the same.
INTERTANKO Commentary Paper on Fireman Outfits On Board Tankers (April 2024)
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See below extract from EN 469:2020. Therefore, as long as the suit is X2 rated it is suitable for use onboard
ships.
C. Commentary
The most suitable way to demonstrate compliance appears to be via the type-approval certificate in which
the compliance of the suit with SOLAS & FSS Code requirements or with the EU MED provisions is stated,
depending on the Flag of the vessel that the equipment is intended to be placed on.
Members should get clarification from their Flag State authority when in doubt.
A type-approval certificate is “prima facie” evidence of compliance with the standards and regulations referred
to in the certificate requirements.
It may be noted that EU MED type-approved products exceed the minimum SOLAS requirements and are
generally accepted by non-EU Flag Administrations.
Earlier PSC Inspectors issued deficiencies on the basis that the firemens’ outfits were not X2 rated and hence
could not be used for firefighting in ships’ structures such as accomodation, enclosed spaces, engine rooms
etc.
Inspectors are also issuing deficiencies when firemen outfits are not Y2 graded – not complying with the FSS
2.1.1.1 requirement that the outer surface shall be water resistant. The rationale provided in the PSC reports
is that the firemen suits marked as Y1 are not tested for water resistance. The only proof that the suit is water
resistant is when it is Level 2, because the outer layer and seams have been tested at least on 20KPA for water
resistance.
There is, however, room for misunderstanding due to the following reasons:
• As per 469:2020/ 6.1, the distinction between Level 1 and Level 2 clothing is restricted only to the
requirements for heat and flame (X1 or X2 – Heat and Flame). For all other attributes (Y and Z) the
requirements for Level 1 and Level 2 are considered the same.Therefore the requirements are to comply
with X2 suits and not Y2 or Z2.
• As per 469:2020/ 6.2.4, Level 1 and Level 2 (i.e. Y1 and Y2) do not define the water resistance of the
outer material. The pressures stated in 6.2.4 are the required test pressure to test the water resistance
of the suits with and without moisture barriers. It does not mean that a suit needs to be tested above
20kpa for it to be water resistant. All suits are to be water resistant. See the extract from 469:2020:
opposite.
INTERTANKO Commentary Paper on Fireman Outfits On Board Tankers (April 2024)
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The EU MED directives require that firefighters’ outfits for protective clothing (close proximity clothing) are to
be tested to applicable standards. The intention of wearing firefighters’ outfits is to enable extinguishing a fire
from a close position and not to passing through an active fire.
This is the reason why some manufacturers are placing a tag on the suits indicating that the firefighters’ suits
are “not suitable for fire entry”, a statement which is frequently misinterpreted in a way to consider that the
fire suits are not suitable for firefighting in enclosed areas.
The specific protection each type of outfit offers can be determined only by reviewing the contents of the
applicable ISO or EN standards according to which they have been tested.
The best possible protection a firefighters’ outfit can offer according to the description of the testing standards
is against “flame lick” and “intense radiant heat”.
The outfit shall be worn for short periods only to enable the firefighter to enter specific high-risk firefighting
and fire rescue situations, which also require the use of breathing apparatus (EN 1486:2007).
To that end, and with the aim misinterpretations for the use of outfit to be avoided, some manufacturers have
included in the tag of the outfit the “WARNING: THIS IS NOT FIRE ENTRY CLOTHING” advising that the outfit
shall not be used to enter or pass through the flames of an active fire but only to come in close proximity as
mentioned in the testing standards. The warning by itself does not mean that the available suits would not
provide the wearer sufficient thermal protection from radiated heat if entering an enclosed space where a fire
is established.
To determine if the suits are suitable for their intended purpose the testing standard used for their type
approval shall be reviewed.
Firefighting teams on board should be aware of the outfit limitations during onboard familiarisation.
These limitations should also be included in the ship-specific training manual and the record of
firefighting drills should not conflict with the limitations.
INTERTANKO Commentary Paper on Fireman Outfits On Board Tankers (April 2024)
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