Structural Fire Protection

GENERAL APPROVAL REQUIREMENTS

Most structural fire protection (SFP) materials may be submitted for approval under various approval series codified in Title 46 Code of Federal Regulations (CFR) Subchapter Q, Part 164 "Materials". All current Federal Regulations may be found at https://www.ecfr.gov. Additionally, SFP materials classified as H-class are approved under 4 additional approval series. See below list of "SFP APPROVAL SERIES".

All of the SFP approval series below are approved principally to IMO standards, however, they may be used on U.S. flag vessels subject to SOLAS (international routes) or domestic routes.

The SFP approval series in Subchapter Q incorporate by reference the 2010 Fire Test Procedures Code (2010 FTP Code). In addition to the fire tests, the FTP Code contains pass/fail criteria as well as additional requirements. The FTP Code includes requirements for follow-up inspections at the manufacturer's plant by an acceptable third party. For the Coast Guard, these third parties are independent laboratories.

SFP APPROVALS COVERED BY A MUTUAL RECOGNITION AGREEMENT

Several SFP approval series are eligible for reciprocal approval covered by a mutual recognition agreement. See NVIC 02-19 ch1. Eligibility is also discussed below for each SFP approval series.

TESTING AND APPROVAL PROCESS

For those manufacturers seeking approval through the Coast Guard, we do not test materials or systems for approval but rather specify the required test methods and minimum performance criteria for approval which must be performed by an independent testing laboratory. Product testing must be performed by a Coast Guard Accepted or Recognized Independent Laboratory. Some products may require an active third-party quality control (follow-up) program before approval is issued. NVIC 02-06 provides information on acceptable practices for a follow-up program between the manufacturer and an overseeing third party.

Additional information on the Coast Guard’s approach to structural fire protection can be found in Navigation and Vessel Inspection Circular NVIC 9-97 (replaces NVIC 6-80). This document, while not regulations, is intended to explain the regulations and provide guidance as well as examples of accepted constructions.  

SUBMITTING AN APPROVAL REQUEST TO US

Please send the Submittal Package and other related information to TypeApproval@uscg.mil.   For details, please see What to submit when corresponding with ENG-4 regarding equipment approvals/renewal. Submission of emails with file attachments above 10MB will not be received. For files over 10 MB, please contact us at typeapproval@uscg.mil. We will send you a request to drop-off files at DoD SAFE (Secure Access File Exchange).

SUBMITTAL PACKAGE: Please submit the follow information in the Submittal Package:

A cover letter requesting Coast Guard Type Approval of the equipment.
A test report from the Accepted Independent Laboratory showing compliance with the above standard.
Evidence that an acceptable follow-up factory inspection program with the Accepted Independent Laboratory is in place
Required plans and a copy of the installation instructions.

CERTIFICATE OF APPROVAL (COA)

If the material meets the appropriate test criteria and follow-up services to the satisfaction of the Coast Guard, the manufacturer will be issued a Certificate of Approval (COA) for the product. The COA will be issued for up to 5 years and will remain valid during that time period if the product meets the testing of the Quality Control Program. The approval will also be listed on the Coast Guard’s Approved Equipment website: http://cgmix.uscg.mil/Equipment/. Approvals found in CGMIX may be used to select materials for ship construction.

164.105 DECK ASSEMBLIES (A-60) (SOLAS)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.105. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

SOLAS requires typical bulkhead and deck prototypes to be tested in accordance with the 2010 FTP Code to ensure that their construction meets the requirements for A-Class divisions, as defined in SOLAS II-2/3. All A-Class divisions must meet the A-60 test standard. The FTP Code requires that all structural insulation materials must be initially tested for non-combustibility under Annex 1, Part 1 and then tested for fire resistance under Annex 1, Part 3. This approval category is intended to cover insulation systems that are installed above the steel deck plating. This method of insulation is usually intended to provide a greater deal of noise and vibration reduction for the passengers and crew. Deck construction where the insulation is installed on the bottom side of the deck is discussed in approval category 164.107.

The Coast Guard does not test materials or systems for approval but rather specifies the required test methods and minimum performance criteria for approval. The testing must be performed on the product by a Coast Guard Accepted Independent Laboratory.

164.107 STRUCTURAL INSULATION (A-60) (SOLAS)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.107. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

SOLAS requires typical bulkhead and deck prototypes to be tested in accordance with the 2010 FTP Code to ensure that their construction meets the requirements for A-Class divisions. The FTP Code requires that all structural insulation materials be tested for noncombustibility under Annex 1, Part 1 and then tested for fire resistance under Annex 1, Part 3. The FTP Code requires structural insulations to be tested in the orientation in which the material will be installed. Because of this, if a manufacturer intends to have a product approved for both bulkhead and deck insultion, two tests are required, one in a vertical orientation, and one in a horizontal orientation.

In the vertical test, the insulation is mounted on a stiffened 4-mm thick steel core plate that is positioned in the furnace with the insulation and stiffeners on the outside or unexposed side. For the horizontal test, the deck test specimen must have the insulation and stiffeners installed below the steel deck plating and exposed to the furnace. The top surface of the steel deck plating is normally left bare during the test.

If the test is to qualify aluminum construction, the test specimen should include the primary deck coverings and floor finishes that the manufacturer specifies, as they will affect the rate of heat loss on the unexposed side of the assembly and would likely cause premature structural failure of the aluminum core. The FTP Code requires that the structural insulation must maintain the aluminum core plate temperature below 200ºC above ambient temperature during the test to pass with the installed primary deck covering and floor finish. Alternatively, aluminum decks may be tested with a bare top side surface if the underside insulation is capable of limiting the core temperature to 150ºC, approval will be granted for the use of any deck coverings.

Insulation materials must be tested at a density that is representative of the manufactured product based on testing the insulation at the manufacturer’s stated nominal density. The production density must be within ± 10 % of the nominal density if the material is produced at densities outside of this range, then two tests should be conducted at the minimum and maximum nominal density, and all densities within that range can be approved. Normally, all structural insulations are tested in the thickness necessary to achieve an A-60 approval.  If a manufacturer requests a separate approval for an A-30 or A-15 rating, additional testing must be performed to determine the required thickness of insulation.

The figures in NVIC 9-97 showing A-60, A-30, and A-15 deck and bulkhead constructions using combinations of materials do not apply to materials tested to the FTP Code.

164.108 BULKHEAD PANELS (B-0 AND B-15) (SOLAS)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.108. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

SOLAS requires prototypes of typical bulkhead panel systems to be tested in accordance with the FTP Code to ensure that their construction meets the requirements for B-Class divisions. The FTP Code requires all bulkhead panel materials to be tested for noncombustibility under Annex 1, Part 1 except that adhesives used in the panel construction may have low flame spread characteristics when tested to Part 5 of the FTP Code rather than meeting non-combustibility criteria. The panels are then tested for fire resistance under Annex 1, Part 3.

Non symmetrical panel systems must be installed in the test furnace with the side giving the inferior performance exposed to the fire.  If a determination of which side of the panel this is cannot be easily made from a review of the manufacturer's drawings, the panels must be tested in each orientation. If the panel system includes internal passages for electric cables or light switches, samples of such panels must be included in the test assembly. Testing is conducted on panels without decorative surface finishes or paints.  Decorative surface finishes are approved separately under Parts 2 and 5 of Annex 1 of the FTP Code.

For bulkhead panels to be approved as as B-0 or B-15 divisions, they must be tested for 30 minutes to determine their B class structural integrity. Temperature measurements must be made for at least 15 minutes in order to receive a B-15 rating. The FTP Code acceptance criteria references B-30 approvals, however, there are no requirements in SOLAS for such a bulkhead qualification, and thus the Coast Guard does not recognize such a designation. Panels that pass the test for 30 minutes are approved as either B-0 or B-15 rated materials.

To be used as a component in A-class construction (membrane construction), the test must be run for a 60-minute period with a steel core plate as part of the test assembly. To receive an unrestricted approval for membrane construction, two separate tests must be conducted; one test with the bulkhead panel facing the fire and one test with the steel core facing the fire. The tested distance between the steel core and the panels is the minimum permitted in actual installations.

Manufacturers of approved bulkhead panels are required to submit drawings with typical joiner details as a required part of the approval. The panels must be installed in accordance with the manufacturer's typical installation drawings.

164.109 NONCOMBUSTIBLE MATERIALS (SOLAS)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.109. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

The use of noncombustible materials is a basic functional prerequisite for may SOLAS material approvals. Materials approved under this category are solid inorganic materials containing only small amounts of organic binder. These materials maybe used anywhere in vessel construction without limitation.

SOLAS requires noncombustible materials to be tested in accordance with the 2010 FTP Code to ensure that they do not burn or give off flammable vapors in sufficient quantity for self-ignition when heated to approximately 750ºC. The IMO FTP Code requires noncombustible materials to be tested in accordance with ISO 1182-1990 using the acceptance criteria listed in Annex 1, Part 1 of the FTP Code. The test samples must be selected at different locations in a production run to ensure that they are representative of the typical product.

Some specific materials such as steel or glass is known to be inherently noncombustible based on their composition, and may be used in merchant vessel construction wherever noncombustible materials are required. These materials do not need to be tested and do not receive certificates of approval. A list of these materials is contained in Annex 2 of the FTP Code. For a product to be accepted as a noncombustible material without testing, the manufacturer must certify that the product consists of only the materials listed in Annex 2. All other materials must be tested.

Cold Service Piping, Acoustic and Thermal Insulation: While SOLAS contains no explicit performance requirements for acoustic and thermal insulation, all insulation materials must be non-combustible as detailed in SOLAS regulation II-2/5.3 and therefore meet the requirements of 46 CFR Subpart 164.109. However, combustible insulation is permitted in limited applications for cold service piping if it is tested for surface flammability. All other insulation must be non-combustible.

164.136 FIRE DOORS (SOLAS)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.136. This item is eligible for approval under a Mutual Recognition Agreement with windows not exceeding 645 cm² in area. See NVIC 02-19 ch1.

SOLAS requires fire doors in A-Class and B-Class bulkheads to provide equivalent fire resistance to that of the bulkhead in which the doors are installed. The FTP Code requires that all materials used in the construction of fire doors must be tested for noncombustibility under Annex 1, Part1 and then tested for fire resistance under Annex 1, Part 3. Adhesives used in the construction of fire doors do not need to be noncombustible, but they must be tested for low flame spread characteristics under Annex 1, Part 5 and should be included in the approved door’s follow-up program.

The maximum size door for which approval is requested must be tested. If the required door size is larger than the test furnace can accommodate, test the largest size possible. The fire door frame may be either bolted or welded in the test bulkhead. Doors that are tested with a bolted frame will be approved for shipboard installation using either method. Doors that are welded to the test bulkhead must be welded on the ship.

Doors must be mounted in the test bulkhead with the side expected to give inferior performance exposed to the fire. Swinging doors must be oriented in the test bulkhead to swing away from the furnace. When it may not be possible to judge which side should be tested such as for sliding doors, both sides of the bulkhead must be tested. Prior to running the test, the U.S. Coast Guard should be contacted to determine the recommended arrangements.

Doors may be tested with an integral window. Hose stream, thermal radiation and temperature rise testing requirements for the glazing are applicable as follows:

Window Dimension	Door Fire Rating	Hose Stream Test Required?	Heat Flux Test Required?	Temperature Rise Test Required?
≤ 645 cm²	A-Class	None	None	None
≥ 645 cm²	A-Class	Yes	Yes	Yes
≥ 645 cm²	A-0	Yes	None	None
≤ 645 cm²	B-15	None	None	None
≥ 645 cm²	B-15	None	Yes	Yes
Any dimension	B-0	None	None	None

Doors should be tested with typical hinges, latches, hose ports, electric strikes, viewers and other hardware that the manufacturer intends to use for shipboard applications. The acceptance criteria for door hardware requires only that the door remain closed for the duration of the fire test and that openings in excess of that permitted by the Code are not allowed to develop. None of the door hardware is required to be functional after the fire test.

The Coast Guard does not test materials or systems for approval but rather specifies the required test methods and minimum performance criteria for approval. The testing must be performed on the product by a Coast Guard Accepted Independent Laboratory.

164.137 WINDOWS (A Class)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.137. These products are NOT eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

SOLAS requires windows in A-Class and B-Class bulkheads and doors to preserve the integrity requirements of the bulkhead or doors in which they are fitted. The FTP Code requires windows to be tested for fire resistance under Annex 1, Part 3. Windows must also meet the thermal radiation test supplement to fire resistance, as outlined in Appendix 1 of Part 3 of the FTP Code, and the hose stream test of paragraph 5 of Appendix A.1 of Res. A.754(18). These tests are not separate tests but are conducted during the normal fire resistance test. These tests are labeled "optional" in the 2010 FTP Code, but are required to obtain Coast Guard type approval. Windows less than 100 in² do not require hose stream or thermal radiation tests.

Window fire tests are required to be conducted with the window installed in a test bulkhead with the stiffeners and bulkhead insulation exposed to the furnace. This configuration is intended to represent exposure of the window to an interior fire scenario, as would be expected on a passenger ship. For windows intended for other applications, it may be necessary to test the sample with the insulation and stiffeners on the unexposed side of the assembly. This situation may exist for windows installed on tankers where the fire exposure may to come from an exterior fire source. Approvals are limited to the largest size windows tested. Unsymmetrical window units that include multiple types of glazing, air gaps and insulating materials must be tested in the orientation that they are intended to be installed. In most cases this will require the window to be mounted in the test bulkhead with the exterior glass layer positioned away from the furnace.

The Coast Guard does not test materials or systems for approval but rather specifies the required test methods and minimum performance criteria for approval. The testing must be performed on the product by a Coast Guard Accepted Independent Laboratory.

164.138 PENETRATION SEALS A-CLASS

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.138. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

SOLAS requires penetrations of A-Class divisions for piping, electrical cables and other shipboard systems to be tested to ensure that they do not compromise the fire integrity of the penetrated barrier. Fire rated penetrations must be tested in both bulkhead and deck configurations and pass testing for both.  Such devices must be tested for their fire resistance in accordance with Annex 1, Part 3 of the FTP Code and Appendices A.III and A.IV of Resolution. A.754(18). Penetration seals are not required to be constructed of noncombustible materials and they do not have to meet surface flammability or smoke and toxicity criteria. The Code allows this because penetration seals must have a degree of flexibility to seal around the penetrating items and remain in place when subjected to expected shipboard motions.

Fire rated penetration seals that must also be watertight are tested separately for their watertight properties. The seals do not need to be tested for water tightness after they have undergone fire testing. The watertight test specimen should be the size specified in the watertight testing procedures and does not need to be the same size as that fire tested. If a penetration seal has been successfully tested for water tightness, the manufacturer may request the type approval certificate to include information to that effect.

164.140 PENETRATION SEALS H-CLASS

APPROVAL GUIDANCE & INFORMATION: These materials are NOT eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

H-class divisions are defined in the FTP Code, as amended by IMO resolution MSC.435((98) stemming from the DEEPWATER HORIZON accident. They are intended to separate accommodation areas, control stations, or vital equipment from the drill floor and other hazardous locations on offshore facilities. H-class division are constructed of steel or other equivalent materials and are capable of preventing the passage of flame. They are designated as H-120, H-60 or H-0 depending on the time the assembly is capable of preventing the maximum temperature rise.

H-class penetrations are evaluated using the test procedures and acceptance criteria in the FTP Code, Annex 1, Part 3, with the exception of the furnace time-temperature curve. The standard furnace heating curve is replaced with Method C of ASTM Standard E 1529, “Standard Test Methods for Determining Effects of Large Hydrocarbon Pool Fires on Structural Members and Assemblies”, which is intended to simulate the higher heat flux from a burning flammable liquid.

H-class penetrations may be tested with one or both sides exposed to the furnace separately. If the penetration is tested with each side of the assembly exposed to the furnace separately, the approval will be unrestricted, and may be installed in the penetrated division with either side exposed to the hazard, with both sides rated. The unexposed side must be installed facing space with no fire risk, such as a void or open weather deck.

If a seal assembly is intended to be used in both bulkhead and deck applications, it must undergo two separate approval tests, one in the vertical orientation and one in the horizontal orientation.

164.146 FIRE DOOR CONTROL SYSTEMS (SOLAS)

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.146. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

SOLAS Regulation II-2/9.4 requires power operated fire doors in main vertical zone bulkheads, galley boundaries and stairway enclosures to be able to operate in case of fire. Testing of the door control system must be performed in accordance with Annex 1, Part 4 of the FTP Code to demonstrate that the door is operable for at least one hour at temperatures up to 200ºC, and at higher temperatures, the control system must disengage to keep the door in the closed position. The test is conducted by mounting a scale model power operated door in a standard test bulkhead. The furnace temperature is controlled at 200ºC for 60 minutes during which time the door is opened and closed every 5 minutes to demonstrate the control function. After 60 minutes, the furnace temperature is increased to the standard IMO time temperature curve. The model door must remain closed until a temperature of at least 945ºC is reached.

164.207 FIRE-RESISTING DIVISIONS FOR HIGH SPEED CRAFT

APPROVAL GUIDANCE & INFORMATION: See 46 CFR Subpart 164.207. This item is eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

The High Speed Craft (HSC) Code requires bulkheads, decks, ceilings, linings and doors to have fire resisting properties. Fire-resisting divisions must comply with the FTP Code Annex I, Part 11, which requires fire resisting divisions to be tested and evaluated in accordance with the fire test procedures specified in IMO Resolution MSC.45(65). This is similar to the test in the FTP Code, Part 3.

The following are additional requirements for materials approved for use in fire-resisting divisions:

Materials must be non-combustible or fire-restricting as verified in accordance with Part 1 or Part 10 of Annex 1 of the FTP Code.
FTP Code Annex I, Part 3 is applicable to certain constructions such as windows, fire dampers, pipe penetrations and cable transits.
FTP Code Annex, I Part 4 is applicable where a control system of fire doors is required to be able to operate in case of fire.
Combustible veneers are allowed on fire-resisting divisions in conjunction with non-combustible substrates, the low flame spread characteristics of such veneers will be verified in accordance with FTP Code Annex I, Part 5.

164.236 DOORS H-CLASS

APPROVAL GUIDANCE & INFORMATION: These items are NOT eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

H-class doors are designed to provide equivalent fire resistance to the two-hour rated bulkheads in which the doors are installed. In addition, they are classified as H-120, H-60 or H-0 depending on the time they are capable of preventing the maximum temperature rise on the unexposed face from exceeding 180°C. H-class doors are installed in H-class divisions on offshore facilities to separate accommodation areas, control stations, or vital equipment from the drill floor and other hazardous locations.

The requirements for this approval remain the same as for A class doors except that the standard furnace heating curve is replaced with the hydrocarbon curve in the laboratory test furnace. This is intended to simulate the higher heat flux from a burning flammable liquids fire. See Method C of ASTM Standard E 1529, “Standard Test Methods for Determining Effects of Large Hydrocarbon Pool Fires on Structural Members and Assemblies”.

164.237 WINDOWS H-CLASS

APPROVAL GUIDANCE & INFORMATION: These items are NOT eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

H-Class windows are intended to provide equivalent fire resistance to the two hour rated bulkheads in which they are installed. In addition, they are classified as H-120, H-60 or H-0 depending on the time they are capable of preventing the maximum temperature rise on the unexposed face from exceeding 180°C. H-class windows are installed in H-class divisions on offshore facilities to separate accommodation areas, control stations, or vital equipment from the drill floor and other hazardous locations.

The requirements for this approval remain the same as for A- class windows, except that the standard furnace heating curve is replaced with the hydrocarbon curve in the laboratory test furnace, which is intended to simulate the higher heat flux from a burning flammable liquids fire. See Method C of ASTM Standard E 1529, “Standard Test Methods for Determining Effects of Large Hydrocarbon Pool Fires on Structural Members and Assemblies”.

All materials used in the construction of H-class windows must be tested for noncombustibility under Annex 1, Part1of the FTP Code, and then tested for fire resistance under Annex 1, Part 3. For practical reasons, small amounts of intumescent or other combustible sealants/gaskets are permitted without testing, at the discretion of the laboratory. Windows exceeding 645 cm2 (100 in2) in area must also meet the thermal radiation test supplement outlined in Appendix 3 of Part 3 of the FTP Code using the performance criterion for A-60 bulkheads, and the hose stream test of paragraph 5 of Appendix 2 section A.1. Both tests are conducted during and immediately after the normal fire resistance test.

The tests for fire resistance follow the procedures in Annex 1, Part 3 of the FTP Code with the exception of the furnace time-temperature curve. The standard furnace heating curve is replaced with the hydrocarbon curve in the laboratory test furnace, which is intended to simulate the higher heat flux from a burning flammable liquids fire. (Method C of ASTM Standard E 1529, “Standard Test Methods for Determining Effects of Large Hydrocarbon Pool Fires on Structural Members and Assemblies”)

H-Class window fire tests are conducted with the window installed in a test bulkhead with the stiffeners and bulkhead insulation on the side of the bulkhead away from the furnace. This configuration is intended to represent exposure of the window to an exterior fire source. Approvals are limited to the largest size windows tested. Unsymmetrical window units that include multiple types of glazing, air gaps and insulating materials must be tested in the orientation that they are intended to be installed. In most cases this will require the window to be mounted in the test bulkhead with the exterior glass layer exposed to the furnace.

164.307 STRUCTURAL INSULATION H-CLASS

APPROVAL GUIDANCE & INFORMATION: These items are NOT eligible for approval under a Mutual Recognition Agreement. See NVIC 02-19 ch1.

H-class divisions are constructed of steel and are capable of preventing the passage of flame and smoke for two hours. In addition, they are classified as H-120, H-60 or H-0 depending on the time the assembly is capable of preventing the maximum temperature rise on the unexposed face from exceeding 180°C. H-class divisions may be required on offshore facilities to separate accommodation areas, control stations, or vital equipment from the drill floor and other hazardous locations.

The requirements for this approval remain the same as for A class structural insulation, except that the standard furnace heating curve is replaced with the hydrocarbon curve in the laboratory test furnace, which is intended to simulate the higher heat flux from a burning flammable liquids fire. See Method C of ASTM Standard E 1529, “Standard Test Methods for Determining Effects of Large Hydrocarbon Pool Fires on Structural Members and Assemblies”.

If the insulation is intended to be used in both bulkhead and deck applications, it must undergo two separate approval tests, one in the vertical orientation and one in the horizontal orientation.

MATERIALS AND ARRANGEMENTS NOT SPECIFICALLY ADDRESSED BY SOLAS OR CFR

There are common materials and arrangements that are not specifically identified in SOLAS, the FTP Code, or 46 CFR Part 164, but must meet safety standards to be installed on board a Coast Guard inspected vessel.

ACOUSTIC AND THERMAL INSULATION: See approval series 164.109 "Non-combustible materials". 46 CFR part 164 contains no specific performance requirements for acoustic and thermal (i.e. comfort) insulation. However, all acoustic and thermal insulation materials must meet the applicable fire safety requirements, such as non combustibility.

ALUMINUM CONSTRUCTION: Aluminum bulkheads and decks can generally be insulated to A-60 by using materials tested and approved for steel bulkheads and decks. The procedure is explained in Technical and Research Bulletin 2-21, entitled "Aluminum Fire Protection Guidelines," published by The Society of Naval Architects and Marine Engineers (SNAME), 601 Pavonia Ave. Jersey City, NJ 07306. Also, NVIC 9-97 provides a summary of Coast Guard requirements. However, some specific materials and designs such as sprayed fiber insulation and continuous ceilings cannot be used with aluminum unless specifically tested and approved for use with aluminum construction. SNAME Bulletin 2-21 cannot be used to calculate aluminum construction for SOLAS vessels. Instead, the aluminum constructions must be tested to IMO Res. A. 754(18).

ASBESTOS: Although neither Title 46 CFR or SOLAS specifically prohibits asbestos, the U. S. Coast Guard does not approve structural fire protection materials containing asbestos fibers.

DECK FINISH EXEMPTION: Federal Regulations permits the use of unapproved deck leveling and finishing material which do not exceed 3/8 inch (9.5 mm) in thickness. SOLAS does not contain this exemption.

FLOOR FINISHES: Under the CFR, these must be approved either as deck coverings under 164.006, or as noncombustible materials under 164.009. Under SOLAS, they must meet the IMO Fire Test Procedures (FTP Code).

MODULAR ACCOMMODATION QUARTERS: The Coast Guard does not have a program for type approving complete accommodation systems for fire safety. Instead, the various structural fire protection elements (bulkhead panels, ceiling, insulation, etc.) of which the system is constructed are approved separately under their individual approval categories. This subject is not currently addressed in the FTP Code.

NONCOMBUSTIBLE CEILINGS (C-CLASS): The U. S. Coast Guard does not issue type approval for noncombustible ceilings and other C Class partitions because C-Class partitions are not required to be tested for fire resistance. The only requirement is that ceilings must be constructed of approved noncombustible materials.

NON-LOAD BEARING INTERNAL DIVISION: A recent IMO interpretation permits light-weight construction, such as honeycomb panels of steel or equivalent material, to be used as non load-bearing internal "A" class division in accommodation and service spaces provided they have been tested to the FTP Code criteria for a one hour period. These panels are constructed of thin metal sheets bonded to an insulated core material and do not have a 4-mm steel core plate. The use of lightweight construction cannot be used as an integral part of main fire zone bulkheads and stairway enclosures on passenger ships.

PAINT: The CFR permits a limited number of coats of standard paint without requiring tests or approval. Nitrocellulose or other highly flammable or noxious fume-producing paints or lacquers are prohibited. The SOLAS treaty requires paint in certain spaces to meet low flammability, smoke, and toxicity criteria.