E

SUB-COMMITTEE ON SHIP SYSTEMS AND SSE 10/8

EQUIPMENT 27 December 2023
10th session Original: ENGLISH
Agenda item 8 Pre-session public release: ☒

REVISION OF THE 2010 FTP CODE TO ALLOW FOR

NEW FIRE PROTECTION SYSTEMS AND MATERIALS

Proposals on the 2010 Fire Test Procedures Code

Submitted by the United States

SUMMARY

Executive summary: This document identifies ambiguities within the FTP Code and
proposes new materials and new construction techniques to be
addressed in the development of the revision to the FTP Code, while
coordinating changes with updates to SOLAS regulation II-2/9.

Strategic direction, 7
if applicable:

Output: 7.34

Action to be taken: Paragraph 23

Related documents: MSC 102/21/11; MSC 103/21; MSC 104/15/2; MSC 105/20;
MSC 107/17/8 and SSE 10/17/1

Background

1 At its 103rd session, the Maritime Safety Committee (MSC 103/21, paragraph 18.28)
approved a new output to review and amend the International Code for Application of Fire Test
Procedures, 2010 (FTP Code), based on a proposal in document MSC 102/21/11
(Austria et al.).

2 The agenda item's scope includes allowing for new fire protection systems and
materials, updating the FTP Code to include existing unified interpretations and updating
references to the most recent ISO fire test standards.

Modular construction and testing

3 The FTP Code and much of SOLAS were developed around traditional ship
construction practices and do not reflect new construction technologies and techniques.
An example of this is the use of modular construction.

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4 Modular construction allows for individual components to be built independently and

then assembled to form the entire ship. This construction technique can result in the creation
of an air gap between bulkheads of separate individual components. This air gap is not present
with traditional vessel construction. This has led to the practice of Administrations and ROs
approving "Restricted" fire rated bulkheads which have only been tested from one side, with
the provision that they are installed adjacent to another similar bulkhead with the untested
sides facing each other, or that the untested side faces a space with no fire risk.

5 "Restricted" type approvals are allowed for A-class, where bulkheads are tested in
one direction, per the FTP Code, annex 1, part 3, appendix 1.4. "In tests for A-Class bulkheads
for 'Restricted application', i.e. where the fire hazard has been identified as being from the
insulated side only, the bulkhead can be tested with the insulation on the exposed face with
stiffeners also on that side."

6 However, type approvals usually do not include installation-specific provisions and

limitations. The most common type approval is a "General application" or "Double-sided
application" where the bulkhead's insulation and stiffeners are placed in the worst case
configuration. As a result, there are no further limitations or provisions placed on the installation
of the bulkhead.

7 The United States conducted preliminary computation analysis research into fire
scenarios on the unexposed side of bulkheads and found that the interstitial space between
modular construction bulkheads may generate temperatures up to 20% greater than those on
the unexposed side of a comparable standard construction bulkhead. Without further research
into this matter, the United States is concerned that the air gap between the two bulkheads
could have a negative effect on the overall fire rating of this arrangement.

8 The United States believes that the FTP Code does not properly address the
application of restricted approvals in current shipbuilding modular construction practices.
The thermodynamic implications of the air gap between the two individually restricted
bulkheads, and the appropriateness of single-sided testing of these divisions has not been fully
evaluated or addressed in the FTP Code. The United States invites Member States and
international organizations to evaluate current practices and the need for amendments to the
FTP Code or SOLAS as it relates to this matter.

New materials and testing

9 The United States seeks a better way to evaluate new materials and technologies
with the FTP Code, so that they can be used in structural fire protection (SFP). The United
States has identified three materials: aerogels, cementitious materials and intumescent
materials, with sufficient performance characteristics for use as SFP that may not otherwise
pass the current testing methods and meet the current evaluation criteria of the FTP Code.

10 Aerogels are a group of synthetic composite materials made of very porous media
(typically silica) and air. The resulting composite materials have a low mass and very low
thermal conductivity. When these new materials are tested using the FTP Code's Part 5 test,
aerogels may produce a very rapid and low intensity initial flame front which travels across the
specimen. Continued testing of the product results in a marginally burned specimen; however,
this initial flaming behaviour gives the impression of a very high burn rate, which when
analysed to the part 5 test criteria, results in the material failing. The United States believes
that this initial flaming behaviour is not representative of the overall fire risk of this material or
its suitability for use in structural fire protection.

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11 Cementous materials also have unique material properties which cause it to appear
to fail the FTP Code's part 5 and part 1 tests. Cementous materials will spall or fragment under
heat, which can produce test results which are inconsistent and unreliable. This spalling effect
can result in failures, or the need to re-test, and the United States believes that this behaviour
may not be representative of the overall fire risk of the material itself or its suitability for use in
structural fire protection.

12 Intumescent materials also have unique material properties which cause it to be

difficult to test in both the part 5 and part 1 tests. Intumescent material's ability to expand in
volume poses a risk to the test apparatus. Expanding intumescent material risks contacting
the surface of the test apparatus and may result in damage to the test equipment through
electrical shorting or producing inconsistent measurements. The United Sates believes that
the current FTP Code test method and apparatus may need to be re-evaluated for testing of
these materials.

13 The United States does not believe that these failure conditions, which occur under
the current FTP Code, are representative of the true fire risk of these products or their suitability
for use in structural fire protection. The United States believes that the FTP Code needs more
appropriate test methods that will properly evaluate these materials and consider their unique
physical and fire risk properties. The United States invites Member States and international
organizations to evaluate current practices and the need for amendments to the FTP Code as
it relates to this matter.

Approval factors and testing

14 The FTP Code assumes traditional construction practices and that test samples of
construction materials are representative of how these products would be installed using
traditional construction practices. As new construction techniques develop, the assumptions
of traditional construction, imbedded in the FTP Code, become less accurate. When vessels
were constructed largely from steel these assumptions were accurate, however composite, or
novel materials do not have the same risks as steel.

15 The United States believes that the FTP Code fails to address what factors are
important to limit the scope of approval of SFP materials. The United States believes that it is
not necessary to test every material and every possible configuration and that careful
consideration of the testing factors can result in approvals which minimize both administrative
and testing burden.

16 For a cable or pipe penetration in an A-60 structural fire boundary, the United States
has received questions regarding if approvals should be limited based on pipe diameter, pipe
schedule, pipe material, pipe brand, pipe paint or coatings, fill percentage, bulkhead material,
thickness and configuration. While all these factors will have an effect on fire performance,
the United States believes that it is not necessary to limit approval based on all of these factors
because some factors matter more and could be used as the basis to limit the scope of
approval.

17 The United States believes that it is impractical to test all possible pipe/cable
configurations for each kind of pipe or cable. The Code could be modified to clearly state what
factors should be considered in limiting the scope of approval, what determine the worst-case
configuration and what factors may be generalized to not limit approvals.

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18 Another factor the United States believes needs clarity is in Part 3 testing to determine
what is 'symmetrical' or what is the 'worst case' configuration. The Code does not define
symmetrical, nor does it provide detailed guidance on what factors should be considered when
determining a 'worst case' configuration. The Code does not qualify the degree of symmetry
needed to consider a fire door, window or penetration symmetrical. Relatively minor changes
to the construction or profile of a test specimen may or may not have a meaningful effect on
testing. However, since the Code is ambiguous on what factors are important or what is the
acceptable level of symmetry, this may result in additional testing, for a relatively low risk
asymmetry. This would result in the manufacturer having to test all possible orientations and
configurations and shipbuilders being limited in their design options.

19 The United States believes that a clear identification of the meaningful factors used
to evaluate the scope of approval will help the FTP Code and Administrations better
understand the technical limitations of their approvals. It would provide understanding on what
configuration is the 'worst-case', and where re-testing new models or new configurations is
warranted on a risk-based approach.

FTP Code improvements and SOLAS regulation II-2/9

20 At its 105th session, the Committee agreed to include in its post-biennial agenda an
output on "Review and update SOLAS regulation II-2/9 on containment of fire to incorporate
existing guidance and clarify requirements" (MSC 105/20, 18.8). However, the United States
notes that this output is not included in the agenda for SSE and is not presently listed in the
biennial agenda for 2024-2025 agreed at A 33 (A 33/8(a)/Add.1).

21 The intent behind SOLAS regulation II-2/9 is to restrict the growth of fire, and the FTP
Code is based on the requirements in regulation 9. Changes in regulation 9 will affect the
requirements in the FTP Code and vice versa. Therefore, the United States believes these two
areas should be reviewed together. Accordingly, the United States supports the proposal made
by IACS to include the output "Review and update SOLAS regulation II-2/9 on containment of
fire to incorporate existing guidance and clarify requirements" in the provisional agenda for
SSE 11 (SSE 10/17/1(IACS)).

Proposal

22 In light of the foregoing discussion, the United States proposes that the following
matters be considered in developing this output:

.1 evaluate the thermodynamic implications of the air gap between rated

bulkheads in modular construction and the appropriateness of single-sided
testing of these divisions (paragraphs 3 to 8);

.2 identify appropriate test methods to allow new materials to be adequately

evaluated under the current FTP Code, considering their unique physical
properties and fire risk (paragraphs 9 to 13); and

.3 identify the factors which should be noted on the approvals to limit of the
scope of an approval or determine worst-case configurations for testing
(paragraphs 14 through 19).

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Action requested of the Sub-Committee

23 The Sub-Committee is invited to:

.1 take the discussion above and the proposals set out in paragraph 22,
into account when progressing the work on this output; and

.2 consider coordinating the work under this output with the output on "Review
and update SOLAS regulation II-2/9 on containment of fire to incorporate
existing guidance and clarify requirements" and view those agenda items as
a cohesive whole.

___________

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