Sub-Committee on Ship Systems and Equipment, 10th session (SSE 10), 4-8 March 2024

Fire safety on ships carrying electric vehicles 

The Sub-Committee endorsed a roadmap and goal-based approach for developing fire safety systems and arrangements to reduce the fire risk of ships carrying new energy vehicles, including battery electric vehicles (BEVs). These will be submitted to the Maritime Safety Committee (MSC 109) in December 2024 for consideration and endorsement. 

The carriage of BEVs at sea is relatively new. However, serious fire accidents on ships carrying such vehicles have occurred, including those resulting in fatalities and major material losses, such as the Fremantle Highway (2023), Felicity Ace (2022) and Sincerity Ace (2019). There are diverse opinions on the dangers and on the methods to combat such fires. 

The Sub-Committee agreed on the following roadmap to address the fire risks associated with electric vehicles carried on ships: 

  • Review scientific reports and studies, new technologies, casualty reports and other available credible sources; 
  • Identify hazards related to new energy vehicles, including BEVs, compared to conventional internal combustion engine vehicles; 
  • Consider a goal-based approach;  
  • Identify gaps in existing regulations and consider the way forward to mitigate the gaps; and  
  • Identify placeholders for possible future amendments to international regulations (i.e. in SOLAS chapter II-2 on Construction – fire protection, fire detection and fire extinction).   

The following goal-based approach was endorsed: 

  • Goal: Minimize the risk of fire in vehicle spaces, ro-ro spaces, and special category spaces of ships in terms of carrying new energy vehicles, including BEVs;  
  • Identify hazards and risk of fire of new energy vehicles, including BEVs;  
  • Examine existing regulations of SOLAS chapter II-2 and whether the regulations cover the identified hazards; and  
  • Formulate functional requirements in support of the abovementioned goal concerning fire detection, control, containment and suppression capabilities, as well as for systems designed to mitigate risks from BEV battery fire, beyond heat and smoke generation. 

The Sub-Committee agreed to re-establish the Correspondence Group on Fire Protection to carry the work forward. It encouraged Member States and international organizations to share their data of scientific reports and studies, new technologies, casualty reports and other available credible sources on fire incidents of new energy vehicles, including BEVs, to the Correspondence Group for consideration. 

The Correspondence Group will report on its progress to the next session of the Sub-Committee (SSE 11). 

Fire detection and control on containerships 

The Sub-Committee continued its work on the development of amendments to SOLAS chapter II-2 and the Fire Safety Systems (FSS) Code, with the aim of enhancing measures to detect and control fires in cargo holds and the cargo deck of containerships.  

The issue of fires, particularly those linked to ultra-large containerships, has gained increasing attention lately. Recent containership fires include the X-Press Pearl in 2021, Yantian Express in 2019 and APL Vancouver in 2018.

The Sub-Committee considered a range of fire safety measures or risk control options (RCOs) including fire-fighting tools, fixed and portable fire detection systems, such as video and infra-red thermal imagers, fire extinguishing systems and protection of hatch covers. 

The Fire Protection Correspondence Group will further advance the work at SSE 11, with a view to amending SOLAS and the FSS Code, as required, while the CCC and HTW Sub-Committees will also be invited to address other RCOs in their respective purview.   

Revision of SOLAS chapter III and LSA Code on lifesaving appliances 

SOLAS chapter III outlines international requirements for life-saving appliances and arrangements, including requirements for lifeboats, rescue boats and lifejackets according to the type of ship. The International Life-Saving Appliance Code (LSA Code) gives specific technical requirements for the manufacturing, testing and maintenance of life-saving appliances. These sets of regulations are being revised, based on safety objectives, functional requirements and expected performance.  

The Sub-Committee agreed on a draft road map for the drafting of related functional requirements and expected performances for SOLAS chapter III and LSA Code. This roadmap will be utilized by an intersessional Correspondence Group, which will report the progress at SSE 11.  

Lifejacket carriage requirements for high-speed craft (HSC) 

The Sub-Committee finalized draft amendments to the International Code of Safety for High-Speed Craft (1994 HSC Code and revised 2000 HSC Code), to harmonize the lifejacket carriage requirements for adults and infants onboard, with SOLAS chapter III provision. 

The HSC Code is a complete set of comprehensive requirements for high-speed craft engaged in international voyages, including equipment and conditions for operation and maintenance. 

The draft amendments to the 1994 and 2000 HSC Codes will be submitted for approval by MSC 109 and subsequent adoption by MSC 110.  

Free-fall lifeboats 

The Sub-Committee agreed in principle to draft amendments to paragraph of the LSA Code. This regulation covers the testing of release systems of free-fall lifeboats as survival craft, ensuring that they meet relevant safety standards.  

The Sub-Committee noted that these amendments would require consequential adjustments to resolutions MSC.81(70), as amended and MSC.402(96), and agreed to request the Committee to expand the scope of the output to cover consequential amendments to other instruments. 

The Sub-Committee re-established the Correspondence Group on LSA to finalize these the draft amendments to the LSA Code, as well as consequential draft amendments to any other relevant instruments. These amendments are planned to be submitted for approval by MSC 110 and subsequent adoption by MSC 111.  

Maintenance, examination and testing of life-/rescue boats and launching appliances  

The Sub-Committee continued its work on the comprehensive review of the requirements for maintenance, examination, and testing of lifeboats and rescue boats, and their launching appliances, as contained in resolution MSC.402(96). The review aims to ensure consistent implementation of the requirements therein by amending the resolution accordingly. 

The LSA Correspondence Group will continue the work to develop, validate and prioritize the list of issues for consistent implementation of MSC.402(96) and report back on progress to SSE 11. 

The Sub-Committee further agreed to the draft justification for a new output to develop amendments to the 1994 and 2000 HSC Codes, as well as 1979, 1989 and 2009 Codes for the Construction and Equipment of Mobile Offshore Drilling Units (MODU Codes), to ensure consistency with resolution MSC.402(96), as a subsequent work item.  

Unified interpretation of provisions of IMO safety, security and environment related conventions 

The Sub-Committee agreed on a number of draft unified interpretations (UI) developed to clarify and help ensure the consistent application of IMO regulations in SOLAS chapters II-1, II-2 and III, as well as resolution MSC.402(96). They will be submitted for approval by MSC 109. Some other proposed UIs were identified as being outside the scope of UIs and should be further submitted as proposed new outputs, as appropriate. 

Model course on survey of electrical installations 

The Sub-Committee finalized the revision of IMO Model Course 3.04 on Survey of Electrical Installations and validated. The course aimed to ensure that surveyors be trained and able to verify the compliance of the ship’s electrical installations with the requirements in IMO conventions.  

The Sub-Committee agreed that the next model course to be revised should be Model Course 3.05 on Survey of Fire Appliances and Provisions. 

Thermal performance of immersion suits and ventilation requirements for liferafts and partially enclosed lifeboats 

The Sub-Committee agreed to continue discussions at SSE11 on the thermal performance of immersion suits used for life-saving, as well as ventilation requirements for liferafts and partially enclosed lifeboats aiming to enhance the survivability of the occupants. This is to allow for new submissions to be made to supplement the ongoing discussions.  

Election of Chair and Vice-Chair 

The Sub-Committee elected a new Chair, Mr. Hironori Eguro (Japan), and re-elected its Vice-Chair, Vice-Admiral Cristiano Aliperta (Palau), for 2025.