7/16/2018: Covered areas on open decks – risks and requirements for passenger vessels

Editor’s note: The information in this post originally appeared in the Technical Notes & Training section of the Cruise Ship National Center of Expertise’s summer newsletter.

Written by Lt. John Di Nino, Marine Safety Center

The evolution of passenger amenities on cruise ships has far surpassed the original language of the existing regulations. This is particularly evident on open deck areas where the current trend to situate a variety of cooking, dining, and entertainment options has increased the fire risk. When combined with an overhanging deck, awning, or similar covered area, these risks are compounded.

The Marine Safety Center (MSC) in 2016 developed Plan Review Guideline SOLAS-29 “Overhanging Decks” to assist vessel owners and operators when using or installing awnings and similar coverings on open deck areas.

In general, any partially-enclosed open deck area that is covered with an overhanging deck in excess of 10 meters is considered an enclosed space requiring fire protection appropriate for the fire load and use. Similar areas covered for less than 10 meters are considered type 5 areas, as described in SOLAS II-2/Regulation 9, provided that all of the high-risk features, such as galley ranges, beneath the overhang are adequately separated from the surrounding areas.

Additionally, the increased trend of providing further amenities on open decks has also given rise to the installation of awnings and other similar coverings. These types of arrangements are covered by MSC.1/Circ.1274, “Guidelines for Evaluation of Fire Risk of External Areas on Passenger Ships,” which details a variety of important factors that should be considered when evaluating the fire risk and impact of a fire in all external areas. Awnings and similar coverings shall be of approved low flame-spread material and should not be capable of producing excessive quantities of smoke and toxic products or not give rise to toxic hazards at elevated temperatures.

These covered areas should not endanger passengers and crew during an emergency. Mitigation measures should be applied, as appropriate, depending on the results of the fire risk assessment detailed in MSC.1/Circ.1274. This assessment should be made available to MSC during new construction or modification plan review and subsequent Certificate of Compliance examinations if using awnings and similar coverings on open deck areas.

For more information on this topic, please contact MSC at msc@uscg.mil.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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