Proposal to amend gasket requirements in the FSS Code

The International Maritime Organization has issued document SSE 11/17/3, highlighting a proposal to amend paragraph 2.1.2.5 of Chapter 5 of the Fire Safety Systems (FSS) Code. This initiative aims to resolve inconsistencies in how gasket construction requirements are applied across different IMO instruments. The proposal, put forward by India, the United Kingdom, and the International Association of Classification Societies (IACS), seeks to clarify and align the requirements for gaskets used in fixed fire-extinguishing systems within protected spaces.

Currently, the FSS Code mandates that all components of discharge piping, fittings, and nozzles, including gaskets, must be constructed from materials with a melting point exceeding 925°C. However, other IMO regulations, such as Chapter 6 of the FSS Code, the IGC Code, and IMO circulars like MSC.1/Circ.1315/Rev.1 and MSC.1/Circ.1430/Rev.3, specifically exclude gaskets from this high melting point requirement. This inconsistency has caused confusion and operational challenges for ship operators and system designers. Recognizing this issue, IACS initially issued a unified interpretation (SC 263) exempting gaskets from the melting point requirement but later withdrew it after SSE 1 determined that an amendment to the FSS Code would be a more appropriate and formal solution.

The proposal stems from the understanding that gaskets in fire-extinguishing systems are not critical to maintaining structural integrity under high temperatures. Their function remains intact during operation, even when their melting point is below 925°C. Furthermore, gasket failure due to heat only occurs after the intentional release of gas into the same protected space. This scenario poses no additional safety hazards to personnel or equipment. Given these considerations, the proposal suggests that the high melting point requirement for gaskets is unnecessary and that aligning the FSS Code with other IMO instruments would standardize regulations without compromising safety.

To address this, the document proposes an amendment to paragraph 2.1.2.5 of the FSS Code. The suggested text reads:

“All discharge piping, fittings, and nozzles in the protected spaces (except gaskets) shall be constructed of materials having a melting temperature which exceeds 925°C. The piping and associated equipment shall be adequately supported.”

The co-sponsors further emphasize that this amendment should apply to both new and existing ships to ensure uniform compliance across the maritime industry. This alignment will simplify regulatory requirements, reduce ambiguity, and address practical concerns related to the manufacturing and operation of fire-extinguishing systems.

The IMO’s Maritime Safety Committee (MSC) has already acknowledged the need for this amendment. During its 107th session, the MSC agreed to include this issue in its post-biennial agenda for 2026–2027, assigning the SSE Sub-Committee to oversee the necessary discussions and amendments. As part of this process, the co-sponsors have requested that the proposed output be included in the agenda for the 12th session of the SSE Sub-Committee (SSE 12), scheduled for 2026.

The Sub-Committee will review the proposal, deliberate on its technical and safety implications, and finalize the amendment text during its discussions. If adopted, this amendment will eliminate inconsistencies across IMO regulations, ensuring a more practical and cohesive approach to gasket construction requirements in fire-extinguishing systems.

The Sub-Committee is invited to consider this proposal, evaluate its merits, and take appropriate action to advance its inclusion in the SSE 12 agenda. This step represents an effort to enhance regulatory clarity and maintain high safety standards in maritime operations while addressing industry concerns.