USCG: Hydrostatic testing of CO2 cylinders associated with fixed gas fire extinguishing systems

The United States Coast Guard has issued a policy letter about the USCG's acceptance of IMO Guidelines for hydrostatic testing of CO2 cylinders associated with fixed gas fire extinguishing systems.

This document was issued on 2 August 2023.

Purpose

This policy addresses inquiries about the effectiveness of reference (a) in achieving goals outlined in references (b) and (c) (see below).

Action

USCG Headquarters Units, Districts, and Sector Commanders must use this policy to ensure compliance with US statutory and regulatory mandates.

Background

• Due to conflicting hydrostatic testing requirements in references (a), (b), (c), and manufacturer guidance (firefighting system manual), the Coast Guard evaluated if reference (a) aligns with reference (b).
• Under references (d)-(l), alternative arrangements can be accepted if equally effective as regulations.
• Hydrostatic testing for high-pressure CO2 cylinders:
  • US-flagged inspection vessels follow (b), retesting cylinders every 12 years.
  • International voyages follow (a), testing CO2 cylinders every 10 years, with varying internal inspections.

Policy

• Based on above info, reference (a) testing is as effective as reference (b) for US-flagged vessels.
• Vessel owners can opt for (a) hydrostatic testing instead of (b) with OCMI notification and MISLE documentation.
• Exemption doesn't apply to halon cylinders (46 CFR 147.65(b)); (c) requirements still hold.
• Follow ship's maintenance plan per reference (a) Annex paragraph 3, considering manufacturer's recommendations.
• In case of conflicting recommendations, follow the stricter testing requirement.

References

(a) International Maritime Organization (IMO) MSC.1/Circ. 1318/Rev.1, Revised Guidelines for the Maintenance, and Inspections of Fixed Carbon Dioxide Fire-Extinguishing Systems (25 May 2021)

(b) 46 Code of Federal Regulations (CFR) § 147.65, Carbon dioxide and Halon fire extinguishing systems

(c) National Fire Protection Association (NFPA) 12, Standard on Carbon Dioxide Extinguishing Systems, 2022 Edition

(d) 46 Code of Federal Regulations (CFR) § 30.15

(e) 46 Code of Federal Regulations (CFR) § 70.15

(f) 46 Code of Federal Regulations (CFR) § 90.15

(g) 46 Code of Federal Regulations (CFR) § 108.105

(h) 46 Code of Federal Regulations (CFR) § 114.540

(i) 46 Code of Federal Regulations (CFR) § 125.170

(j) 46 Code of Federal Regulations (CFR) § 136.115

(k) 46 Code of Federal Regulations (CFR) § 175.540

(l) 46 Code of Federal Regulations (CFR) § 188.15

For more information, please see the document below (available only to subscribers):

USCG Acceptance of IMO Guidelines for Hydrostatic Testing of CO2 Cylinders Associated with Fixed Gas Fire Extinguishing Systems