USCG released PRGs on stability for small passenger vessels and decorative doors in escape paths

The United States Coast Guard has recently released two Plan Review Guidelines. On 25 September the Review of Stability for Small Passenger Vessels (T) was released, and the Review of Decorative Doors in Escape Paths was issued on 2 October 2023.

Review of Stability for Small Passenger Vessels (T)

This Plan Review Guideline (PRG) offers instructions and details for the marine sector when it comes to submitting stability calculations and drawings for Small Passenger Vessels aiming for certification under 46 CFR Subchapter T.

The PRG applies to the evaluation of stability calculations and drawings by the Marine Safety Center for vessels certified under 46 CFR Subchapter T.

If the stability of the vessel is being assessed by the American Bureau of Shipping following reference (1), there is no need for the MSC to conduct a separate review of stability.

Review of Decorative Doors in Escape Paths

This PRG serves the purpose of offering clear instructions for reviewing decorative doors installed within passenger escape routes.

Applicability

This PRG is relevant to SOLAS passenger vessels carrying over 36 passengers.

It applies to decorative doors positioned within designated escape routes as outlined in the approved Emergency Escape/Egress Plan (EEP).

This PRG does not pertain to fire doors that must meet "A" or "B" class integrity standards.

Reference

Reference is made to SOLAS II-2/13.3.2, which covers means of escape in passenger ships.

SOLAS II-2/9.4.1.1.7 states that the requirements for "A" class integrity do not apply to exterior doors, except those in specific areas.

SOLAS II-2/9.4.1.2.3 exempts exterior doors in superstructures and deckhouses from "B" class integrity requirements.

Background

A subcategory of decorative doors includes "automated" decorative doors, which are electronically controlled and powered. Concerns include potential loss of functionality during power outages and inadvertent locking by passengers or crew.

This PRG addresses decorative doors placed within designated passenger escape paths, primarily for aesthetic or climate control purposes.

Decorative doors are sometimes installed near required fire doors, in accordance with SOLAS II-2/9.4.1.1.7 and 9.4.1.2.3.

During all operational conditions, decorative doors within escape routes must allow for safe escape, following SOLAS II-2/13.3.2.

These doors must not affect the functionality of adjacent fire doors, as they could impede egress.

Content

In light of the background information, decorative doors within escape routes should meet the following functional requirements:(1) Ensuring means to open the door in the direction of escape under all conditions, including:

• a. Accessibility without requiring special tools or knowledge.
• b. For automated decorative doors, provision of power-driven and/or manual means during power loss.
• c. Safeguards to prevent inadvertent "locking" of the doors in the escape direction (SOLAS II-2/13.3.2.6).
• d. The doors should be operable by the crew from both sides for firefighting purposes.

Arranging decorative doors so that they do not hinder the functionality of required fire doors, including:

• a. Preserving accessibility to the fire door handle.
• b. Ensuring the passage of a fire hose through the fire door remains unaffected.
• c. Guaranteeing that the movement of the fire door remains unobstructed by the positioning of the decorative door.

Additional considerations

Vestibules created by a pair of decorative doors should enable opening from inside to prevent passenger entrapment.

For automated decorative doors, clear markings should indicate the means for manual override or operation during power loss, visible in all conditions.

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

Review of Stability for Small Passenger Vessels (T)

Review of Decorative Doors in Escape Paths