Chapter 2 - Assessing fire safety of FRP composite structures
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Statutory Documents - IMO Publications and Documents - Circulars - Maritime Safety Committee - MSC.1/Circular.1574 – Interim Guidelines for Use of Fibre Reinforced Plastic (FRP) Elements Within Ship Structures: Fire Safety Issues – (9 June 2017) - Annex - Interim Guidelines for Use of Fibre Reinforced Plastic (FRP) Elements Within Ship Structures: Fire Safety Issues - Chapter 2 - Assessing fire safety of FRP composite structures

Chapter 2 - Assessing fire safety of FRP composite structures

 2.1 Laminates, sandwich panels and stiffeners formed by polymers, fibres and core materials may be combined in different ways to make up FRP elements on ships. Within these guidelines, FRP is defined as multi-material compositions of monolithic or sandwich constructions. Monolithic constructions and skin layers of sandwich constructions are based on long-fibre reinforced resins. Reinforcements can be for example fabrics of glass, carbon, aramide or basalt fibres. Resins shall be based on duromer (thermoset) resin. Sandwich core materials are typically based on structural foams or honeycombs. Coatings (gelcoats, topcoats or paints), casting masses and adhesives are handled under these guidelines as well. Some typical FRP composite materials and compositions used in shipbuilding are further described in appendix B (FRP composite materials and compositions used in shipbuilding). It also exemplifies fire behaviour of typical FRP composite constituents and compositions. Relevant fire properties of the particular materials considered in an alternative design must be derived by tests for each specific design case (see appendix D (Fire testing of FRP composite)).

2.2 Use of FRP composites on SOLAS vessels is generally not allowed due to prescriptive requirements on use of non-combustible materials. However, when design or arrangements deviate from the prescriptive requirements of SOLAS chapter II-2, review and approval can be carried out in accordance with SOLAS regulation II-2/17. Combustible FRP elements and related safety measures can thus be treated as alternative fire safety design and arrangements. Engineering analysis, evaluation and approval shall then be carried out based on a procedure summarized in the regulation, whilst more detailed descriptions are contained in the Guidelines on alternative design and arrangements for fire safety (MSC.1/Circ.1002, as amended by MSC.1/Circ.1552). Life safety performance criteria are contained in MSC.1/Circ.1552. These guidelines support the use of performance-based methods of fire safety engineering to verify that the fire safety of a ship with alternative design and arrangements is equivalent to the fire safety stipulated by prescriptive requirements, a concept often referred to as the "equivalence principle". Briefly, the procedure can be described as a two-step deterministic risk assessment carried out by a design team. The two major parts to be performed are:

  • .1 the preliminary analysis in qualitative terms; and
  • .2 the quantitative analysis.

In the first part, the design team is to define the scope of the analysis, identify hazards and, from these, develop design fire scenarios as well as develop trial alternative designs. The different components of the preliminary analysis in qualitative terms are documented in a preliminary analysis report which needs consent by the design team before it is sent to the Administration for review. With the Administration's approval, the preliminary analysis report documents the inputs to the next step of the assessment, the quantitative analysis. At this stage, the design fire scenarios are quantified and outcomes are compared with performance criteria determined based on the fire safety objectives and the functional requirements of the SOLAS regulations. The criteria are quantified with reference to relevant prescriptive requirements or by comparison to the performance of an acceptable prescriptive design. The documented level of fire safety of the alternative design and arrangements may therefore not be absolute but relative to the fire safety of a traditional design, which is a product of the fire safety implied by prescriptive regulations. Accounting for uncertainties when comparing levels of fire safety, the final documentation of the engineering analysis based on SOLAS regulation II-2/17 (hereafter referred to as "SOLAS regulation II-2/17 assessment") should with reasonable confidence demonstrate that the fire safety of the alternative design and arrangements is at least equivalent to that of a prescriptive design.

2.3 According to SOLAS regulation II-2/17, alternative design and arrangements for fire safety should provide a degree of safety at least equivalent to that achieved by compliance with the prescriptive requirements. It is therefore important that the approach used to assess safety can properly describe the effects on fire safety posed by the alternative design and arrangements, i.e. descriptions of uncertainties must be sufficient to establish appropriate safety margins. This is a particularly relevant consideration when evaluating FRP composite structures. Depending on the scope, an assessment in accordance with MSC.1/Circ.1002, as amended by MSC.1/Circ.1552, could appear overly complex or insufficient. Recommendations and requirements for the method used to assess the safety of an alternative design involving FRP composite structures are discussed in appendix C (Recommendations regarding the assessment). It may also be relevant to consider the Guidelines for the approval of alternatives and equivalents as provided for in various IMO instruments (MSC.1/Circ.1455), which describe an approach which is more adaptable to the scope of the alternative design and arrangements. MSC.1/Circ.1455 was developed to provide a consistent process for the coordination, review and approval of alternative design and arrangements in general, i.e. not only concerning fire safety. It may therefore provide additional guidance when the use of FRP composite structures affects other aspects of safety than those related to fire (see appendix A (Issues other than fire safety)). In detail it also describes the risk-based approval process surrounding the assessment. As referred to in SOLAS, the guidelines in this document take basis in MSC.1/Circ.1002, as amended byMSC.1/Circ.1552.

2.4 One of the first and most foundational steps in the SOLAS regulation II-2/17 assessment is to form an approval basis. This is done by identifying the prescriptive requirement(s) deviated by the alternative design and arrangements (SOLAS regulation II-2/17.3.2). With an understanding of their associated functional requirements, the deviated prescriptive requirements are then used to define performance criteria, as described in MSC.1/Circ.1002, as amended by MSC.1/Circ.1552, paragraphs 4.4, 5.1.2 and 6.3.2 and in SOLAS regulation II-2/17.3.4. However, owing to limitations in the current regulations, identification of deviated prescriptive requirements may not form a sufficient basis to ensure equivalent safety. When considering FRP composite structures, deviations fundamentally concern the required non-combustibility of structures. With the assumption that non-combustible structures are used, the fire safety regulations include unwritten (implicit) safety requirements. In order to establish an appropriate approval basis, it is therefore required in each design case to perform the necessary investigations to identify all relevant effects on fire safety. This is further described in appendix C (Recommendations regarding the assessment). In particular, the achievement of each fire safety objective and functional requirement should be judged independently, including the functional requirements in purpose statements at the beginning of the regulations. Potential challenges to fire safety objectives, functional requirements, purpose statements and prescriptive requirements in SOLAS chapter II-2 when considering FRP elements are exemplified in chapter 3 (Important factors to consider when evaluating FRP elements with starting point in the regulations of SOLAS chapter II-2). Further recommendations regarding an assessment of fire safety involving FRP elements are presented in appendix C (Recommendations regarding the assessment).

2.5 A number of fire hazards may be introduced by the use of FRP elements. A useful starting point for the hazard identification is the investigation of challenges to regulations and thus chapter 3 (Important factors to consider when evaluating FRP elements with starting point in the regulations of SOLAS chapter II-2). Fire hazards relevant for further investigation, categorized according to the regulations in SOLAS chapter II-2, are particularly:

  • .1 probability of ignition;
  • .2 fire growth potential;
  • .3 potential to generate smoke and toxic products;
  • .4 containment of fire;
  • .5 firefighting; and
  • .6 structural integrity.

2.6 The fire hazards and performance of safety measures may be quantified by tools for fire safety engineering and risk assessment and with reference to fire tests (see appendix D (Fire testing of FRP composite)). Sufficient safety may be assured within delimited areas separately, e.g. covered by functional requirements or regulations, or included in a holistic estimation of effects on safety. The former is illustrated along with further examples of an assessment in appendix E (Assessment examples).

2.7 Key terms are defined in MSC.1/Circ.1002, as amended by MSC.1/Circ.1552, and MSC.1/Circ.1455, as well as in fire safety engineering guidelines for buildings, e.g. ISO 23932.


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