May 31, 2019 – CG – Engineering issued a new policy letter. Following are some excerpts from that letter that are specific to Subchapter M towing vessels under 65 feet long. Please click on the link below to download the full policy letter.
(1) Purpose.This policy letter provides guidance on the acceptance of fixed fire pump size requirements for towing vessels 65 ft or less to provide a level of safety that is equivalent to the requirements of reference (a) and (b), uninspected and inspected towing vessels, respectively.
(3) Discussion. When developing references (c) and (d), the Coast Guard assumed smaller vessels would utilize portable fire pumps, while larger vessels would utilize fixed fire pumps; therefore, vessel size was not associated with fire pump requirements. This assumption imposed a larger burden on smaller vessels that opted to install fixed fire pumps. Generally, the fixed pump is required to have a higher capacity to accommodate the greater hydraulic losses expected from the extensive fire main systems used in larger vessels. In small vessels, however, the hydraulic losses of the smaller fire main systems are negligible, and the fixed fire pump need be of no higher capacity than the portable pump. Thus, in small vessels, fixed and portable pumps of similar capacity will provide similar fire streams affording an equivalent level of safety. Accordingly, for towing vessels 65 ft or less, the Coast Guard has determined a fixed pump that meets the portable pump capacity and pressure requirements meets an equivalent level of performance to the requirements in references (a) and (b).
(4) Action.
b. Subchapter M: For towing vessels 65 ft or less subject to 46 CFR 142.325, vessels may use a fixed pump that meets the performance requirements of 46 CFR 142.325(e)(1), instead of 46 CFR 142.325(a)(1). These towing vessels must also meet the requirements in 46 CFR 142.325 (a)(2), (b)-(d).
Click here to download CG-ENG Policy Letter 01-19 Equivalency Determination – Fire Pumps for Subchapter C and Subchapter M Towing Vessels
