46 CFR 142.330(a)(7)
QUESTION:
What is required as evidence of a fire detection system being certified and inspected by a registered professional engineer (PE) or National Institute for Certification in Engineering Technologies (NICET) Level IV fire alarm engineering technician?
RESPONSE:
Commonly referred to as a PE Letter, auditors, surveyors, or Coast Guard inspectors will ask for documentary evidence of the certification and inspection of the vessel’s installed fire detection system. This documentation should adequately document the certification and inspection of the system. The content and layout of these letters vary among the individuals that make these attestations. TVIB has communicated with the TVNCOE, and various PE/NICET individuals, and reviewed multiple versions of these letters. While no specification for the content of these letters can be pointed to, we have been able to identify what a towing vessel owner/operator should reasonably expect to see in these letters.
Expected content of PE/NICET letters for an installed fire detection system:
- Vessel Name and Official Number
- Date of Inspection
- A statement that the system complies with 46 CFR 142.330 or individually lists each of the requirements under §142.330
- Identify the control panel make/model and serial number
- A list of smoke and/or heat detectors installed throughout the vessel including the make/model and location and/or a basic diagram indicating the same
- A letter produced on the letterhead of the PE/NICET that bears the printed name, signature, and stamp of the PE/NICET
WHAT TO DO IF THE PE/NICET LETTER DOES NOT CONTAIN THE ABOVE INFORMATION:
It is not required to have your PE/NICET letter reissued. However, at such time any change or modification to the system is performed a new PE/NICET letter is required so that the system is certified and inspected to verify compliance. This would be the time to discuss with your hired PE/NICET your expectations for their letter.