Consultation outcome

Consultation outcome report for MGN 681 on fire safety and storage of small electric powered craft on yachts

Updated 26 May 2023

Section 1: Introduction

1.1 The Maritime and Coastguard Agency (MCA), an Executive Agency of the Department for Transport (DfT), carried out a public consultation on the draft Marine Guidance Note MGN 681 (M) “Fire safety and storage of small electric powered craft on yachts”, which ran from 14 November 2022 to 5 February 2023.

1.2 Small electrically powered craft and other vehicles (such as personal watercraft) are becoming more commonly used in place of similar petrol-powered craft or vehicles stowed on yachts. Whilst electric craft do not necessarily represent a greater fire risk than petrol craft, there are considerable differences in best practice for fire prevention, storage, fire detection and fire suppression of such craft, which should be considered when they are stored onboard. This MGN provides guidance for fire prevention, carriage, charging, fire detection and firefighting of small electric craft that may be stowed on yachts.

1.3 The consultation generated some very detailed and technical responses. The detailed responses offering constructive feedback are welcomed and through our engagement with stakeholders as part of this consultation and through other meetings we have made significant changes to the guidance.

1.4 This Report gives a high-level outline of the comments received from respondents. It does not seek to cover every individual comment received, but all comments received have been taken into consideration.

Section 2: Consultation

2.1 This consultation was carried out between 14 November 2022 to 5 February 2023. It can be found at: https://www.gov.uk/government/consultations/consultation-document-for-draft-mgn-681

2.2 The consultation was promulgated on GOV.UK for anyone who wished to read it and/or respond to it, and triggered notifications for anyone who is subscribed to receive such government notifications. All persons and organisations who had specifically requested notification were included.

Section 3: Consultation outcome

3.1. The government’s proposals were described in the consultation document, which then posed seven generic questions and offered a free comment box for respondents to provide detail and other thoughts they had on the content of the proposed guidance. A total of fifteen (15) responses were received, three from classification societies, six from builders of large yachts, one from the Law Society of Scotland, one from a private individual, one from a marine firefighting consultancy, one from a surveyor of large yachts, one form an electrical equipment installation contractor and one from an insurer of large yachts.

3.2.1 Comments from Class Societies

Three class societies provided comments on the MGN. All three welcomed the guidance provided in the MGN and provided technical feedback related to the guidance as well as asking for clarification around the applicability based on battery size, how the guidance would be applied to Red Ensign Group (REG) Code Part B Yachts and how the guidance would be applied where it diverged from class rules and mandatory requirements. There were also some comments around spelling and formatting issues.

The class societies who responded have requested that further technical information is provided with regards to charging of batteries and how to do this safely. They also asked questions around how the hazardous area classification would be applied, provided suggestions for the temperature-controlled areas used for charging and how these should be monitored.

One also asked a question around how tenders, where the battery cannot be removed, should be treated.

With respect to applicability, all asked for an additional section to be added which made clear at what battery size this guidance should be applied. As part of this, one requested that a list of acceptable battery chemistries be included as well as an additional warning over the use of batteries and associated equipment coming from less reputable manufacturers without valid certification and approval.

Questions were raised over how this guidance would impact on class rules where they diverge and how it would be interpreted against the (REG) Yacht Code Part A where the guidance does not match with the requirements within the code. There was also a question over this guidance and how it would apply to yachts under the REG Yacht Code Part B.

One class society provided comments relating to best practice for firefighting of lithium metal that they proposed be included in the guidance.

3.2.2 MCA Response

The MCA welcomes the response from the class societies and has made some changes to the to the guidance based on the comments provided where appropriate.

A section on applicability has been added as section 2 to clarify the application of the guidance and how it relates to yachts of different sizes, ages and battery sizes. This is also used to clarify the application to Part B yachts and to older yachts.

The information provided around the best practice for firefighting of lithium metal was welcome but has not been included in the MGN as it is not thought to be relevant when discussing Lithium-Ion (Li-ion) batteries which use lithium as a salt to store charge and have very different firefighting requirements to lithium metal.

A full list of battery chemistries was not included in the guidance in an attempt to remain as technology neutral as possible and to future proof the guidance against new developments in battery chemistry. However further emphasis was added to the guidance in Section 4.4 around the importance of using batteries and associated systems from reputable manufacturers with the correct certification to minimise the potential fire risk.

Clarifications have been added around the application of the rules to tenders and around the explosive atmosphere risks.

3.3.1 Comments from Builders of Large Yachts

Comments on the MGN were received from six builders of large yachts and these are welcomed by the MCA. All of the ship builders who responded were in favour of the guidance but asked for clarification around applicability, additional guidance on the batteries that can be taken on board and provided some technical comments against certain parts of the guidance.

Two builders asked that this guidance only be applicable to yachts that are not yet under construction and that it should not be applied to existing ships. They also asked that it be made clearer in the guidance that this should not be applied for the small Li-ion batteries found in personal devices such as laptop computers and mobile phones.

Two builders requested that additional information was provided about the batteries that can be taken onboard and made comments around the increase in safety of newer batteries based on developments from other industries, the importance of using reputable manufacturers and having the correct approvals and certification. They also pointed-out that the personal water craft and other small electric vehicles are often added after the yacht has been supplied by the shipyard and they do not have control over this. One ship builder commented that the MGN underestimates the battery sizes in these small electric craft and suggests that these will trend towards even larger sizes over the coming years.

From a technical perspective two builders commented around the guidance for not charging in a space adjacent to a Category A machinery space. They pointed out that this would already be separated by an A-60 boundary and that with the correct fire detection and firefighting systems it is no less safe being placed there than in any other space if the batteries are stored and charged away from the A-60 boundary with the category A machinery space.

Three builders commented on the guidance proposing integrating the ships alarm and control systems with the battery management systems (BMS) of the vehicles being charged on board to provide early detection of faults such as overheating etc. noting that while this would be a useful feature and would aid in early detection it is unlikely that the BMS would be compatible with the ships systems and that any integration would be impractical.

There was also a comment from one ship builder asking for clarification relating to the use of the same “garaging” spaces for both petrol and battery powered craft and if this was allowed by the guidance.

3.3.2 MCA Response

The MCA welcomes the response from the ship builders and the perspective that they bring, especially related to the technical aspects of the ships design.

The questions around applicability are addressed in the new Section 3 which includes comments on the applicability to older ships and makes clear that the guidance is for batteries used with electric vehicles.

Corrections have been made to the battery sizes and extra text has been added to highlight the responsibility for tender battery safety lies with the tender manufacturer. The BMS comments have been included, noting that while this would be enormously beneficial to the safety of charging operations it is impractical as most of the vehicles’ BMSs would not be able to communicate with the ships systems in a meaningful way.

The comment regarding location of charging spaces has been acknowledged and the guidance adjusted in section 4.7.3 to reflect the comments from the builders noting the existing fire protection between any of the spaces described.

3.4.1 Comments from Law Society, Insurers and Private Individuals

Responses to the consultation were received from the Law Society of Scotland, a private individual and large insurer who provides coverage for yachts.

The Law Society of Scotland asked for clarity over what size of battery the guidance should apply to, asked about the use of the term “off-gassing” and suggesting that venting is a more appropriate term as well as requesting a more specific breakdown of the gases produced during thermal runaway events.

A private individual proposed that a specific device could be used to prevent overcharging. This device would be an electrical device rather than the software-based approach taken by the BMS.

The insurer welcomed the guidance but raised concerns over how it is applied to vessels that are not on the UK flag, how it is applied to older vessels and how it will be enforced. They also noted that the guidance was very technical in nature and requested that simplified guidance be developed for placing onboard ships to aid with Li-ion battery fire safety.

3.4.2 MCA Response

The MCA thanks the law society, the insurer and the individual who replied to the consultation.

The battery size to which the guidance applies has been clarified in the added section on application, this should address the comment made by the Law Society of Scotland. The term off-gassing is well understood and differs from venting, it is thought that the term off-gassing is correct to use in this instance. The specific gasses that are produced during a thermal runaway event are dependent on the battery chemistry. It is felt by the MCA that the current description of the gases is sufficient.

The guidance tries to avoid promoting specific solutions and for this reason will not include reference to the device suggested by the individual who responded.

The queries raised by the insurer are partly addressed within the new section on applicability where the applicability to existing vessels is discussed. With respect to ships outside the UK and not on the UK flag, the MCA has no control over vessels that are outside UK waters and are not UK flagged but would welcome this guidance being used by these vessels as a reference to help improve their own procedures and practices for carriage of li-ion batteries. It should also be restated that this is guidance and not a set of enforceable requirements.

The MCA acknowledges that the guidance is technical in nature, it is not developed to be a quick reference for use onboard but others are welcome to be use it as a basis for developing their own abridged guidance for specific audiences and situations.

3.5.1 Comments from Yacht Surveyors, Marine Fire Consultants and Electrical Equipment Installers

Comments were received from a surveyor of large yachts, a marine fire consultancy and marine electrical installer. They provided technical comments relating the guidance as well as asking for further clarification to be provided in some areas.

They also highlighted the importance of using reputable manufacturers with the correct certification for batteries placed on board and made reference to the risk of fire being heavily dependent on the battery chemistry and construction.

They proposed that the temperature limit for the temperature-controlled areas be increased from 40 °C to 45 °C to align with existing guidance for other systems and to ease the burden on the air conditioning loads when operating in warm weather environments.

There was also a request for clarity on the Personal Protective Equipment (PPE) requirements and the use of fire blankets as well as a recommendation to strengthen the guidance around the use of handheld thermal imaging cameras for early detection of potential Li-ion battery fires.

3.5.2 MCA Response

The MCA welcomes the comments from surveyors, fire consultants and electrical installers and is grateful that their perspective is included in the guidance. The comments around certification and use of reputable manufacturers is now included in the guidance at section 4.4.

The comment regarding the increase in the upper limit of temperature-controlled spaces from 40 °C to 45 °C was explored and found to be a strong suggestion, decreasing the extra demands on the vessel for cooling, aligning with commonly used temperature limits for other equipment and not increasing the risk of battery fire. Section 4.9 has been updated to reflect this proposal.

The PPE requirements in the guidance reflect the best practice, however the MCA will not require ships to supply PPE beyond the requirements of SOLAS Chapter II-2 Regulation10.1 and Chapter 3 of the Fire Safety Systems (FSS) Code. The use of BS EN 469:2020 level 2 protection suits is however recommended.

The MCA believes that the existing guidance is strong enough in its endorsement of the use of thermal imaging cameras.

3.6 Summary

There was engagement in the responses across all areas of the guidance. The responses were generally supportive with all respondents approving of the overall plan to introduce formal guidance of fire safety for Li-ion battery vehicles on large yachts.

While not all comments have been included with in the revised MGN they have all been fully considered. The MGN has been updated accordingly and will be published after final review by the MCA.

Section 4: Next steps

4.1. The government will finalise the guidance with a view to publishing by Summer 2023.