MGN 657 requirements for fixed aerosol fire extinguishing systems for use in small vessel machinery spaces
Updated 17 May 2023
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Section 1: Overview of this consultation
Aim
1.1 This consultation seeks your views on the draft Marine Guidance Note MGN 657 (M+F) Requirements for Aerosol Fixed Fire Suppression Systems for use in Small Vessel Machinery Spaces. Aerosol fixed firefighting systems have been approved by the Maritime and Coastguard Agency (MCA) since 2001. The MCA has previously witnessed and approved the testing of these systems; this MGN seeks to formalise the test methodology and pass approval responsibility to an approved body. Previously, the installation requirements for these systems have been contained within the MCA’s systems approval certificates, and the codes which have approved them for use, this MGN seeks to simplify the requirements by giving details of the installation requirements and vessel applicability.
Views sought
1.2 Your views are sought in the following areas:
a) any content which you believe to be inaccurate:
b) any typographical errors;
c) any non-statutory advice with which you disagree;
d) any content you believe is unclear;
e) any content you think is inappropriate to include, and should therefore be omitted;
f) any content which has been omitted which you believe should be included;
g) the proportionality of the guidance and any content you believe is overly restrictive or any content that you believe is not going far enough.
h) any thoughts on the expansion of the scope of approval to domestic passenger ships under 24m load line length.
1.3 A full list of consultation questions is contained in Section 5 of this consultation.
Deadline for responses
1.4 Responses are welcomed from 5 August 2022 until 23:45 on 10 October 2022.
Section 2: Areas of consideration
2.1 The MCA has previously approved aerosol fixed fire suppression systems for use in small vessel machinery spaces through approval certificates based on the MCA’s MSF 1814 forms issued to suppliers of aerosol suppression systems. These certificates required the MCA approval of tests to show the safe and effective operation of the systems by live fire testing. This MGN now formalises the process by publishing the test requirements for future approvals and to require the tests are witnessed by an approved body appointed by the MCA.
2.2 The approval certificate provides information on the vessel types that the system is accepted for as well as details of the installation requirements for that system. Requirements that are common to all aerosol fixed firefighting system installations are described in the draft MGN.
2.3 Aerosol fire extinguishing systems involve the release of a chemical agent to extinguish a fire by interruption of the process of the fire. There are two methods considered for applying the aerosol agent to the protected space:
2.4 Condensed aerosols - created in pyrotechnic generators through the combustion of the agent charge.
2.5 Dispersed aerosols - which are not pyrotechnically generated but are stored in compressed gas containers with carrier agents (such as inert or approved halocarbon gasses) with the aerosol released into and distributed throughout the space through valves, pipes & nozzles.
2.6 A UK Approved Body, as appointed under the Merchant Shipping (Marine Equipment) Regulations 2016, as amended, (“the Regulations”), in this context, is a body which may undertake approval of an aerosol fire suppression system test that complies with the requirements of these test procedures on behalf of the MCA.
2.7 Further details on the UK Approved Bodies requirements can be found in MGN 554 “Marine Equipment - procedure for becoming a UK Approved Body following the UK’s exit from the EU”, as amended, as well as in MIN 590 as amended “United Kingdom conformity assessment procedures for marine equipment following the transition period”.
Section 3: Responding
3.1. There are specific questions highlighted in section 5 of this document and information on how to respond to this consultation document. A response form is also enclosed as a separate document.
Consultees
3.2. Anyone may respond to this consultation and consideration will be given to all responses. We will be particularly interested to hear from: Operators of vessels under 24m, domestic passenger ship operators, operators currently using aerosol fixed firefighting systems, approved bodies, manufacturers of aerosol firefighting systems and test laboratories interested in undertaking these tests.
Duration
This consultation is open for 8 weeks from 5 August 2022. The deadline for responses is 23:45 on 10 October 2022.
Submitting your response
3.4. Consultation responses should be emailed to marine.technology@mcga.gov.uk. Any questions should be sent to this email address.
3.5. When responding, representative groups are asked to give a summary of the people and organisations they represent, and where relevant who else they have consulted in reaching their conclusions.
Freedom of information
3.6. Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.
3.7. If you want the information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.
3.8. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department/MCA.
3.9. The MCA will process your personal data in accordance with the data protection framework and, in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties.
Data protection
3.10. The MCA is carrying out this consultation to gather evidence. The consultation is being carried out in the public interest to inform the development of policy.
3.11. The MCA will use your contact details to send you information about the consultation, for example if we need to ask follow-up questions, as part of its functions as a government department. Your information will be kept secure and will not be used for any other purpose without your permission.
3.12. To find out more about how the MCA looks after personal data, your rights, and how to contact our data protection officer, please go to:
If you do not wish to remain on this list, please reply and let us know.
Section 4: Outline of plans beyond this consultation
4.1. Once this consultation closes we will review all responses. In considering the responses we will apply appropriate weight to those from organisations and individuals with specialist knowledge of the subject area.
4.2. We will be analysing the responses during October 2022. Our aim is to publish an overview of the responses and the MCA’s comments by late November 2022 which will be available from: www.gov.uk/government/publications
4.3. Where appropriate the draft guidance will be revised to take into consideration the consultation responses.
4.4. Our aim is for the MGN to come into force on 1st of December 2022. The guidance will be published on www.legislation.gov.uk
4.5. An overview timetable is below for reference:
Timetable
Section 5: Conduct of this consultation
6.1. This consultation has been conducted in accordance with the Cabinet Office Consultation Principles.
Consultation principles
6.2. The Cabinet Office Consultation Principles can be found at:
Feedback on conduct of consultation
6.3. If you have any comments regarding the conduct of this consultation, please contact the Consultation Co-ordinator at consultation.coordinator@mcga.gov.uk.
6.4. We are continually trying to improve the way in which we conduct consultations and appreciate your views. We would be grateful if you could complete and return the attached feedback form. These should be submitted to the Consultation Co-ordinator and are not affected by the deadline for this consultation.
6.5 If you require this consultation in an alternative format, please contact either the Consultation Co-ordinator or the named official conducting this consultation.