The Coast Guard Design and Engineering Standards Office has issued MSIB 06-22 to advise responsible officers of the Coast Guard, Marine Inspection (OCMI), and the marine industry that the FM-200 (also known as HFC-227ea or heptafluoropropane), an extinguishing agent, is being phased out in production under the recent Environmental Protection Agency (EPA) rule1 to reduce gas production to greenhouse effect leading to global warming. FM-200 is used in fire suppression systems for machinery spaces and cargo spaces on non-inspected vessels, commercial vessels and public vessels. This rule does not prohibit the use of the FM-200 to extinguish a fire and ship operators should not hesitate to use their existing fire extinguishing systems in the event of a fire.

FM-200 is one of the hydrofluorocarbons (HFCs) regulated by the EPA under the US Innovation and Manufacturing (AIM) Act. The EPA rule requires U.S. net HFC production to be reduced to 15% of baseline levels in a phased manner over a 15-year period (2022-2036).2 The overall net HFC production reduction will result in a reduced FM-200 availability. Over time, this could lead to a shortage of supply for new FM-200 system installations and to charge existing systems following system discharge and/or routine maintenance. Shortage of supply can lead to increased materials and maintenance costs, and could result in unusable systems or delays in completing maintenance. Ships that have an inoperable fire extinguishing system are susceptible to receiving an anomaly or being ordered not to sail.

There are alternative suppression technologies that are not suppressed under the EPA rule. These systems include, but are not limited to, NOVEC 1230 cleaning agent (FK-5-1-12), carbon dioxide, inert gas systems (Inergen), water spray systems and of water mist. These extinguishing agents are Coast Guard approved for protection of machinery spaces and other spaces with flammable liquid hazards and should be considered alternatives to FM-200 for new installations or for retrofit purposes to avoid the potential shortage of FM-200.

For existing vessel FM-200 systems, these alternative suppression systems may not be an easy one-to-one replacement. The modified system could eventually require more agent, or require a system overhaul, upgrade, or complete replacement to protect the same space. A full review of the system plan and throughput calculation will be required to verify that the modified systems provide an equivalent level of security. Requests for modifications to these listed systems and USCG certified shipboard systems must be submitted to the appropriate USCG office for review prior to modification/installation.

Shipowners should not hesitate to use their existing FM-200 fire suppression systems in an emergency, as the safety of the vessel, its crew, passengers and the waterway is paramount. Where maintenance and servicing of the FM-200 system can be scheduled, such as hydrostatic testing of cylinders, it should be scheduled well in advance to ensure replacement FM-200 cylinders are available. Inspectors are encouraged to educate vessel owners about the EPA rule and the FM-200 phase-down.

Questions regarding this notice may be directed to the Coast Guard Design and Engineering Standards Office at [email protected]

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