Compliance

Compliance

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MGN 580 (M) - Fire Protection - Fire Retardant Treatments for Fabrics - New Legislation

Although the new MGM 580 (M) legislation replaces the previous MGM 453 (M), all vessels with MGM 453 (M) certification will continue to be covered until the renewal date of their certificate. Upon which any future certification will be completed to the new MGM 580 (M) standard.

Here's What You Need To Know about Compliance and MGM 580 (M)

The requirements regarding flame retardant treatments and those who apply them on-board vessels certified under the Maritime and Coastguard Agency (MCA) Large Commercial Yacht Code part A (vessel < 500GT) have improved immensely over the last 20 years. We believe some of the the most significant changes took place when MGM 453 (M) was introduced. The MGM 453 (M) requirements were more stringent and raised the standards of those companies providing this crucial service. At that time, any prior MCA accreditations were revoked and all companies had to be approved and certified in accordance with a new set of procedures to recognise and document what was fire safe. As a result, crews, owners, and guests would benefit from the advancement.

Timeline of Legislation

  • The first Yacht Code was published by the UK’s Maritime and Coastguard Agency (MCA) in 1997
  • LY2 The Large Commercial Yacht Code MSA 010/009/0184 published September 2007
  • LY3 The Large Commercial Yacht Code MS 174/004/055 published August 2012
  • MGM 453(M) came into force on 1st October 2012
  • The Large Yacht Code LY3 combined into The Red Ensign Group Yacht Code known as The REG published Jan 2019.
  • Finally, the most recent amendment has been MGM 580 (M) which came into force earlier this year.

Very little has changed in MGM 580 (M) from the previous MGM 453 (M) legislation. As a result, owners, guests, captains, crew, management companies and charter companies, won’t have to do anything new.

We have set out the amendments below in more detail in a QA format.

The most important fact to note is the following:-

Although the new MGM 580 (M) legislation replaces the previous MGM 453 (M), all vessels with MGM 453 (M) certification will continue to be covered until the renewal date of their certificate. Upon which any future certification will be completed to the new MGM 580 (M) standard.

To control the approval of these fire retardant treatments, the MCA continues to use MCA Approval Procedures and a Declaration of Conformity for such treatments.

The standards required by those applying flame retardant products to floor coverings, suspended textile materials, upholstery materials and bedding components are set out in The Maritime and Coastguard Agency (MCA) Marine Guidance Note (MGN) 580 (M).

The New MGN 580 (M) Legislation - What has changed from the previous MGN 453 (M)? Your Questions Answered.


MGM 580 (M): What do owners and captains of vessels need to do?

There are no changes from the client perspective at all. MGM 453 (M) certification is still recognised and valid until the renewal date. Then the certification will be completed to
the new MGM 580 (M) standard.

MGM 580 (M) – What has changed compared to MGM 453 (M) legislation?

1. MCA Notified Bodies to Manage the new legislation.

The MCA have passed the management of MGM 580 (M) to any interested parties who are on the MCA’s Notified Body List of UKAS Accredited Companies.

2. Changes to the pre-test process when the flame retardancy chemical is tested.

The MGN now requires a pre-soak of all textiles before we visit to treat them and the process witnessed, before the samples are then sent to test.

The fabrics are now soaked in water for 72 hours and the water is changed every 24 hours to prevent any pre-treatment tampering, before the company is invited in to spray. This is done to break down any previous treatments which may have been applied and thus preventing a spurious result.

Under the new MGM 580 (M), are all textiles tested to a higher performance requirement than previously?

No, that is not true. The only addition is the pre-soak discussed above which has nothing to do with flammability testing, that is exactly as it was and is strictly controlled by the IMO FTP Code of 2010, none of which has changed.

Do carpet and floor coverings require both flammability and the stringent life saving toxicity test under the new MGM 580 (M)?

No, that is not true, the IMO FTP CODE 2010 (Revised 2012) Part 5 – A.653 (16) Test for Surface Flammability for primary floor coverings is exactly the same, this includes the smoke toxicity test. They now have a water extraction element after treatment, which has been taken from the rules used for Cruise liners and Passenger Ferries, but no change to the Flame Test.

What does the MCA say about the requirement to treat carpets?

We contacted the MCA regarding this very subject and here is what they said about carpets and floor coverings:-

1. There is currently no requirement on Large Yachts under 500GT to treat floor coverings

2. The REG Yacht Code (Red Ensign Group) provides the current requirement.

3. Part A Section 14A does not require FTP Code compliance of carpets. (in line with SOLAS for under 500GT cargo ships).

4. Part A Section 14B does not require FTP Code compliance of carpets – only Primary Deck Coverings.

5. Part B Passenger Yachts does require FTP Code compliance of carpets – (in line with SOLAS for Passenger ships)

MGN 580(M) details how to treat floor coverings and primary deck coverings if there is a requirement to do so. MGN 580(M) does not constitute the requirement.

MGN 580 (M): Summing up and Going Forward

Flame Screen welcomes the new legislation. Here is a brief summary of our thoughts regarding our products, procedures and documentation:-

  • Our chemical Emalfon has not changed from the first time it passed testing.
  • The actual Flame Tests have not changed from the first time we tested.
  • All the tests for the new MGN 580 (M) are performed by the testing company chosen by the MCA.
  • Nothing about the process, the treatment, logging and issuing of paperwork has changed from how we have always done it.
  • The only thing which has changed is we are now effectively controlled as well as audited by a private company and not the MCA.
  • Remember that all flag members of the REG expect all certificates to run concurrently with no gaps regardless of whether your vessel is in the yard or not.

What's Checked and Monitored?

The following areas of the flame retardancy process have been scrutinised to create a more rigid method of monitoring and approval:-

Products used for the flame retardancy treatment

Testing of the textiles once treated

Certified applicators of the product and their methods

Detailed documentation of the treatment process

Audit of service provider's Quality Manual and processes including audit of Licensed Applicators

Information on all certified personnel approved by the service providers

Vessel certification ideally valid for one year in accordance with MCA recommendations

In conclusion
The Approval Procedures and Declaration of Conformity provide equivalence to inherently fire retardant materials on-board vessels built under the Large Commercial Yacht Code, now known as the REG.
Also, they establish robust quality assurance procedures to allow approval of flame retardant treatments, products and their application.
 

Want to Know More About Flame Retardancy?

We can help you through the ins and outs of fire retardancy. Just get in touch and let's take it from there.

What Should You Look For in a Flame Retardancy Company?

You need to decide on a company who is not only professional but one that you trust.

Ask to see the chosen company's credentials, if they are certified for the task they will be happy to do so.

Find out about the product they apply. Check to make sure it doesn't contain any harmful chemicals.

The company should have the experience and wealth of knowledge to provide professional valuable advice as every yacht is different in style, shape and décor employing luxurious unusual fabrics and textiles which often will require professional cleaning prior to treatment.

Choose a company who you will enjoy working with - a company who show they want to work with you on a long term basis, remember this should be a regular process, with planned maintenance intervals.

Finally, choose a company whose emphasis is on quality, know-how, professionalism and extremely high levels of service, you don't want to entrust your prized possession and considerable asset with anyone less.

"With Flame Screen, I know I'm in safe hands. They have been so helpful with compliance questions."

Overview of the REG (Red Ensign Group)

 

The REG has been in the business of regulating yachts since 1997 when the first “Large Yacht Code” was published by the UK’s Maritime and Coastguard Agency (MCA).

Over the last 20 years, a lot has happened in the superyacht industry, including a huge increase in the size and complexity of yachts being built today, which has required an ever-changing regulatory framework to reflect the industry’s needs.

The Red Ensign Group Code consolidates an updated version of the Large Yacht Code (LY3) and the latest version of the Passenger Yacht Code (PYC) to better address the needs of the large yacht industry. The code further develops the well-established industry standards of the LY3 and the PYC, combining the lessons learned from 20 years of developing yacht codes.

Therefore, if you are currently flying a REG (Red Ensign Group) flag and are certified to any of the earlier versions of LY3 or PYC, then the new REG Yacht Code will be applicable.

Part A.

Is an updated version of LY3 and is now known as Part A, which continues to look after yachts which are 24Mtrs and over in load line length, are in commercial use for sport or pleasure, do not carry cargo and do not carry more than 12 passengers (not counting the crew).

Part B.

Is an updated version of the Passenger Yacht Code which is applicable to pleasure yachts of any size, in private use or engaged in trade, which carry more than 12 but not more than 36 passengers (not counting crew)  and which do not carry cargo.

This is like the Passenger Yacht Code 6th Edition but again will be called the REG.

New Vessel

Means a vessel, to which this new code applies, the keel of which was laid or was at a similar stage of construction on or after the 1st January 2019.

Existing Vessel

Means any vessel, the keel of which was laid or was at a similar stage of construction prior to the 1st January 2019.

Part A Points of Note:

The following should be used as a guide only to the major items that require physical change or purchasing of new equipment on-board, in preparation for REG Yacht Code Compliance for Part A Vessels and remember to always consult with your Flag Surveyor.

Where the major physical items that require changing can be found listed below, many of which may already have been updated, but the “soft “ side of compliance should not be overlooked or ignored.

  1. Recovery of persons from the water (although this can be a paperwork  exercise, some additional equipment or modifications may be required.
  2. Fire Protection Treatment for interior materials (under 500GT Vessels).
  3. Removal of fixed carbon dioxide fire extinguishing systems in machinery spaces.
  4. Carriage of intrinsically safe radios for fire fighters.
  5. Availability of Radio Equipment which may require duplication of equipment.
  6. Fitting of Bridge Navigationia Watch Alarm System (BNWAS).
  7. Fitting of ECDIS for vessels over 3,000GT.
  8. Carriage of portable atmosphere testing equipment for entry into enclosed spaces.
  9. Over-side Working Rails are to be tested and demonstrated compliant or are to be de-commissioned.

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