By Paul R. Nichols Lloyd’s Register August 2025 Navigating the minefield of regulations relating to marine interiors A report from Cruise & Ferry www.cruiseandferry.net
This report is written by Paul R. Nichols, Principal Specialist of Lloyd’s Register, for Cruise & Ferry. Views expressed in this report are solely those of the author. (c) 2025 Tudor Rose. All rights reserved. The regulations relating to materials within the ship are written by the International Maritime Organisation, (IMO), through the Safety Of Life At Sea Convention (SOLAS), supported by the Fire Test Procedure Code (FTP Code). Lloyd’s Register (LR) acts on behalf of over 120 countries in applying these regulations in the construction of ships around the world.
3 Any designer of interiors for cruise ships and ferries will be familiar with the aesthetic aspects which need to be considered. However, Paul Nichols of the marine classification society Lloyd’s Register points out that without the appropriate certification, even the best design won’t make the transition from drawing board to ship. As a young surveyor for Lloyd’s Register in the early 1990s there was a ro-ro passenger ferry moored across the quayside in Southampton, UK, named ‘Candi’. It never moved while I worked there, but I’d look out of the window of our office on Town Quay and wonder what it must have been like on that vessel when she sailed as the Scandinavian Star. As the Scandinavian Star, the ship caught fire in 1990 and 159 people lost their lives. The cause of the fire was arson, but irrespective of the cause it is a basic truth that if a fire occurs onboard a passenger ship then the consequences can be catastrophic and horrendous. Prior to the Scandinavian Star fire, ships such as the SS Moro Castle in 1934 and the MV Dara in 1961 also experienced tragic incidents involving fires causing considerable loss of life. Due to incidents such as these, legislators have acted to create a regulatory regime which acknowledges that fires are probably the major risk to passengers onboard ships. Onboard fire risk awareness is not new. When designing the SS United States in in the late 1940s, William Francis Gibbs was so concerned about the risk of fire that it is said that the only wood onboard was the butcher’s block in the galley and the Steinway piano in the lounge. It is understood that the world of maritime regulations may be unknown to most in the business of cruise and ferry interior design, but it could be crucial in getting a design accepted. This document therefore provides a brief guide to the rules affecting interior design and construction, in the hope that it may allow designers to understand the regulations and avoid the unfortunate situation where designs are rejected or need to be changed to comply. Navigating the minefield of regulations relating to marine interiors
4 The legislation scenario First, there is a globally accepted requirement which comes from the United Nations Convention of the Laws of the Sea (UNCLOS) that states that one of the duties of the flag state is to “effectively exercise its jurisdiction and control in administrative, technical and social matters over ships flying its flag”. In particular, each state must take measures for ships flying its flag to ensure safety at sea regarding construction, equipment and seaworthiness. Although this is a high level requirement and not detailed, it sets the foundation for a regulatory framework for safety. The UN has the IMO, as one of its specialised agencies responsible for the safety and security of shipping. The IMO is responsible for regulations in the maritime sector through various conventions, of which SOLAS is the most “ The IMO is responsible for regulations in the maritime sector through various conventions” The fire-damaged Scandinavian Star was renamed Candi and moored in Southampton in the early 1990s
5 relevant to interior designers. SOLAS covers many aspects such as stability, life saving appliances and fire. Designers should focus on the fire area. SOLAS is constantly reviewed and updated by various working groups and every so often the members of the IMO meet to discuss proposed amendments. This means designers should keep an eye on what changes are in the future and try to future-proof their designs where possible. Lloyd’s Register issues, twice yearly, a document highlighting future legislation which can be downloaded for free. The text within the SOLAS chapters is supported by various codes that detail some of the requirements. The primary codes affecting designers are the Fire Test Procedure Code (FTP Code) and the Fire Safety Systems Code (FSS Code). These international requirements are not applied on behalf of the UN or IMO. They are applied by the individual flag states through their legal systems. In the UK, this is through the Merchant Shipping Act, which says the UK applies SOLAS, and other countries have similar arrangements where their national legislation recognises SOLAS as their method of meeting their UNCLOS commitment. Within Europe there is a European Directive – the Marine Equipment Directive (MED) – also known as the ‘wheel mark’. This was a way to have an approval for an item which is accepted to the SOLAS requirements on behalf of one European flag to the SOLAS requirements accepted by other European flags. In the past, for a French flagged ship the French could look for French approval certificates, and for an Italian flag ship they would look for Italian certificates. This made it very expensive for suppliers looking to provide equipment to several European flagged vessels. However, with MED the French authorities would accept Italian certificates, as would any other European authority. Some non-European flags also accept certification through the MED, and there is a reciprocal arrangement with the United States Coast Guard. Now we know why there are rules and where they came from. Next we’ll look into how the rules are applied to the design of the ship, following the prescriptive rules within SOLAS and the supporting codes. Basically, SOLAS divides the ship into large chunks, then breaks those down to small spaces, then looks at what is in the spaces and limits how they are constructed.
6 What do we use to divide the ship up? Firstly, let us look at how we can divide the ship into more manageable parts to assist fire fighting, or more specifically what we use to divide the ship up. To divide the ship up there are three types of fire divisions used, which are all to be non-combustible, as follows: • A Class – Steel or equivalent and will stop smoke and flame for one hour • B Class – Will stop flame for 30 minutes • C Class – Won’t stop smoke of flame, but will not contribute to a fire. The A Class divisions are then divided into four types, depending on how long the division can control the temperature on the opposite side of the division. An A60 division will control the temperature on the opposite side below a certain limit for 60 minutes, where as an A15 division will only control the temperature for 15 minutes. The four types used are A60, A30, A15 and A0. The B Class divisions are divided into two types, depending on the temperature control. These are B15 or B0, where B15 will stop flame for 30 minutes and control the temperature on the opposite side for 15 minutes, whereas the B0 will simply stop the flame but not control the temperature. The C Class divisions will not stop flame, smoke or control temperature and their only main requirement is to be non-combustible. The full definitions of these types of divisions are within SOLAS, Chapter 2-II, Regulation 3 and how these should be tested to show their characteristics are included within the FTP Code. Dividing the ship into large chunks Now we have division types defined, we can begin to divide the ship into large chunks at first then smaller spaces of similar types. SOLAS, Chapter 2-II, Regulation 9.2 divides the ship into vertical Main Fire Zones (MFZ), which are up to 48 metres in length and bounded by MFZ bulkheads that are designed to prevent a fire crossing the boundary. Many of the ship’s systems and arrangements are required to be designed taking the MFZ into consideration. For example, ventilation, escapes, lighting and firefighting systems will be designed to serve particular fire zones. The MFZ 2 HVAC system will be separate from the MFZ 4 HVAC system, etc. These MFZ bulkheads will be A60 in most areas, unless certain criteria are met.
7 Dividing the ship into smaller spaces Within the MFZ, there will be many different types of space – cabins, staircases, corridors, laundries, galleys, shops, cinemas, main machinery spaces for example, and all these spaces have their own characteristics in terms of risk and importance to the ship. SOLAS Chapter 2-II, Regulation 9 grouped together similar spaces into 14 categories as below. Dividing the ship into these spaces SOLAS then looked at the individual spaces and their proximity to other spaces within the fire zone. It considers whether the boundary between two spaces should be A60 – which is the highest level of protection – or only C class, the lowest level of division. Some spaces, such as the wheelhouse, are important to the ship, so should be protected from others. Other spaces may be higher risk, therefore the surrounding spaces should be protected from those high-risk spaces. This is the basis of the logic deciding the types of division between spaces. It considered that there’s a difference between spaces which are horizontally adjacent or vertically adjacent. For instance, a galley is a higher fire risk space. Consequently, positioning the escape route above the galley increases the risk to those escaping than having the escape route below the galley, as fire generally moves up rather than down. Category number Category name 1 Control stations 2 Stairways 3 Corridors 4 Evacuation stations and eternal escape routes 5 Open desk spaces 6 Accommodation spaces of minor fire risk 7 Accommodation spaces of moderate fire risk 8 Accommodation spaces of greater fire risk 9 Sanitary and similar spaces 10 Tanks, voids and auxiliary machinery spaces having little or no fire risk 11 Auxiliary machinery spaces, cargo spaces, cargo and other oil tanks and similar spaces of moderate fire risk 12 Machinery spaces and main galleys 13 Store-rooms, workshops, pantries, etc. 14 Other spaces in which flammable liquids are stowed
8 Therefore, the insulation of the galley deckhead to the escape route would be A60, but an escape under a galley would only have A0 division. Limiting the fire load inside these spaces Now that we have the ship divided up between the different types of space, we can now look at the interiors of the individual spaces. Within these spaces there will be all the things that the people onboard can see, such as the internal linings, furniture, ceilings and flooring. For two categories of space, there are limits on the construction of furniture. In a category 6 space, only furniture and furnishings of restricted fire risk are permitted. However, in a category 7 space, the cabin may contain furniture and furnishings that are not of restricted fire risk. Similarly, a category 7 large public space should contain furniture and furnishings of restricted fire risk, but a category 8 large public space would have no similar restriction. For passengers and crew, a category 6 cabin would not be aesthetically pleasing if all furniture was non-combustible, so these end up as category 7 spaces. The only places where furniture is specifically addressed is for cabin balconies and for stairway enclosures, as required by Regulation 5 of Chapter 2-II of SOLAS, which also requires the construction of all linings, grounds, draught stops and ceilings to be of non-combustible material except in mail rooms, baggage rooms, saunas or refrigerated compartments of service spaces. Within these linings and beneath the ceilings is the space visible to passengers and crew. Many surfaces have limitations, and SOLAS Chapter 2-II, Regulation 6 evaluates their ability to produce smoke and toxic fumes. Paints, varnishes and other finishes used on exposed interior surfaces must not create excessive quantities of smoke and toxic products, in accordance with the FTP Code. This also applies to exposed surfaces of cabin balconies, excluding natural hard wood decking systems. Primary deck coverings installed within accommodation, service spaces, control stations and on cabin balconies must be made of approved materials. These “ Paints, varnishes and other finishes used on exposed interior surfaces must not create excessive quantities of smoke and toxic products”
9 materials should not produce smoke or toxic or explosive hazards at elevated temperatures, as determined by the FTP Code. To prevent the spread of fire should there be an ignition source, SOLAS requires that the following exposed surfaces shall have low flame-spread characteristics: • Exposed surfaces in corridors and stairway enclosures and of bulkhead and ceiling linings in accommodation and service spaces (except saunas) and control stations • Surfaces and grounds in concealed or inaccessible spaces in accommodation and service spaces and control stations • Exposed surfaces of cabin balconies, except for natural hard wood decking systems. Wooden grounds found in a public space, requiring removal
10 The visible surfaces of the panels may have a certain amount of combustible material attached. If the area of the four bulkheads and the ceiling is calculated then multiplied by 2.5mm, this will give a volume of combustible material which may be attached to the lining. Materials permitted to be attached to the linings and ceilings within the space must have a limited calorific value, meaning they should not be highly flammable and have an energy of no more than 45 MJ/m2 of the area for the thickness used. This requirement does not apply to the surfaces of furniture fixed to linings or bulkheads. Just as a chain is only as strong as the weakest link, the same is true of fire divisions. Their effectiveness is determined by the quality of construction and, more importantly, how the divisions are respected where there are openings or passages in the divisions. Cables, pipes, ventilation ducts, doors and windows are often passed through bulkheads and decks. Therefore care should be taken to ensure that the fire category of the division is maintained by using approved penetrations, dampers and doors, for example. Behind the linings To construct the various spaces onboard, many B Class bulkheads do not go from the deck to deck, they go from deck to ceiling. This creates large areas behind panels and ceilings that could be troublesome should a fire break out behind the linings, as smoke could develop and spread for many metres before entering the space below. This could result in the smoke detection system being activated and result in the fire team searching in the wrong area for the fire. To Illustration of the surfaces considered for Fire Load Calculation Space Area of bhd and ceiling (A)
11 prevent this, spaces behind linings and ceilings are divided up by draught stops which are placed at a maximum of 14 metres apart and at each deck level in multi-deck spaces. These must be non-combustible and mechanically fixed to the ship structure. Additional requirements on ro-ro passenger vessels When selecting bulkhead panels or linings on ro-ro passenger vessels, there are SOLAS requirements relating to the strength of the handrails and corridors. Handrails must be provided in corridors along the entire escape route so that a firm handhold is available at every step of the way, where possible, to the assembly stations and embarkation stations. They should be able to withstand a distributed horizontal load of 750 N/m applied in the direction of the centre of the corridor or space, and a distributed vertical load of 750 N/m applied in the downward direction. The two loads need not be applied simultaneously. Additionally, the lowest 0.5 metres of bulkheads and partitions forming vertical divisions along escape routes, must be able to sustain a load of 750 N/m to be used as walking surfaces from the side of the escape route with the ship at large Escape route load requirements
12 angles of heel. Corridor panels, handrails and their fixings will need testing during construction. If the handrail pulls out of the panel, the choice of panel or the fixings may be inappropriate and require replacement, which can be costly. This requirement applies only to ro-pax vessels, so confirm that panels were used on ro-pax ships, not cruise ships, as tests differ. Alternative design and arrangements (AD&A) There is a regulation within SOLAS Chapter 2-II Regulation 17 which allows the use of alternatives to the standard prescriptive rules for fire safety. For example, the prescriptive limit on MFZ length may be exceeded if the designer can demonstrate that the larger MFZ has the same level of safety as the prescriptive regulations. The regulation outlines the procedure to be followed to use an alternative design or arrangement to the prescriptive rules and it can benefit the designer. To illustrate the potential benefits of using AD&A, consider a ship which is 156 metres long. With the 48 metre limit of MFZ, the ship would need four MFZs, each about 39 metres. Each MFZ has staircases, HVAC stations, etc. which all take up space. By using AD&A, the vessel could have three MFZs – two at 48 metres and one at 60 metres long. If the design with the 60m fire zone can be shown to be at least equally as safe as the prescriptive solution, it may be accepted. The initial cost of the alternative design may be higher compared to a purely prescriptive solution; however, the benefits such as increased space for cabins or shops, or simply an increase in the available volume per passenger, may be considered positive for the operator. Sustainability With any construction in the 21st century, the sustainability of the build needs to be considered. For shipping, there are the Hong Kong International Convention For The Safe And Environmentally Sound Recycling of Ships and the EU Ship Recycling Regulation, which mean any hazardous materials used in the vessel need to be identified and records kept throughout the ship’s life. To do this, suppliers should identify and declare whether or not certain materials are present above specific limits. Lloyd’s Register’s ship recycling experts can assist suppliers, shipyards and operators in the application of these regulations. How to implement these rules? The usual passenger ship case is that the ship builder subcontracts a significant amount of the outfitting of the vessel to different suppliers looking after specific
13 spaces. One supplier may provide accommodation spaces with cabins and corridors, with others providing public spaces such as theatres, atria, restaurants and galleys. To ensure compliance with the regulations, early communication between all parties is essential. When a space is allocated to a subcontractor, it’s best to hold a meeting with the builder, subcontractor and flag (or recognised organisation such as the classification society) to discuss drawings and fire load calculations. A Lloyd’s Register surveyor verifying the material of a bulkhead lining panel
14 The subcontractor should present their design, materials, arrangements and certificates. Discussions should cover flooring, panels and mounted items to ensure they meet regulations. Unusual designs should be reviewed and agreed upon in advance. For instance, a bulkhead with 15 different types of leather covering it may need 15 certificates for smoke and toxicity and low flame spread capabilities. Through life These documents and certificates are important during construction but must be kept for the life of the ship. This is because if the owner wants to refurbish in 5, 10, 15 years, they will need accurate records. For example, if a bar area in an atrium is to be replaced by a seating area then fire load calculations for the bar must be updated to reflect the new seating area. Without access to the original calculations for the refurbishment, the designer would have to recreate the original documents, referencing all materials and certificates, and then adjust them for the new arrangement, which would be a lot of work. Similarly, the documentation for ship recycling must be maintained until the ship is scrapped. In summary Within these notes we have examined the origin of the rules and their implementation. We have divided the ship into large sections called fire zones, which are then divided into smaller spaces. The various types of divisions used, their materials and their surface requirements regarding low flame spread, fire load, smoke and toxic fume generation have been discussed. It’s been noted that division types should be maintained where there are penetrations or passages. Additionally, the possibility of using alternatives to the prescriptive regulations has been highlighted.
15 This report focuses solely on the passive fire protection of the ship, which do not require any electrical, mechanical or piping systems. Active fire protection systems, such as sprinklers and smoke detection, are not considered here and warrant a separate disucssion. Lloyd’s Register has specialists dealing with all of the aforementioned topics, whether it is the original Type Approval of materials, approval of Structural Fire Protection Plans and Fire Load Calculations in newbuild or the recycling requirements. Lloyd’s Register helps suppliers, designers, builders or operators navigate through the minefield of statutory legislation relating to marine interiors. For support, visit www.lr.org
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