MARINE Reports - 2001 - M01M0017

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Analysis

Fire Fighting Resources - Halifax Harbour

The CFAV Firebird is a DND asset and is not considered a first line fire response for Halifax Harbour. While there is no formal arrangement with the Halifax Regional Municipality or the port authority for the use of the fire tug, the CFAV Firebird is available for SAR and humanitarian assistance cases as tasked by the JRCC and subject to the boat's availability given other high priority military-related activities or maintenance.

The CCG does not normally have a fire fighting capability available in Halifax Harbour. The CCG, either through the JRCC or the Regional Operations Centre, contract or task other government agencies or private salvage companies to render this service in order to save lives or prevent pollution. In the case of commercial companies, there is currently no standing-offer for this service. Instead, negotiations for a vessel of opportunity are made at the time of the incident.

The HRM Fire Service, in addition to its primary role as a municipal fire department, is also available to fight any shipboard fire as long as the vessel is secured alongside. The department is not trained in shipboard fire fighting and damage control and would treat any vessel fire as a structure fire.

Engineering Analysis - GC IPH Activated Carbon Pellets

During, and immediately after the occurrence, the question was raised as to whether the GC IPH activated carbon pellets which were shipped as an undeclared cargo should have been classified as dangerous goods under the International Maritime Dangerous Goods (IMDG) Code. According to present regulations, products containing activated carbon or potassium hydroxide may be considered dangerous goods if they meet certain prescribed criteria.

In order to determine whether the GC IPH activated carbon pellets met any of the prescribed criteria, a sample of the product was collected and sent to the TSB Engineering Branch for analysis. There, a battery of tests was carried out on the product which included a chemical analysis, a United Nations (UN) H.4 heat accumulation test, a UN N.1 test for readily combustible solids, a UN N.4 test for self-heating substances, a Corrositex^® test to evaluate corrosive potential and an ad hoc heat rise test. On completion of the analysis and testing of the GC IPH activated carbon pellets, TSB Engineering Report LP 037/2001 yielded the following conclusions:

1. The results of the chemical analysis were consistent with the information supplied in the manufacturer's material safety data sheet (MSDS).
2. The results of the UN N.1 test for readily combustible solids were not consistent with a Class 4.1 dangerous goods classification.
3. The results of the UN N.4 test for self-heating substances were consistent with a classification of Class 4.2 (substances liable to spontaneous combustion), Packing Group III, when transported in packages with a volume of more than 3m³.
4. The result of the Corrositex^® test was not consistent with a Class 8 dangerous goods classification.
5. The temperature rises witnessed in the ad hoc heat rise test were not high enough to produce ignition in themselves. However, given that the GC IPH was self-heating, any increase in heat may have contributed to the likelihood of a fire.

Source of the Fire

At the outset of the occurrence, the container containing the GC IPH activated carbon pellets was identified as the only unit indicating signs of smoke and extreme heat. In addition glowing carbon pellets were observed falling from the wooden bottom of the container onto another container directly below. A preliminary boundary survey of all the adjacent containers revealed no abnormalities. The container with the activated carbon pellets was the source of the fire.

Source of Ignition

As the cargo of activated carbon pellets in container 301184 was either consumed by the fire or washed/jettisoned overboard during the firefighting efforts, the source of ignition could not be determined.

Findings as to Causes and Contributing Factors

1. The source of the fire was container 301184 which contained a cargo of GC IPH activated carbon pellets.
2. The source of ignition of the fire could not be determined.

Findings as to Risk

1. At present, there is no dedicated fire fighting resource available to commercial vessels which are in Halifax Harbour or its approaches, but not alongside a quay or wharf.
2. Commercial salvage vessels with firefighting capability are generally on station in Halifax Harbour, however, their availability is not guaranteed.
3. Firefighters of the Halifax Regional Municipal (HRM) Fire Service are not presently trained or equipped to respond to shipboard fires while the vessel is in the stream.
4. There is presently no formal agreement between HRM and the Department of National Defence for mutual aid in the event of an emergency.
5. In spite of the fact that the carbon pellets showed signs of self heating, they were not required to be classified as a Class 4.2, Packing Group III cargo, because they were transported in packages with a volume of not more than 3 m³.

Safety Action

Advisory on Marine Firefighting

Further to TSB recommendations 96-06, and 96-07 on shore-based marine firefighting, in March 2002, the TSB sent Marine Safety Advisory No 05-02 to Transport Canada (TC), noting the continuing risks posed by the disparities in the readiness of shore-based firefighters to respond to shipboard fires. The advisory further suggested that TC, in cooperation with federal, provincial and municipal agencies, may wish to take further action to ensure that firefighters located in municipalities contiguous to port and seaway facilities in Canada are trained and equipped to effectively respond to shipboard fires.

Safety Action Taken by Transport Canada

In the fall of 2000, the Port Programs and Divestiture group of TC requested the Regions to ensure that international shore connectors were made available at all TC public port facilities. At the same time, it was pointed out that all public port and public port facilities emergency plans should be in place. In addition to these two initiatives, it was also suggested that regional port representatives encourage local fire departments to conduct site visits to public port facilities. These site visits were to include the familiarization of ships using TC facilities and stopping at Canadian public ports.

TC Ports and Harbours started an awareness program for firefighters who may be called to public ports in case of fire onboard ships. To date, TC's consultant has visited the Atlantic, Ontario and Pacific Regions. Presentations have been given at 31 ports/communities. Also, in these regions, there are presently emergency plans in place at 37 public ports/public ports facilities. The department has also made available, in these three regions, 77 international shore connectors for use by local fire departments during shipboard fires. Twelve emergency plans are in place in the Quebec Region and awareness discussions with fire and town officials were conducted. There are 12 locations with international shore connectors available for use by firefighters in this region.

In October 2002, the Association of Canadian Port Authorities held an operations seminar in Prince Rupert, British Columbia. A particular presentation entitled "Firefighting and Emergency Response in a Port" emphasized how a shipboard fire can be a very serious risk to port operations, that municipal crews are untrained in fighting such fires, and that there is a need for pre-incident coordination.

Safety Concern

The Board noted previously in its report into the explosion and fire aboard the tanker Petrolab that only the larger Canadian ports have the physical and human resources to prepare for emergencies and that small local ports administered by TC and Fisheries and Oceans Canada - or those divested to the provinces or municipalities - do not have adequate resources to ensure emergency preparedness.

As for the divested ports, the onus is on the new owner/operator to ensure that they have what they need to operate safely and remain an ongoing viable entity. TC does not maintain physical or regulatory supervision over divested sites/facilities to ensure compliance by the new entity with the safety provisions of acts and regulations administered under its authority. As such, there are no provisions for enforcement of safety measures nor for safety audits of divested facilities.

Canadian port and harbour authorities continue to lack the proper facilities and resources to effectively contain shipboard fires occurring within their ports/harbours. Consequently, the Board recommended that TC conduct a special audit of fire-fighting facilities at Canadian ports and harbours under its jurisdiction (Recommendation M96-06) and that it, in collaboration with port and harbour authorities, take measures to ensure that shore-based fire brigades expected to support on-board fire-fighting, receive appropriate training (Recommendation M96-07).

In response to the recommendations , the Canadian Association of Fire Chiefs (CAFC), with the aid of TC, circulated a short questionnaire to assess the firefighting capabilities of municipal fire departments responsible for fighting fires in Canadian ports. In July 1998, the CAFC received a limited response to the survey questionnaire and found the answers poor and relatively insignificant. Most of the municipal fire departments surveyed are not members of the CAFC and did not feel compelled to respond. However, the CAFC found that the survey provided enough information to raise concerns that the firefighting services available in municipalities with public ports may not be adequate to provide firefighting services in the event of a fire on board a vessel.

In an accident involving a fire aboard the bulk carrier Windoc in the Seaway, one of the Board's findings was that "the responding fire department's lack of training and experience for fighting shipboard fires, the lack of equipment to access the vessel, and the non-accessibility of fire control plans hindered an effective firefighting response".

As a result of the Association of Canadian Port Authorities (ACPA) October 2002 operations seminar, it was agreed that, with the assistance of the port authorities, TC would develop a survey in conjunction with the CAFC. The purpose of the survey will be to get a better understanding of the number of fire departments that may be involved in responding to fires in ACPA ports (of which there are twenty) and TC administered ports, as well as their training and experience with shipboard fires. The survey is expected to be distributed and completed by September 2003.

While it is noted that some municipalities, such as those along the Welland Canal, and cities, such as Québec, Quebec, and Vancouver, British Columbia, have provided some training in shipboard firefighting to their firefighters, the Board is not aware of any standards that would ensure consistency of training. There are fire departments in other municipalities and cities who may be called upon to provide firefighting services within ports but have not been provided the training. The ports of Halifax, Nova Scotia and St. John's, Newfoundland, for example, have no trained shipboard firefighting services available to immediately respond to a shipboard fire within their ports.

The United States (US) National Fire Protection Association (NFPA) has developed the Guide for Land-Based firefighters Who Respond to Marine Fires (NFPA 1405, 2001 edition). The guide identifies the elements of a comprehensive firefighting response program and includes training considerations. Although the practices in the guide apply to vessels that call at US ports, they also apply to vessels subject to the requirements of the International Convention for the Safety of Life at Sea (SOLAS). Although information contained in the guide may have been used by some fire departments, many more fire departments are unaware of the existence of the guide.

Work is currently underway within the NFPA to develop standards for professional qualifications for marine firefighting for land-based firefighters. It is anticipated that the proposed standard will be approved in about two and one-half years.

The Board acknowledges the positive actions taken by TC and others to promote firefighting awareness and preparedness for responding to shipboard fires at public ports and public port facilities. However, the Board also notes that there are many other 'non-public' ports within Canada and that TC is continuing to transfer operational control and to divest itself of most of its ports to not-for-profit organizations, provincial and local governments, community interests or private businesses. As of the end of March 2003, 64 sites were transferred to other federal departments, 40 sites were transferred to provincial governments and 109 sites were divested to local interests - 71 regional/local ports remained under the purview of the department.

Given the continuing disparities in the readiness of shore-based firefighters to respond to shipboard fires and the limited actions taken by TC and others to address the inadequacy of responses by shore-based firefighters to recent shipboard fires, the Board is concerned that the lack of attention being given to the special requirements of shipboard firefighting at Canadian ports will continue to result in less-than-adequate firefighting responses, thereby increasing the risk of personal injury and damage to property.

This report concludes the Transportation Safety Board's investigation into this occurrence. Consequently, the Board authorized the release of this report on 28 January 2003.

Appendix A - Sketch of the Occurrence Area

Appendix B - Container Stack : Bay 30

Appendix C - List of Supporting Reports

The following TSB Engineering Branch Report was completed:

LP 037/2001 - Testing of Cargo Samples - MV Kitano.

This report is available from the Transportation Safety Board of Canada upon request.

Appendix D - Glossary

AST		Atlantic standard time
CAFC		Canadian Association of Fire Chiefs
CCGC		Canadian Coast Guard Cutter
CCGS		Canadian Coast Guard Ship
CFAV		Canadian Forces Auxiliary Vessel
DND		Department of National Defence
EMO		Emergency Measures Organization
HMCS		Her Majesty's Canadian Ship
HRM		Halifax Regional Municipality
IMDG		International Maritime Dangerous Goods Code
JRCC		Joint Rescue Co-ordination Centre
LOF		Lloyds Open Form 2000
m3		Cubic metre
MSDS		Material Safety Data Sheet
SAR		Search and rescue
TEU		Twenty Foot Equivalent Unit
TSB		Transportation Safety Board of Canada
UN		United Nations
VCS		Halifax Coast Guard Radio
VTS		Halifax Vessel Traffic System

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1. See Glossary at Appendix D for all acronyms and abbreviations.

2. All times are Atlantic standard time (Coordinated Universal Time minus four hours).

3. In this report, containers are identified by bay number, see Appendix B for reference.

4. LOF 2000 - Lloyd's Standard Form of Salvage Agreement. A form of salvage contract approved and published by the Council of Lloyd's. The acronym "LOF" derives from the former name of the Agreement ("Lloyd's Open Form"). LOF 2000 provides for salvage services to be rendered on the principle of "no cure - no pay".

5. H.M. Griffith TSB Report M95C0033;
Ambassador TSB Report M94M0057;
Fraser Princess TSB Report M97W0035
Sha 122 TSB Report M97W0044;
Petrolab TSB Report M97N0099;
Western Viking TSB Report M97W0194;
Southgate TSB Report M98L0139;
Canadian Transport TSB Occurrence M01C0032; and
Windoc TSB Report M01C0054.

6. TSB Report M97N0099.