Commodore Clipper - Marine Accident Investigation Branch

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If it is accepted that a fire in a special category space might not be extinguished
while the vessel is at sea, then a means of disembarking passengers and crew with
a minimum risk of injury should be provided once the vessel has berthed. Although
lifeboats and marine evacuation systems can be used when a vessel is alongside, in
principle it should be safer to allow passengers to walk (or be assisted) ashore via a
gangway.
The 2008 and 2009 amendments to SOLAS address this issue and the addition
of Regulation 3.9 to Chapter II-1 requires that a means of embarkation and
disembarkation for use in port is provided. However, this only applies to vessels
constructed after 1 January 2010, and there is no requirement for there to be
a protected route from the assembly station to the point of disembarkation. On
existing ro-ro passenger ferries where this regulation does not apply, it would be
good practice for operators to consider how they might disembark pedestrians
under the requirements of the International Safety Management 25 Code to establish
emergency operating procedures.
2.9 FIRE-FIGHTING TACTICS
2.9.1 Access to the seat of the fire
All ferry operators need to carry the maximum amount of cargo in their vessels to
make voyages economically successful, and there are no regulations that specify
a minimum distance between each vehicle. In practice, access routes between
vehicles are only maintained where crew have to reach equipment, or where
passengers need to get out of their cars. The issue becomes most acute with
unaccompanied freight trailers that are loaded by stevedores and lashed down
by the crew. Crew are expected to be able to move under the trailer load-beds
and through narrower gaps than would be expected of passengers. The distance
between trailers on the main vehicle deck of Commodore Clipper was generally in
the order of 150-450mm and in some cases, adjacent trailers were nearly touching.
This density of trailers encourages higher rates of fire growth and reduces the
effectiveness of fixed drencher systems and portable fire-fighting equipment.
Crew and firefighters saw water from the drencher system bouncing off the roofs of
the trailers and running down their sides, while the cargo continued to burn inside,
sheltered, yet ventilated through the damaged curtain-sides. Moving around the
main vehicle deck was very difficult in normal circumstances and became far worse
when wearing BA. Similarly, man-handling a charged fire hose in between trailers to
direct water onto fires set deep inside trailers was also extremely challenging. All this
was made harder by the low visibility, cargo debris and chain lashings.
Effective access could only be gained from the stern ramp, and ventilation was
needed to maintain adequate visibility. HFRS officers accepted that this would
increase the intensity of the fire and, although they attempted to mitigate this, they
were unable to prevent it completely. If this method of attacking the fire is to be
used, it must be expected that the fire will intensify before it is brought under control.
The potential risk to any passengers on board will increase during this period and it
would be preferable to evacuate all non-essential personnel before attacking the fire
in this way.
Balancing the priorities of evacuating passengers and creating access to fight the
fire requires a thorough understanding of the constraints of the vessel’s layout and
the time needed to extinguish a fire of this type.
25 ISM Code, 2010 edition, section 8, emergency preparedness