The Office of Design and Engineering Standards (CG-ENG) has issued Policy Letter 05-25, Acceptance of Aluminum Flammable Liquid Storage Cabinets on Weather Decks Of Inspected Towing Vessels.
This policy letter provides national guidance for use of aluminum flammable liquid storage cabinets on towing vessels per 46 CFR 136.115, as an equivalent level of safety to the steel cabinet requirements of 46 CFR 142.225 (Lockers authorized within 46 CFR 142.225 are still the preferred standard.). In coordination, the Office of Commercial Vessel Compliance (CG-CVC) has published an update to CG CVC-WI-010(4) OCMI Guidance on Special Consideration for 46 CFR Subchapter M Vessels and removed the section “Storage of flammable/combustible products” in the enclosure to align HQ Policy directives.
If an OCMI issued a Special Consideration for Flammable lockers for an inspected towing vessel, the COI and special note for the equivalency must be updated to reflect the CG-ENG policy letter and the allowance as an equivalency under 46 CFR §136.115, NOT a special consideration under 46 CFR §136.120 at the next CG attendance and/or administrative review.
Approvals for equivalencies outside of the criteria in CG-ENG Policy Letter 05-25 must be sent to CG-ENG. Additionally, the equivalency for use of flammable liquid storage cabinets outside of the §142.225 standard is restricted to domestic voyages only.
A complete list of ENG Policy Letters can be found at the following link: https://www.dco.uscg.mil/ENG/Policy/
A complete list of CVC Policy Letters and Work Instructions can be found at the following link: https://www.dco.uscg.mil/CG-CVC/
For any questions regarding the policy, please contact CGENG@uscg.mil. For any questions regarding implementation of 46 CFR Subchapter M on your vessel, please seek advice from your local Officer in Charge, Marine inspections. For any questions regarding the work instruction, please contact CGCVC@uscg.mil.
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