Bill Lucas

IMO FSS Code Ch 5 Sec 2.2.2 requires two controls to active co2 flooding systems and provides for the use of a lock box to prevent accidental activation of the flooding system. Use of the lock box and key is a readily available off the shelf system which will provide protection from unintended activation of flooding systems. Use of this type of protection will lessen the burden on owners and operators of existing systems as some will already comply. Other systems which do not can be easily retro fit by existing vendors who are already familiar with the lock box. Cutting into existing systems to install valves will be costly. It will also be difficult to define a place for these valves in systems which were not designed to have them. Often real estate on vessel can be difficult to find for the retro fit of things even as simple as a single valve. As the lock box is designed to work with an existing system controls it will be easier to install and maintain.