Guidance 13

G1    Escape panels in doors

G1.1    It is generally considered that escape panels in 'B' Class doors are unnecessary. However they may be fitted if an owner requires them. In such cases the panels should be constructed in accordance with any details shown on the approved drawings, provided they do not exceed 410mm x 410mm in size. A ventilation opening, when fitted, should be incorporated in the escape panel. Where no details of an escape panel are given the door manufacturer should be requested to submit details of the construction to MCA Headquarters for consideration before use.

G1.2    Escape panels should only be capable of being operated from that side of the door from which a person needs to escape and should be of such a design as to preserve the integrity and insulation standard of the door and prevent any unlawful entry into a space.

G1.3    Escape panels should be marked with the words 'ESCAPE PANEL - KICK OUT' in white letters on a green background.

G2    Locks in doors

G2.1    Every 'B' Class door fitted in a cabin bulkhead should be capable, when locked, of being opened manually from the cabin side other than by means of the key or key card.

G2.2    Any 'B' Class door, other than a cabin door, which is fitted to an opening forming part of an escape route should not be capable of being locked shut, except that when such a door is required to be locked shut by the owner for security reasons keys should be provided on each side of the door in glass fronted boxes fitted close to the door.

G2.3    Alternatively a door which is unlocked in the escape direction may be 'access controlled' subject to suitable safeguards. Digital locks for which the access code is known to appropriate crew members, may be accepted on such doors. (See also specific guidance G13.11 on "doors in crew accommodation").

G3    General requirements - applicable to all ships

G3.1    The general requirements apply to the escape arrangements of all ships - passenger ships, cargo ships and tankers - except where specifically indicated otherwise.

G4    Stairways and ladderways

G4.1    The width is to be measured on the tread within the sides or between the handrails, whichever is the least.

G4.2    Stairways should not extend in a single flight more than one 'tweendeck or a vertical distance of 3.5m whichever is the least. Stairways in adjacent 'tweendecks within the same enclosure should, wherever possible, be offset if sloping in the same direction or slope in different directions.

G4.3    In either case, the stairways should be separated by a landing having its shorter dimension not less than the width of the wider stairway. However when it is only possible to arrange such stairways to slope in the same direction without being offset, they should be separated by a landing having a length not less than 2m.

G4.4    Curved stairways should be such that they do not present a hazard to passengers and crew. It should be borne in mind that such stairways may be used in an emergency situation by both elderly and very young passengers (see also guidance G13.15.2 at the end of paragraph 3).

G4.5    Nosings on treads should be kept to minimum dimensions in order to reduce the risk of passengers and crew tripping over them and should be of the same sectional shape on all treads of a stairway.

G4.6    Stairways and ladderways should be fitted on each side with an efficient handrail, which in the case of stairways should be continued unbroken from the slope of the stairway round each landing to the entrance to the stairway enclosure or connected to the handrails in the corridor whenever the Regulations permit a stairway to be open to the corridor.

G4.7    Stairways and ladderways should, as far as possible, be pitched fore and aft, not athwartships, and should normally be inclined at not less than 45º to the vertical.

G4.8    In general the rise of each step should be kept constant to facilitate easy movement up (or down) the stairway, especially in an emergency situation.

G5    Corridors and doorways

G5.1    Corridors and doorways providing access to and from stairways or open decks should be of sufficient width to prevent congestion and, in the case of those serving stairways, should not be less than the width of the stairways.

G5.2    Handrails should be fitted in corridors at an approximate height of 1000mm above the deck.

G5.3    The width of a corridor should be measured between handrails or the handrail and the opposite bulkhead whichever is applicable.

G6    Escalators

G6.1    Escalators may be treated as stationary stairways for the purpose of this Regulation. (In such cases the surveyor should ensure that adequate deck area is provided in the enclosure at each end of the escalator in order to avoid any congestion. In addition the doors in the enclosure bulkheads should be wide enough to permit passengers to disperse quickly. Due regard should be paid to the design and positioning of the controls so as to reduce the risk of their unauthorised use. The emergency stop controls should however be in positions readily accessible from the escalator).

G7    Hatches

G7.1    Where hatches are provided as the second means of escape for crew from accommodation spaces, the hatches should be of such dimensions as will allow a person to escape wearing a lifejacket.

G7.2    Any hatch provided for escape from crew accommodation or working spaces should not be capable of being locked and should be operable from below and above. It is preferable for such a hatch to be provided with a counter-balance weight for ease of opening. Access to the hatch should be by means of a fixed steel ladder.

G7.3    The surveyor should ensure that escape hatches are so sited that they cannot be overstowed with deck cargo or stores or, in the case of spaces below a special category space or Ro-Ro cargo space, that vehicles cannot be parked over them or prevent them from being opened fully. In some cases it may be necessary to site the hatches on raised kerbs or be protected by substantial stanchions and rails. In no case should painted lines be accepted as the means of protecting such hatches.

G7.4    When the hatches are fitted in 'A' Class or 'B' Class decks, their construction should be such that the integrity and insulation standards of the decks are not impaired.*

G8    Escape panels

G8.1    In certain instances, 'escape panels' may be used with advantage to provide an alternative means of escape. However, in no case should an escape route incorporate more than one escape panel.

G8.2    An 'escape panel' should be fitted so that it can be kicked-out with the minimum of effort and should be clearly marked to indicate its purpose. Where an escape panel is utilised to provide an escape to another compartment, the surveyor should ensure that the door to that compartment opens onto a corridor and is capable of being opened from inside at all times.

G8.3    Escape panels should not be fitted in any escape route providing access for passengers to the muster stations or lifeboat, liferaft and marine escape system embarkation positions.

G8.4    Escape panels should not be fitted in 'A' Class bulkheads or doors and when they are fitted in 'B' Class bulkheads or doors their construction should be such that the integrity and insulation standards of the bulkheads and doors are not impaired.

G9    Sleeping rooms in crew accommodation

G9.1    It is necessary to provide an emergency means of escape from sleeping rooms where access to such a sleeping room is by way of a dayroom, there being no direct access by means of a door to the sleeping room from a corridor. Ideally the crew accommodation should be designed so that a sleeping room is so positioned that an emergency escape therefrom is not required. However, where there is a need to provide an emergency escape from a sleeping room, this should be achieved by fitting a clearly marked escape panel to an adjacent room or corridor as indicated in the previous paragraphs on "escape panels" or, where this is not possible, by an escape window or sidescuttle as indicated in guidance G13.14 to paragraph 3.

G9.2    Where a dayroom is fitted with a smoke detector as part of an approved 'fixed fire detection and fire alarm system' a second means of escape will not be required.

G10    Crew messrooms, recreation rooms etc.

G10.1    When messrooms, recreation rooms, cinemas, television rooms and similar communal spaces are provided to accommodate more than 15 crew members at any one time, such spaces in general should have two doors to the adjacent corridor. In cases where this is not possible, in addition to the provision of a door to the corridor, a door to the open deck should be provided, or if this is also not possible, an escape window or sidescuttle may be accepted as indicated in guidance G13.14 to paragraph 3.

G11    Doors in crew accommodation

G11.1    In general, all doors which are not type approved should be of the hinged type. Where it is not practicable to provide a hinged door, a sliding door may be accepted provided that in the case of a 'C' Class door it can be readily removed from its rails from each side of the door or an escape panel is fitted in the sliding door.

G11.2    Doors in an escape route should not normally be locked closed. However, doors which give access to 'sensitive areas' may be locked for security purposes, provided the surveyor is satisfied that the escape routes will remain viable.

Guidance 13

G12    Construction and insulation

G12.1    The stiles, treads, risers and, if fitted, backing plates of stairways should be constructed of steel except that they may be constructed of aluminium alloy, suitably insulated, when the structure is of aluminium alloy. Stairway enclosures constructed of steel which are required by the tables in regulation 9 to be insulated, may be insulated on either side but when the enclosures are insulated on the inside, measures should be taken to prevent heat transmission through the divisions in way of decks, landings etc.

G13    Public rooms used for concerts etc.

G13.1    When a public room in a passenger ship (any class) is to be used for concerts, cinema shows etc., and lighting is to be subdued, the illuminated signs marking the exits should be in white lettering approx. 180mm high on a green background. Each door which does not afford a safe escape from the space should be provided with an illuminated sign indicating 'NO EXIT' in white lettering approx. 180mm high on a red background.

G14    Escape windows and sidescuttles

G14.1    Where the second means of escape from a space such as a radio office is provided by an opening window or sidescuttle, the window should be of the fully opening type of suitable dimensions and the sidescuttle should be not less than 450mm in diameter. When such a window or sidescuttle is locked by cone nuts to prevent unauthorised opening e.g. in lieu of mosquito protection in crew spaces on air conditioned ships, a special key should be provided in a glass-fronted box adjacent to the window or sidescuttle.

G15    Requirements applicable to passenger ships

The following applies specifically to passenger ships and are additional to the general requirements for all ships.

G15.1    Widths of stairways and ladderways

G15.1.1    The minimum aggregate width of stairways and ladderways, by which passengers and crew are specifically routed to the assembly stations and/or lifeboat, liferaft and marine escape system embarkation positions, is to be determined as indicated in Chapter 13 of the Fire Safety Systems Code.

G15.2    The carriage of elderly and disabled passengers

G15.2.1    Surveyors should ensure that shipowners and shipbuilders are conversant with the contents of MGN 31(M) and the IMO publication MSC/Circ 735 of June 1996 entitled; 'Recommendation on the Design and Operation of Passenger Ships to Respond to Elderly and Disabled Persons needs'.

G15.3    Continuous fire shelters

G15.3.1    Where a stairway providing continuous fire shelter has no direct access to the lifeboat, liferaft and marine escape system embarkation decks, the corridors between the stairway and the decks should be assumed to be part of the stairway enclosure with its division having the appropriate 'A' Class standards accordingly. See also paragraph on corridor and doorways in the guidance to regulation 9.2.

G15.4    Machinery space escapes

G15.4.1    The shelter should extend from the floor plate level at which there is direct access into a space, other than a special category space, or Ro-Ro cargo space, which provides a safe escape route to the embarkation deck.

G15.4.2    The protected enclosure, referred to in paragraphs 4.1.1.1 and 4.2.1.1, should be of sufficient cross sectional dimensions (but not less than the 800mm x 800mm) to provide unrestricted access within its height and should not be used for pipes, cables, ducts etc. except for electric cables serving light fittings within the shelter.

G15.4.3    The cross sectional dimensions of the protected enclosure should be increased in way of each opening in order to provide a landing within the shelter and permit the door to open without affecting a person who may be climbing the ladder.

G15.4.4    An opening into the protected enclosure should be provided at floor plate level and at each flat or grating level within the height of the protected enclosure except that such an opening need not be provided at any flat or grating level at which there is a door in a boundary of the machinery space which provides a safe escape route to the embarkation deck.

G15.4.5    Each opening in the protected enclosure should be fitted with a self-closing 'A' Class door of the same 'A' Class standard as the part of the shelter in which it is fitted. Each door should open into the protected enclosure.

G15.4.6    A control room situated within a machinery space should be provided with a means of escape which does not entail entering the machinery space. This may be achieved by one of the following:

G15.4.6.1    direct access into the protected enclosure referred to in paragraphs 4.1.1.1 and 4.2.1.1; or

G15.4.6.2    direct access into an adjacent space which provides a safe escape route to the embarkation deck.

G15.4.7    When a machinery space is recessed into or under an adjacent space and neither of the two means of escape referred to in paragraph 4.1.1 or 4.2.1 is situated in the recess, an additional means of escape may be required to be provided from the recess. This will depend on the dimensions of the recess, the distance to the nearest escape in the main part of the machinery space and its accessibility and the location of items of machinery which may present a fire hazard.

G15.5    Spaces in which gas cylinders are stored

G15.5.1    A space in which gas cylinders are stored should be located preferably on an open deck or, where this is not practicable, in a 'tweendeck immediately below an open deck. Any entrance to such a space should be from the open deck and be independent of the protected space or any other space. Every access door should open outwards.

G15.5.2    Where such a space is located below an open deck, the access into the space should be by a companion and sloping stairway. Access in such a case should not be by means of a hatch and vertical ladder which are not considered suitable for rapid evacuation in the event of an accidental discharge of gas into the space. See guidance to regulation 9.7 for the ventilation of such spaces.

G15.6    Low location lighting

G15.6.1    Proposals for compliance with the requirements for 'low location lighting' in escape routes should be presented on a plan drawn to a scale of not less than 1:100. This should show the layout and type (photo luminescent or electrically powered) of low location lighting and also the position of any symbols incorporated in the system.Reference should be made to guidelines on evaluation, testing and application of low location lighting on passenger ships adopted by the Organization by resolution A.752(18). This recommends luminance testing of low location lighting systems once in 5 years: such periodic testing is particularly relevant to unpowered systems.

G15.7    Marking and illuminating exits and escape routes

G15.7.1    Requirements relating to the marking and illuminating of exits and escape routes are given in paragraph 3.2.5. When considering those requirements the contents of the Merchant Shipping (Emergency Information for Passengers) Regulations 1990, should be observed.

G16    Requirements applicable to cargo ships and tankers

The following applies to cargo ships and tankers and are additional to the general requirements for all ships.

G16.1    Accommodation below the weather deck

G16.1.1    The two means of escape from each group of accommodation spaces situated between main bulkheads below the weather deck should be stairways as widely separated as possible. One stairway should provide direct access to the embarkation deck or higher deck and the other stairway should lead to the deck over or a higher deck which provides access to the embarkation deck by means of internal stairways and/or doors in the boundaries of the deckhouses and external ladders. However, if this is not practicable, the stairway which leads to the deck over or higher deck may be replaced by a trunked vertical ladder which provides the same degree of access. (See also the Instructions to Surveyors on the application of the Merchant Shipping (Crew Accommodation) Regulations 1997, - paragraph 2.7 refers).

G16.1.2    In certain circumstances, depending on the layout of the spaces under consideration and the position of the stairway, it may be necessary to provide two trunked vertical ladders, one port and one starboard, in order to provide adequate means of escape from the group of spaces.

G16.2    Accommodation above the weather deck

G16.2.1    The two means of escape from each group of accommodation spaces situated above the weather deck should be stairways as widely separated as possible. One stairway should provide direct access to the embarkation deck or higher deck and the other stairway should lead to the deck over or higher deck which provides access to the embarkation deck except that this stairway need not be fitted if there is at least one door from the corridor serving the group of spaces in each side of the deckhouse which provides access to the embarkation deck. The two doors and the stairway providing direct access to the embarkation deck should be as widely separated as possible.

G16.3    Arrangement of doors along escape routes and accessibility of embarkation decks

G16.3.1    The escape routes are routes for escape and also for access. Accordingly, the locking arrangements should be such that it does not obstruct these two objectives (escape and access) and that the doors in way of the escape routes can be opened from both sides.

G16.3.2    The embarkation deck should be accessible from the open decks to which the escape routes lead.

G16.4    Spaces in tower blocks

G16.4.1    When crew accommodation, service spaces and control stations are arranged in a tower block with no outside decks, all tiers in the block should be connected to each other by means of external sloping ladderways with at least one access door in each tier and by an internal enclosed stairway.

G16.5    Spaces in which gas cylinders are stored (on cargo ships)

G16.5.1    Table 9.5 in regulation 9, which relates to the location of spaces containing the gas fire extinguishing medium for cargo spaces on cargo ships, should also be noted. See also guidance to regulation 9.7 on Independent Ventilation Systems in respect of spaces in which gas cylinders are stored.

G17    Emergency escape breathing devices

G17.1    The minimum carriage of spares is one in cargo ships and in passenger ships two spare sets. In addition when more than 40 sets are carried one additional spare set is to be carried for each further 20 units (or part there of) with a total maximum number of 4 spare sets needed to be carried on board.

G17.2    The numbers needed for machinery spaces is undefined and is a departure from the normal prescriptive requirement. Because of the different manning arrangements and machinery space layouts, IMO concluded that it would be not be possible to determine satisfactory carriage requirements. The object of the regulation is to allow personnel to evacuate a dangerous space to a place of safety. It is the owner/operator, through a risk assessment process, and in consultation with the ships crew, who is to determine the number and location of the EEBD's. If a surveyor attending a ship is not satisfied with the arrangements, he/she should ask for the assessment to be repeated in light of deficiencies identified.

Guidance 13

G18    Flexible ladders (not acceptable)

G18.1    Flexible ladders, i.e. ladders having strings of flexible steel wire rope (or chains) are not acceptable as forming part of any escape route.

G19    Crew spaces

G19.1    In a space or group of spaces allocated solely to crew, the means of escape referred to in paragraphs 4.1.1 and 4.1.2 may consist of one stairway providing continuous fire shelter to the lifeboat, liferaft and marine escape system embarkation decks or, where necessary, to a higher deck and another stairway or vertical ladder giving access to the deck above through an escape hatch with access from that deck to the embarkation decks. In certain circumstances, depending upon the layout of the spaces under consideration and the positions of the stairway, it may be necessary to provide two escape hatches, one port and one starboard, in order to ensure that a fire in a particular location would not render escape impossible from some spaces.

Guidance 13

G20    Special category spaces

G20.1    The stairways forming the means of escape from each special category space should be suitably spaced in order to provide adequate coverage to the whole of the space. In general, at least one stairway should be provided at each end of the space and one stairway at approximately mid-length, each of which provides continuous fire shelter to the lifeboat, liferaft and marine escape system embarkation positions or, where necessary, to a higher deck. However, in ships fitted with two or more casings, this spacing of stairways providing continuous fire shelter should apply to each casing. Suitable signs to indicate the route to the escape stairways should be provided.

Guidance 13

G21    Ro-Ro spaces

G21.1    Ro-Ro spaces should be fitted with at least one stairway providing continuous fire shelter to the lifeboat, liferaft and marine escape system embarkation decks or, where necessary, to a higher deck and a stairway or ladder giving access to the deck above through an escape hatch with access from that deck to the embarkation decks. The two means of escape should be situated at opposite ends of the Ro-Ro space or as near thereto as practicable. Additional means of escape may be necessary in a space which extends longitudinally over a considerable portion of the ships length. Suitable signs to indicate the route to the escape stairways should be provided.

G22    Number and location of escape routes in Ro-Ro spaces

G22.1    The escape (and access) routes in Ro-Ro spaces should be so arranged that there are adequate escape routes during both the loading and unloading process.