Vessel Examination: The mounted fire extinguisher debate

By Daren Lewis

Shipmates,
Proving once again that there is always something to learn, the issue of mounting of fire extinguishers came up at our Vessel Examiner workshop this month.

Before I break into my research on the topic let's agree that mounting of ALL fire extinguishers is a good idea and something we need to promote while doing VEs.

Into the debate:


The latest version of "A boaters guide to the Federal requirements for recreational boats" states on page 21:

"...and must be provided with a mounting bracket. While not required, it is recommended that extinguishers be mounted in a readily accessible location."

Easy right? Recommended but not required. Unfortunately it isn't that easy. First, the text may simply apply to "readily accessible location" but even if we assume there is no general mounting requirement for ALL extinguishers that isn't the end of the story.

The USCG does not actually test portable fire extinguishers for recreational boat use. The Coast Guard relies on third party testing labs to do the testing and maintain oversight of fire extinguisher manufacturers. These third party testing labs may set additional conditional requirements for their certification to apply.

I pulled my home ABC extinguisher from the mount in the pantry and had a look at the label. In the UL section (not the manufacturers instructions) we see the following:

Marine Type U.S.C.G.
Type A Size II, Type B:C Size I
U.S.C.G. Approval Number 160.028/EX1793
Valid only with bracket P/N 466400


The key part is this last "Valid only with bracket P/N 466400". This means the U.S.C.G. Approval only exists when the extinguisher is in the required bracket.

Bottom line, we need to check all extinguishers. If an extinguisher has this or a similar note from a third party testing agency, as part of the U.S.C.G. approval, the extinguisher must be mounted in the bracket to be counted as a required extinguisher.

A few key points:

• Unmounted extinguishers are acceptable if they are excess to the requirements and there are other mounted or extinguishers not requiring mounting that meet the requirements.
• You are unlikely to know if the bracket provided is the required bracket - we can allow passage of properly mounted extinguishers in these cases.
• You need to remove portable extinguishers to do a proper check. Seeing them is not sufficient to assure they are USCG Approved and to check to see if the contents are caked and packed.
• Please explain the issue to boat owners if the issue arises (i.e. "There is no general requirement that all extinguishers be mounted but THIS particular extinguisher is only approved when mounted as it says in the U.S.C.G. Approval notice right here on the label.")
• Remember, we are seeking 100% voluntary compliance with the requirements before we issue the VSC decal. This applies to mounting of those extinguishers that require mounting.

Thank you to everyone who offered a perspective on this question. I'd welcome additional feedback. I am also seeking photos of USCG Approved extinguishers without a mounting requirement and/or those approved by other third party testing agencies. The first member to provide photos of either instance gets a customized pint glass.