NVIC 09-00: Carbon dioxide fire extinguishing system safety

Last reviewed: October 19, 2026

This circular revises NVIC 09-00 and carries OSHA guidance to prevent accidental discharge of installed carbon dioxide fire extinguishing systems during shipyard periods or dockside repairs. Owners and operators of certain vessels can either provide a positive means to prevent discharge or develop vessel specific training with the shipyard employer. It is Coast Guard guidance.

Applies toOwners and operators of vessels inspected under Title 46 CFR, Subchapter's I, H, K and T that have a fixed carbon dioxide fire extinguishing system.

What it says

  1. The circular revises NVIC 09-00 and includes OSHA guidance meant to prevent accidental discharge of an installed carbon dioxide system in protected spaces on a commercial vessel during shipyard periods or dockside repairs.

    NVIC 09-00 1“to prevent an accidental discharge of an installed carbon dioxide fire extinguishing system within protected spaces on board a commercial vessel during shipyard periods or dockside repairs”

  2. Coast Guard personnel should become familiar with this circular and apply the safety procedures as necessary while on board U.S. flagged vessels with a fixed carbon dioxide system.

    NVIC 09-00 2“Coast Guard personnel should become familiar with this circular and apply the safety procedures, as necessary, in their regular work activities”

  3. Officers in Charge, Marine Inspection, are encouraged to bring this circular to the attention of appropriate individuals in the marine industry within their zones.

    NVIC 09-00 2“Officers in Charge, Marine Inspection, are encouraged to bring this Circular to the attention of appropriate individuals in the marine industry within their zones.”

  4. This change supersedes and replaces enclosure (1) of NVIC 09-00 and adds enclosures (2), (3) and (4).

    “This change to NVIC 09-00 supersedes and replaces enclosure (1) of NVIC 09-00 and adds enclosures (2), (3) and (4).”

  5. The OSHA final rule requires employers to provide a means to prevent a carbon dioxide system on a commercial vessel from discharging during a shipyard period, or to ensure employees are trained to recognize system alarms and evacuation routes.

    NVIC 09-00 5“The OSHA final rule requires employers to provide a means to prevent a carbon dioxide system onboard a commercial vessel from discharging during a shipyard period”

  6. The OSHA guidance for Fire Protection in Shipyard Employment goes into effect on December 14, 2004.

    NVIC 09-00 6“The OSHA guidance for Fire Protection in Shipyard Employment goes into effect on December 14, 2004.”

  7. Owners and operators of vessels inspected under Title 46 CFR, Subchapter's I, H, K and T with a fixed carbon dioxide system can either provide a positive means to prevent accidental discharge or develop vessel specific training with the shipyard employer.

    NVIC 09-00 6“can either provide a positive means to prevent an accidental discharge from the carbon dioxide system or develop vessel specific training on carbon dioxide systems safety with the shipyard employer”

Common questions

Why is carbon dioxide discharge more dangerous during shipyard periods?

Many crew and shipyard workers in protected spaces may not know the escape routes. Repair equipment could slow evacuation, and removed deck plates or moved machinery may block escape routes.

“Also, repair equipment located throughout the ship could slow evacuation, and the removing of deck plates or moving of machinery may block the direct path to an escape route.”

What can vessel owners do to comply with the OSHA guidance on carbon dioxide systems?

Owners and operators of the listed vessels can provide a positive means to prevent an accidental discharge. They can instead develop vessel specific training with the shipyard employer during shipyard or dockside repair periods.

“can either provide a positive means to prevent an accidental discharge from the carbon dioxide system or develop vessel specific training on carbon dioxide systems safety with the shipyard employer”

When does the OSHA guidance for shipyard fire protection take effect?

The OSHA guidance for Fire Protection in Shipyard Employment goes into effect on December 14, 2004.

“The OSHA guidance for Fire Protection in Shipyard Employment goes into effect on December 14, 2004.”

Why was NVIC 09-00 published?

It was published to provide information on Coast Guard approved installed carbon dioxide fire extinguishing systems.

“NVIC 09-00 was published to provide information on Coast Guard approved installed carbon dioxide fire extinguishing systems.”

The text of NVIC 09-00

U.S. Coast Guard, NVIC 09-00 (main body; enclosures not shown)

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety.

U.S. Department of Homeland Security United States Coast Guard Commandant United States Coast Guard 2100 Second ST. SW Washington, DC 20593 Staff Symbol: G-MSE-4 Phone: (202) 267-1444 FAX: (202) 267-1069 COMDTPUB P16700.4 NVIC 09-00 Change 1 10 FEBRUARY 2005 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 09-00, Change 1 SUBJ: CH-1 TO NVIC 09-00; CARBON DIOXIDE FIRE EXTINGUISHING SYSTEM SAFETY

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety. — PURPOSE. This document revises Navigation and Vessel Inspection Circular (NVIC) No. 09-00 and includes the guidance of the Occupational Safety and Health Administration (OSHA) promulgated in Title 29, Code of Federal Regulations (CFR) section 1915.506 of Federal Register dated Wednesday, September 15, 2004 (69 F.R. 55705) to prevent an accidental discharge of an installed carbon dioxide fire extinguishing system within protected s

1. PURPOSE. This document revises Navigation and Vessel Inspection Circular (NVIC) No. 09-00 and includes the guidance of the Occupational Safety and Health Administration (OSHA) promulgated in Title 29, Code of Federal Regulations (CFR) section 1915.506 of Federal Register dated Wednesday, September 15, 2004 (69 F.R. 55705) to prevent an accidental discharge of an installed carbon dioxide fire extinguishing system within protected spaces on board a commercial vessel during shipyard periods or dockside repairs.

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety. — ACTION. Officers in Charge, Marine Inspection, are encouraged to bring this Circular to the attention of appropriate individuals in the marine industry within their zones. Coast Guard personnel should become familiar with this circular and apply the safety procedures, as necessary, in their regular work activities while on board U.S. flagged vessels equipped with a fixed carbon dioxide fire extinguishing system. This NVIC is avail

2. ACTION. Officers in Charge, Marine Inspection, are encouraged to bring this Circular to the attention of appropriate individuals in the marine industry within their zones. Coast Guard personnel should become familiar with this circular and apply the safety procedures, as necessary, in their regular work activities while on board U.S. flagged vessels equipped with a fixed carbon dioxide fire extinguishing system. This NVIC is available on the World Wide Web at: http://www.uscg.mil/hq/g-m/nvic/ . The Coast Guard will distribute it by electronic means only.

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety. — DIRECTIVES AFFECTED. This change to NVIC 09-00 supersedes and replaces enclosure (1) of NVIC 09-00 and adds enclosures (2), (3) and (4).

DIRECTIVES AFFECTED. This change to NVIC 09-00 supersedes and replaces enclosure (1) of NVIC 09-00 and adds enclosures (2), (3) and (4).

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety. — BACKGROUND. NVIC 09-00 was published to provide information on Coast Guard approved installed carbon dioxide fire extinguishing systems. These systems are very effective for the protection of shipboard machinery spaces and cargo holds however, the concentration of carbon dioxide needed to extinguish fires exceeds the level to which humans can be safely exposed. There have been a number of casualties where crew members and inspecto

4.

BACKGROUND.

NVIC 09-00 was published to provide information on Coast Guard approved installed carbon dioxide fire extinguishing systems.

These systems are very effective for the protection of shipboard machinery spaces and cargo holds however, the concentration of carbon dioxide needed to extinguish fires exceeds the level to which humans can be safely exposed.

There have been a number of casualties where crew members and inspectors have died as the result of an inadvertent operation or malfunction of an installed DISTRIBUTION SDL No. 142 | a | b | c | d | e | f | g | h | i | j | k | l | m | n | o | p | q | r | s | t | u | v | w | x | y | z A | | | | | | | | | | | | | | | | | | | | | | | | | | | B | | 2 | 1 | | 1 | | | 1 | | | | | | 1 | 1 | | | 1 | | | | | | | | | 1 C | | | | | 1 | | | | | | | 1 | 1 | 1 | | | | | | | | | | | | | D | 1 | 1 | | 1 | | | | | | | 1 | * | | | | | | | | | | | | | | | E | | | | | | | | | | | | | | | 1 | | | | | | | | | | | | F | | | | | | | | | | | | | | | | | | | | | | | | | | | G | | | | | | | | | | | | | | | | | | | | | | | | | | | H | | | | | | | | | | | | | | | | | | | | | | | | | | | NON-STANDARD DISTRIBUTION: (SEE PAGE 2) NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 09-00, Change 1 carbon dioxide system while the system was being serviced or tested.

The casualties occurred as a result of varying root causes; however, most of them could have been avoided if the personnel involved were more familiar with the design and operation of approved carbon dioxide systems and had followed pre-planned safety precautions.

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety. — DISCUSSION. During shipyard periods or dockside repairs the potential of injuries or death due to an accidental discharge of carbon dioxide greatly increases due to the large number of ship's crew and shipyard workers located within the protected spaces who may be unfamiliar with the escape routes of the vessel. Also, repair equipment located throughout the ship could slow evacuation, and the removing of deck plates or moving of m

5. DISCUSSION. During shipyard periods or dockside repairs the potential of injuries or death due to an accidental discharge of carbon dioxide greatly increases due to the large number of ship's crew and shipyard workers located within the protected spaces who may be unfamiliar with the escape routes of the vessel. Also, repair equipment located throughout the ship could slow evacuation, and the removing of deck plates or moving of machinery may block the direct path to an escape route. The OSHA final rule requires employers to provide a means to prevent a carbon dioxide system onboard a commercial vessel from discharging during a shipyard period or to ensure that employees are trained to recognize system alarms and the location of the evacuation routes. The purpose of this Circular is to alert marine industry personnel of the risks involved with carbon dioxide fire extinguishing equipment: a. to recommend basic safety guidelines whenever system testing or servicing are being performed; b. to provide guidance on the installation of a positive means to prevent an accidental discharge during shipyard periods or dockside repairs; c. to provide guidance to vessel owners and shipyard employers with the training of their personnel to ensure their safety when working in a space protected by a carbon dioxide fire extinguishing system.

Ch-1 to 09-00, carbon dioxide fire extinguishing system safety. — IMPLEMENTATION. The OSHA guidance for Fire Protection in Shipyard Employment goes into effect on December 14, 2004. Owners and operators of vessels inspected under Title 46 CFR, Subchapter's I, H, K and T equipped with a fixed carbon dioxide fire extinguishing system can either provide a positive means to prevent an accidental discharge from the carbon dioxide system or develop vessel specific training on carbon dioxide systems sa

6. IMPLEMENTATION. The OSHA guidance for Fire Protection in Shipyard Employment goes into effect on December 14, 2004. Owners and operators of vessels inspected under Title 46 CFR, Subchapter's I, H, K and T equipped with a fixed carbon dioxide fire extinguishing system can either provide a positive means to prevent an accidental discharge from the carbon dioxide system or develop vessel specific training on carbon dioxide systems safety with the shipyard employer during shipyard or dockside repair periods. Internet release authorized. T. H. GILMOUR Rear Admiral, U.S. Coast Guard Assistant Commandant for Marine Safety, Security and Environmental Protection Encl: (1) Information on Carbon Dioxide Fire Extinguishing Systems (2) Recommendations to isolate Carbon Dioxide Fire Extinguishing Systems (3) Training Recommendations for Carbon Dioxide System Safety (4) Safety Procedures for Fixed Carbon Dioxide Extinguishing Systems NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 09-00, Change 1 Non-Standard Distribution: D:l CG Liaison Officer MILSEALIFTCOMD (Code N-7CG), CG Liaison Officer RSPA (DHM-22), CG Liaison Officer MARAD (MAR-742), CG Liaison Officer JUSMAGPHIL, CG Liaison Officer ABS, Maritime Liaison Office Commander U.S. Naval Forces Central Command (1). ABS Americas (1). NOAA Fleet Inspection Office (1). U.S. Merchant Marine Academy (1).

The plain-English explanation on this page was written with AI from the regulation text above and checked automatically before publishing: every quote appears in the text, every number comes from it, and a second model confirmed each statement adds nothing the text doesn't say. The regulation text governs. RegKnot is not affiliated with the U.S. Coast Guard.