NVIC 10-99: Interpretations of SOLAS Chapter II-2 guidance

Last reviewed: October 14, 2026

This Coast Guard circular calls attention to MSC/Circ.847, an IMO set of interpretations of vague wording in SOLAS Chapter II-2. The interpretations should be used as guidance for fire protection construction, arrangements, and equipment installed on or after 14 May 1998. They clarify the regulations and do not amend them.

Applies toU.S. flag or foreign flag vessels, when applying the relevant provisions of SOLAS Chapter II-2.

What it says

  1. The interpretations in MSC/Circ.847 should be used as guidance when applying SOLAS Chapter II-2 to fire protection construction, arrangements, and equipment installed on board ships on or after 14 May 1998.

    “The interpretations contained in MSC/Circ.847 should be used as guidance when applying relevant provisions of SOLAS Chapter II-2 to fire protection construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998”
  2. The interpretations should be used as guidance for both U.S. flag and foreign flag vessels.

    “should be used as guidance when applying the relevant provisions of SOLAS Chapter II-2 to U.S. flag or foreign flag vessels.”
  3. The interpretations are clarifications only and are not intended to amend SOLAS regulations.

    “These interpretations are clarifications only and are not intended to amend SOLAS regulations.”
  4. The interpretations are not retroactive. They apply to construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998.

    “These interpretations are not retroactive, but apply to construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998.”
  5. The Commanding Officer, Marine Safety Center and Officers in Charge, Marine Inspection, should use the MSC/Circ.847 interpretations when applying the relevant SOLAS provisions in plan review and vessel inspection functions.

    NVIC 10-99 a.“should use the interpretations contained in MSC/Circ.847 when applying the relevant provisions of SOLAS in plan review and vessel inspection functions.”

Common questions

Are the MSC/Circ.847 interpretations mandatory?

The circular says the interpretations should be used as guidance. They are clarifications only and are not intended to amend SOLAS regulations.

“These interpretations are clarifications only and are not intended to amend SOLAS regulations.”

Are the SOLAS Chapter II-2 interpretations retroactive?

The interpretations are not retroactive. They apply to construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998.

“These interpretations are not retroactive, but apply to construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998.”

Who at the Coast Guard should use the MSC/Circ.847 interpretations?

The Commanding Officer, Marine Safety Center and Officers in Charge, Marine Inspection, should use them in plan review and vessel inspection functions.

“should use the interpretations contained in MSC/Circ.847 when applying the relevant provisions of SOLAS in plan review and vessel inspection functions.”

The text of NVIC 10-99

U.S. Coast Guard, NVIC 10-99 (main body; enclosures not shown)

Interpretations of SOLAS Chapter II-2

Commandant 2100 Second St. S.W. United States Coast Guard Washington, DC 20593 Staff Symbol: (G-MSE-4) Phone: (202) 267-1444 COMDTPUB P16700.4 NVIC 10-99 9/10/99 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 10-99 Subj: INTERPRETATIONS OF SOLAS CHAPTER II-2

Interpretations of SOLAS Chapter II-2 — PURPOSE. This Circular calls attention to “Interpretations of Vague Expressions and Other

Vague Wording in SOLAS Chapter II-2”, as approved by the International Maritime Organization (IMO), Maritime Safety Committee, as MSC/Circ.847. The interpretations contained in MSC/Circ.847 should be used as guidance when applying relevant provisions of SOLAS Chapter II-2 to fire protection construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998, in order to fulfill the requirements of the 1974 SOLAS Convention.

Interpretations of SOLAS Chapter II-2 — DIRECTIVES AFFECTED. None.

DIRECTIVES AFFECTED. None.

Interpretations of SOLAS Chapter II-2 — BACKGROUND.

a. The IMO’s Subcommittee on Fire Protection, at its 42nd session (8-12 December 1997), completed a multi-year effort to develop a set of unified interpretations, with a view to ensuring uniform application of the requirements of SOLAS Chapter II-2 containing vague expressions such as “to the satisfaction of the Administration” or other vague wording which is open to diverging interpretations. The United States delegation to the Subcommittee on Fire Protection was very active in the development of these interpretations. b. The IMO’s Maritime Safety Committee, at its 69th session (11-20 May 1998), approved the set of interpretations to SOLAS Chapter II-2 as MSC/Circ.847, “Interpretations of Vague Expressions and Other Vague Wording in SOLAS Chapter II-2.” c. The IMO’s Subcommittee on Fire Protection, at its 43rd session (11-15 January 1999), agreed to various minor editorial corrections to MSC/Circ.847 (as listed in IMO documents FP 43/9 and FP 43/9/1). Although the IMO Secretariat will issue these corrections in due course, Commandant (G-MSE-4) has included them in the MSC/Circ.847 attached to this Circular.

Interpretations of SOLAS Chapter II-2 — DISCUSSION. The interpretations in MSC/Circ.847 should be used as guidance when

applying the relevant provisions of SOLAS Chapter II-2 to U.S. flag or foreign flag vessels. These interpretations are clarifications only and are not intended to amend SOLAS regulations. They are intended to serve as uniform explanations of practices used by Administrations to comply with the intent of the regulations. These interpretations are not retroactive, but apply to construction, arrangements, and equipment to be installed on board ships on or after 14 May 1998.

Interpretations of SOLAS Chapter II-2 — ACTION.

a. The Commanding Officer, Marine Safety Center and Officers in Charge, Marine Inspection, should use the interpretations contained in MSC/Circ.847 when applying the relevant provisions of SOLAS in plan review and vessel inspection functions. b. Officers in Charge, Marine Inspection are encouraged to bring this NVIC to the attention of appropriate individuals in the marine industry within their zones. Encl: (1) MSC/Circ.847, “INTERPRETATIONS OF VAGUE EXPRESSIONS AND OTHER VAGUE WORDING IN SOLAS CHAPTER II-2”, as corrected Non-Standard Distribution: C:e New Orleans (90); Hampton Roads (50); Baltimore (45); San Francisco (40); Philadelphia, Port Arthur, Honolulu, Puget Sound (35); Miami, Houston, Mobile, Long Beach, Morgan City, Portland OR (25); Jacksonville, Long Island Sound (20); Boston, Portland ME, Charleston, Galveston, Anchorage (15); Cleveland (12); Louisville, Memphis, Paducah, Pittsburgh, St. Louis, Savannah, San Juan, Tampa, Buffalo, Chicago, Detroit, Deluth, Milwaukee, San Diego, Juneau, Valdez (10); Providence, Huntington, Wilmington, Corpus Christi, Toledo, Guam, Sault St. Marie (5). C:m New York (70); Sturgeon Bay (4). D:d Except Baltimore, Moriches, and Grand Haven. 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 (20). 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.