b'FOGHORN FOCUS Overall, it is important or existing IMO standards, such as the IGF Code. Over the last few years, the IMO has released Interim Guide-to engage regulatory lines for the Safety of Ships Using Methyl/Ethyl Alcohol as Fuel (MSC.1-Circ.1641) and Interim Guidelines for bodies and third-party the Safety of Ships Using Fuel Cell Power Installations (MSC.1-Circ 1647), which have been fundamental to the organizations early and Coast Guard Design Basis approval process. The IMO continues to develop other sets of draft guidelines to be often on novel fuel released in the future, to include guidance on hydrogen projects, especially as and ammonia as fuel. RISK ASSESSMENTregulatory standards To identify and mitigate safety concerns regarding novel fuels,ariskassessmentforthevesseldesignshouldbe continue to develop. conducted after the design has been submitted and dis-cussed with the Coast Guard review team. As designs of increasingly complex nature are expected to emerge in the coming decades, it is paramount that risk assessments are thedelineationofhazardousareaswithinthegeneralconducted properly so that any deficiencies may be ad-arrangements of the vessel, and fire protection measures. dressed. As outlined in the CG-ENG Policy Letter 01-23, Design Basis Agreement Submission Guidance, the risk In addition to gas or liquid fuels, lithium-ion battery de- assessment should be a comprehensive report of all the signs have also gained popularity as a means of primaryelements of the novel fuel design where deviation from or secondary propulsion in recent design proposals. Lithi- the standards is requested, including proper justification um-ion battery design requirements that have been utilizedfor the proposed mitigation measures. The finalized risk in the DBA process predominately stem from Americanassessment will be included in the DBA to provide addi-Society for Testing and Materials (ASTM) standards andtional requirements, where courses of action are agreed Coast Guard policy letters. Currently, updates to both theupon based on the results. Often, the officer in charge, ASTM standard and the Coast Guard policy letter are an- marine inspection (OCMI) and representatives from the ticipated to further address the primary concerns with lith- Coast Guard design review team will participate in risk ium-ion battery designs and to continue fostering techno- assessment workshops to provide subject matter expertise logical growth for lithium-ion battery use in the maritimeon the findings from the assessment. The Coast Guard industry. Suitable fire protection measures for lithium-ionalso utilizes requirements based on the IGF Codes risk as-battery designs are of the utmost importance, includingsessment requirement, which also provides detailed guid-considerationstothestructuralfireprotectionratings,ance on the scope that should be considered to achieve ventilation capabilities, and installed battery managementan equivalent level of safety to existing standards. Safety system (BMS). Lithium-ion battery fires are dangerous andconsiderations for a risk assessment may involve items such difficult to extinguish, therefore proper monitoring andas hazardous locations, specific vessel systems in relation alarmingmustbeimplementedforlithium-ionbatteryto the type of novel fuel used, or fuel storage on the vessel. designstoensurevisibilityonbatteryvoltage,current,Additionalguidanceforriskassessmentscanbefound temperatures, and other critical parameters. inInternationalAssociationofClassificationSocieties (IACS) Recommendation #146 Risk Assessment as Re-Otherstandardsthatareoftenconsultedforthesafequired by the IGF Code (Aug 2016). implementation of emerging fuel sources include various Interim Guidelines published by the International Mar- REGULATORY ENGAGEMENTitime Organization (IMO). These guidelines provide in- AND COMMUNICATIONternational standards for novel fuels and novel fuel tech- Overall, it is important to engage regulatory bodies and nology, which will eventually become codified into newthird-partyorganizationsearlyandoftenonnovelfuel FOGHORN 38'