Working together

for a safer world

Detection Limits
Ammonia as Fuel – Discussion Note

7th December 2020 Rev00

Report prepared by

Dr Paul Davies
Technical Manager, Risk Assessment, Alternative Fuels
Marine Global Technology Centre, UK

T: +44 (0)7789 921 555 Report prepared by

Email: [email protected]
Detection Limits
Ammonia as Fuel – Discussion Note

FOREWORD

The contents of this note are for information only and are not necessarily the views of
LR. All detection limits are subject to change.

th
[email protected] i 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

---------------------------------------------------------

There are no maritime rules or codes specific to the safe use of ammonia as fuel for ships.
Currently, guidance can be taken from generic requirements for ‘low-flashpoint fuels’ noted in
the IGF Code, requirements in the IGF Code for natural gas that are judge applicable to ammonia,
and existing class rules for the bulk carriage of ammonia and ammonia used as a refrigerant.

---------------------------------------------------------

Ammonia is both toxic and flammable. Therefore, although the likelihood of an unintended
release is small, there is a need to identify when a release occurs, what warnings should be
1
initiated, and what safety actions should be taken. For example , for a release in a Fuel Preparation
Room, at what concentration should an audible and visual alarm be initiated, and safety systems
activated to isolate the leak, shutdown supply and change engines over to run on fuel oil?

---------------------------------------------------------

In air, ammonia is flammable at a concentration of between 160,000 ppm (16%) and

270,000 ppm (27%). This compares to a concentration of, for example:

 5,000 ppm (0.5%)2 which can be fatal within minutes;


2
2,500 ppm (0.25%) that can be fatal after 15 minutes;
 700 ppm (0.07%)2 that can cause immediate eye irritation; and

3,4
5 ppm (0.0005%) which is typically the lower limit of olfactory detection (i.e. a
noticeable ‘smell’) unless habitual exposure causes desensitisation4 where concentrations
of 100 ppm or more may not be detected.

The effects of ammonia vary dependent upon conditions and an individual’s susceptibility; and
reporting of the effects is subjected to variation in testing methods, equipment and interpretation
of results. Therefore, it is not surprising that many differing effects and seemingly contradictory
5
concentrations and exposure times are published . Hence, the values noted above are simply
illustrative of the harm that can be caused and demonstrate that detection limits need to be set
in relation to toxicity rather than flammability.

---------------------------------------------------------

1. Assumes a dual-fuelled ship where fuel oil is used for emergency power.
2. Public Health England. 2015. Ammonia: Toxicological Overview.
3. eurammon-Information No. 6 / Updated version, May 2018. Gas detection for ammonia refrigeration plants.
4. Food Storage and Distribution Federation’s Technical and Safety Committee, British Engineering Services, Institute of
Refrigeration and other stakeholders, with support from the Health and Safety Executive. 2016. Safe management of ammonia
refrigeration systems.
5. Similar statements can be made for the differing flammability ranges quoted by many sources.

th
[email protected] 1 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

With regards to detection limits, several sources set requirements or provide advice. Although
these are not specific to ships and the use of ammonia as fuel, they do provide insight to detection
limits used elsewhere.

European Standard EN378:2016, Refrigerating systems and heat pumps – Safety and
environmental requirements

 233 ppm – an electrical signal is given at this concentration to activate “shut-off valves,
the alarm system, the mechanical ventilation or other emergency controls.”

The calculated value of 233 ppm is taken as the highest concentration level in an occupied space
6
that will not result in any acute effects (or create a risk of ignition) .

There are two other concentrations that are also listed in EN378 but these are to “warn against
the danger of explosion or fire”7. These concentrations are as follows.

 500 ppm – alarm and activation of mechanical ventilation.

 30,000 ppm – refrigerating system stopped automatically, power supply to the machinery
room isolated automatically, and mechanical ventilation stopped if measures are not
provided to limit likelihood of ignition.

TRAS 110, 2014 – safety requirements on ammonia refrigeration systems

 150 ppm to 500 ppm – “The emergency ventilation, the remote-controlled shut-off valve
in the refrigerant supply and, if applicable, the water curtain trigger automatically when
the gas warning device (150 to 500 ppm) responds.”8
 150 ppm to 500 ppm – “ammonia pre-alarm with automatic activation of the technical
ventilation.”9
 1,000 ppm – “main alarm with automatic shutdown of the affected system components
(refrigerant pumps, compressors, shut-off valves).”8
 30,000 ppm – “At the latest, when the concentration in the machine room is 30,000 ppm
shutdown and closure of supply air openings automatically.”10
3
eurammon, 2018 – Gas detection for ammonia refrigeration plants

 50 ppm to 100 ppm – “To spot small leakages at an early stage, a lower value of sensitivity
is often used than required in EN378 (500 ppm) or recommended in TRAS 110
(150 ppm).”

6. Refer to EN378: Part 1, Section 5.2; Part 3, Section 9.3.1; and Part 1, Annex E, Table E.1.
7. Refer to EN378: Part 3, Section 9.3.3.
8. Trans. from German. Refer to TRAS 110: Section 4 Requirements for ammonia refrigeration systems, 4.2.6 (2).
9. Trans. from German (abridged). Refer to TRAS 110: Section 4.4, Gas warning systems / signalling devices for gas hazards, (5).
10. Trans. from German (abridged). Refer to TRAS 110: Section 4.4, Gas warning systems / signalling devices for gas hazards, (6). It
is judged that this concentration is noted to warn against fire/explosion as per EN378.

th
[email protected] 2 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note


 ≤ 500 ppm – Pre-alarm, “[TRAS 110 and EN378] generally demand trigger values of 150
to 500 ppm for the pre-alarm which activates automatic ventilation in the machine rooms.
Working rooms need sensors with a trigger value of 200 ppm.”
 1,000 ppm – Main alarm “(according to TRAS 110): The affected components of the plant
(refrigerant pumps, compressors, shut-off valves) are automatically shut down.”
 30,000 ppm – Upper alarm, “The technical ventilation system is switched off and the
fresh air flap closed. A low-voltage trigger at the main switch of the switchboard
disconnects the system from the power supply.”
 10,000 ppm – upper alarm threshold in the UK.

The ‘organisation’ entitled eurammon is a “joint initiative of companies, institutions and

individuals who advocate an increased use of natural refrigerants” (eurammon.com).

Center for Chemical Process Safety (CCPS), 2009 – Continuous monitoring for hazardous material
11
release

 150 ppm (50% of IDLH) – advised as the maximum low-level alarm.

 300 ppm (100% of IDLH) – advised as the maximum high-level alarm.

Although ‘IDLH’ is taken as ‘Immediately Dangerous to Life or Health, it is important to note it

refers to the maximum exposure concentration in the workplace from which one could escape
within 30 minutes without any escape-impairing symptoms or any irreversible health effects.

---------------------------------------------------------

Proposals for detection limits are listed below and serve only to initiate further and wider
discussion to determine and agree limits.

The detection limits are based upon the above literature/standards review, guided by IGF Code
requirements for natural gas, and class rules, and by appraisal of comments from a small group
of stakeholders. These comments are listed on page 7 of this document under the section
‘Stakeholder Comments and Response’. For context, all the comments were made on initial limits
given in [square brackets].

It is interesting to note that the initial limits [in square brackets] were in some cases space/area
specific. For simplicity and to reflect the stakeholders’ views for lower detection limits, the current
values in red text are largely the same regardless of space/area.

It is also important to note that finalisation of detection limits needs to consider: the number and
location of detectors; the local/environmental conditions; release characteristics (e.g. buoyancy of

11. Referenced from: Health and Safety Executive. 2013. Review of alarm setting for toxic gas and oxygen detectors.

th
[email protected] 3 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

ammonia gas); and the duration over which detection is undertaken. Therefore, in addition to
further comments on the proposed limits, views are sought on these matters.

Fuel Storage Hold Space (FSHS) - a space/room in which the fuel tank is located

1. 25 ppm [500 ppm] detection initiates an audible and visual alarm at the entrance to (and
within) the FSHS, and on the navigation bridge (or in a continuously manned control
station).
2. 220 ppm [1,000 ppm] detection initiates the safety system (i.e. to isolate the leak) and
change-over to fuel oil.

It is assumed here that the FSHS is subjected to management controls (e.g. permissions,
notification, permit-to-work and appropriate training).

Fuel Preparation Room (FPR) - a space/room in which vaporisers, pumps and similar are located

3. 25 ppm [500 ppm] detection initiates an audible and visual alarm at the entrance to (and
within) the FPR, and on the navigation bridge (or in a continuously manned control
station).
4. 220 ppm [1,000 ppm] detection initiates the safety system (i.e. to isolate the leak) and
change-over to fuel oil.

It is assumed here that access to the FPR is subjected to management controls (e.g. permissions,
notification, permit-to-work and appropriate training).

Machinery Spaces Containing Ammonia Pipework, Equipment and Consumers (M/C)

– other than FSHS, FPR, BS and TCS

5. 25 ppm [500 ppm] detection initiates an audible and visual alarm at the entrance to (and
within) the M/C and on the navigation bridge (or in a continuously manned control
station).
6. 220 ppm [1,000 ppm] detection initiates the safety system (i.e. to isolate the leak) and
change-over to fuel oil.

Tank Connection Space (TCS) – a secondary enclosure around tank valves

7. 25 ppm [500 ppm] detection initiates an audible and visual alarm within the FSHS, and
on the navigation bridge (or in a continuously manned control station).
8. 220 ppm [1,000 ppm] detection initiates the safety system (i.e. to isolate the leak) and
change-over to fuel oil.

th
[email protected] 4 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

Bunker Station (BS) – external area/internal space where connections to bunker fuel are located

9. 25 ppm [250 ppm] detection initiates an audible and visual alarm within the BS and on
the navigation bridge (or in a continuously manned control station).
10. 220 ppm [500 ppm] detection initiates the safety system (i.e. to isolate the leak/supply)
and stops ammonia supply/delivery.

It is assumed here that the BS is manned by trained personnel wearing appropriate PPE, and BS
access is subjected to management controls (e.g. permissions, notification, permit-to-work). For
BS, also refer to ‘13’ below.

Double-walled Pipework/Duct
– lines carrying ammonia, and the secondary enclosure of a Gas Valve Unit

11. 25 ppm [500 ppm] detection (within the annulus) initiates an audible and visual alarm on
the navigation bridge (or in a continuously manned control station) and a further distinct
audible and visual alarm within the space through which the double-walled
pipework/duct passes through. This latter alarm needs to be audibly and visually distinct
from an alarm indicating a leak directly within the space through which the double-walled
pipe/duct passes through.
12. 220 ppm [1,000 ppm] detection (within the annulus) initiates the safety system (i.e. to
isolate the supply) and change-over to fuel oil.
13. For double-walled bunker lines only, 25 ppm detection within the annulus initiates an
audible and visual alarm at the BS and on the navigation bridge (or a continuously manned
control station) and ceases/shuts down bunkering.

Airlock – ammonia gas migration/leak into an airlock space (used as access to a space
containing ammonia equipment)

14. 25 ppm [100 ppm] detection initiates an audible and visual alarm on the navigation bridge
(or in a continuously manned control station) and at access to the airlock.

Ventilation Inlet & Other Openings to Spaces

– ammonia gas migration/leak into openings, as advised by risk assessment/modelling

15. 25 ppm [≤ 100 ppm] (dependent upon space usage)] detection initiates an audible and
visual alarm on the navigation bridge (or in a continuously manned control station).
16. 100 ppm [≤ 250 ppm] (dependent upon space usage)] detection initiates an audible and
visual alarm on the navigation bridge (or in a continuously manned control station), a local
warning, and closure of the opening (and/or other appropriate mitigation).

th
[email protected] 5 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

Fuel Tank, Pressure Relief Valve (PRV) – a valve to relieve excess pressure in the fuel tank

17. 1,000 ppm [≤ 250 ppm] detection downstream of the PRV initiates an audible and visual
alarm on the navigation bridge (or in a continuously manned control station).

This detection is to identify if a PRV is ‘passing’ ammonia – it is not for the identification of PRV
activation. Each ammonia fuel tank will require a minimum of two PRVs.

th
[email protected] 6 7 December 2020
Detection Limits
Ammonia as Fuel – Discussion Note

Summary: Discussion – Proposed Ammonia Detection Limits (ppm) & Principal Actions

FSHS FPR M/C TCS BS DWP AL VI PRV

Audible & Visual

25 25 25 25 25 25 25 25 1,000
Alarm
ESD & Change to
220 220 220 220 NA 220 NA NA NA
Fuel Oil
ESD & Bunker 220
NA NA NA NA 220 NA NA NA NA
Cessation
Audible & Visual
Alarm, Local Warning, NA 220*
NA 220*
NA 220
NA
220
NA NA NA 100 NA
Openings Closed
Notes NA – not applicable
FSHS – Fuel Storage Hold Space FPR – Fuel Preparation Room M/C – Machinery Space TCS – Tank Connection Space
BS – Bunker Station AL – Airlock VI – Ventilation Inlets and Other Openings
PRV – Pressure Relief Valve ESD – Emergency Shutdown ppm – parts per million of ammonia in air
DWP – Double-walled pipework/duct including secondary enclosure of Gas Valve Unit

* Openings not to be closed

---------------------------------------------------------

th
[email protected] 7 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

Stakeholder Comments and Response

The following is a summary and brief response to insightful and welcome comments from a small
group of stakeholders (May 220): ship operator; engine manufacturer; shipyard; classification
society; and, national administration. The comments and responses are largely relate to the ppm
limits between square brackets.

Level of Detection Limits

Comment
Two stakeholders considered that detection limits should be far lower than proposed in square
brackets above. This was based on reference to:

 health and safety regulation related to occupational workplace exposure12;

 general alarm set-points in cargo areas such as compressor rooms and hold spaces on
LPG/ammonia carriers (i.e. 100 ppm to 150 ppm); and,

13
setting of alarm points to gain ECO notation (i.e. 25 ppm for a permanently manned
location).

Response
A lower detection limit could provide earlier warning of a leak, and thereby provide a quicker
response. This could reduce leak duration and volume, and exposure of individuals. It could also
detect a ‘smaller’ leak, enabling quicker initiation of actions to prevent escalation into a much
larger and ‘serious’ leak. However, a possible downside of implementing lower detection limits is
that a greater number of spurious detections could be encountered.

Comment
If the detection limit is ‘too low’ it may increase the possibility of alarm and shutdown. However,
to protect occupants of a normally manned workplace, an alarm at 25 ppm needs to be available.
If necessary, ‘pre-alarm’, ‘main alarm’ and ‘shutdown’ could be introduced, based upon the
operational concept of the space.

Comment
The National Research Council (USA) provides Acute Exposure Guideline Levels (AEGL)14. In
particular, AEGL-2 refers to evacuation. Therefore, given an ammonia leak it would be reasonable
to set the alarm for evacuation (from a relatively small space such as a machinery space) by
reference to the AEGL-2 of 220 ppm (for an exposure time of 10 minutes). This value is similar to
that derived from EN378 (i.e. 233 ppm) increasing confidence in its use. To help finalise a practical

12. Workplace exposure to ammonia should not exceed an average of 25 ppm for 15 minutes over an 8-hour working day, and
35 ppm over an 8-hour working day and a 40-hour working week.
13. Where ammonia is used as a refrigerant.
14. Acute Exposure Guideline Levels for Selected Airborne Chemicals: Vol.6 (2008). www.epa.gov/aegl/ammonia-results-aegl-program

th
[email protected] 8 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

detection limit value, it is advisable to investigate the ‘false alarm sensitivity’ of ammonia detectors
available for marine application.

Response
The value of 220 ppm is similar to that derived from EN378 (i.e. 233 ppm) and increases support
for a detection limit at or between 220 ppm to 233 ppm, especially due to the ‘expert-authority’
of these sources. To help set detection limits and minimise spurious alarms the advice to
investigate ‘false alarm sensitivity’ of detectors is important.

Different Detection Limits for Different Spaces

Comment
One respondent who did not specifically comment on the level of detection limits, did question
why the detection limits were lower for the Bunker Station (BS) compared with some other spaces
(ppm limits in square brackets). This was questioned because: (1) if only bunkering crew are
potentially exposed to an ammonia leak they could be protected with appropriate PPE; and, (2) a
‘low’ detection limit could cause ‘undesirable’ and ‘frequent interruptions’ during bunkering.

Response
It is assumed that the BS is a manned location, at least during connection and disconnection of
the bunkering hose. Therefore, the detection limits for the BS were originally set at lower values
compared to normally unmanned spaces, such as the Fuel Storage Hold Space (FSHS).

Comment
The same respondent acknowledged that detection limits could vary dependent upon the location
and purpose of a space, but clarity on the rationale would be helpful.

Specifically, with reference to ppm limits in square brackets:

(a) detection limits for airlocks (AL) and ventilation inlets and other openings (VI) are lower than
for other spaces; and
(b) detection limits for machinery spaces (M/C) that are ‘gas safe spaces’ are the same as for
spaces dedicated to ammonia equipment that are ‘gas handling spaces’ (e.g. the Fuel Preparation
Room, FPR).

Response to (a)
The detection limits for AL and VI are lower than other spaces because airlocks and openings to,
for example accommodation, contain no ammonia leak sources. Therefore, any ammonia within
an AL or VI would have dispersed from another space. This means that the leak would most likely
be ‘serious’, requiring urgent action. Furthermore, detection of ammonia within an AL would
illustrate that it is defective.

th
[email protected] 9 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

Comment to Response (a)

This response is agreed for airlocks (AL) and ventilation inlets (VI) serving spaces with no ammonia
leak sources (e.g. accommodation). However, when serving spaces with potential ammonia leak
sources (i.e. ammonia handling equipment) it may be reasonable to have a higher detection limit.

Response to (b)
The detection limits for M/C are the same as for spaces dedicated to ammonia equipment and
storage because it was assumed that the M/C (i.e. Engine Room) contains ammonia equipment
and is normally manned. Therefore, to protect crew from a toxic release, it would be appropriate
to have lower detection limits than for unmanned spaces containing ammonia equipment (such
as the FPR). However, if detection limits are ‘too low’ then there is the increased possibility of
spurious alarms and shutdown. Therefore, as a starting point for discussion, detection limits for
the M/C were set as the same as those for an FPR and FSHS (with reference to limits in square
brackets).

Comment to Response (b)

The Engine Room (ER) is a ‘gas safe space’. This means no single failure can result in an ammonia
leak to the ER (e.g. pipework is of double-walled construction and the annular space is provided
with redundant ventilation). Hence, the ammonia detection limit within the ER could be reduced
in accordance with the engine manufacturer’s safety concept or design guideline.

Response
A lower detection limit may be appropriate, and this would be ‘more in-line’ with limits related
to EN378 and AEGL-2.

Comment
For unmanned spaces, consideration should be given to a lower detection limit of 50-100 ppm,
and an upper detection limit of 100-300 ppm. Similarly, for manned spaces, a lower detection
limit of 25 ppm and an upper detection limit of 50-100 ppm should be considered. It might also
be useful to consider three detection levels: ‘pre-alarm’, ‘main alarm’ and ’shutdown’.

For ‘Ventilation Inlets and Other Openings’ (VI) consideration should be given to a lower detection
limit of 25 ppm, and an upper detection limit less than that set for a ‘gas safe space’. Ammonia
detection at a VI should also consider shutdown of the ventilation system and/or closure of the
ventilation dampers. For an airlock (AL) detection limits lower than the space it serves should be
considered.

Response
There are advantages to setting lower ammonia detection limits (as noted elsewhere in this
document), and distinction between manned and unmanned spaces is appropriate.

th
[email protected] 10 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

Comment
Compared to a machinery space (e.g. Engine Room), larger spaces such as accommodation, may
require a lower detection limit than that based on AEGL-2 (i.e. lower than 220 ppm noted in the
comment above). This would allow more time for mitigation/evacuation and could be achieved
by monitoring the inlet air-flow to the space. However, a higher detection limit (e.g. 500 ppm)
may be acceptable for unoccupied spaces. This assumes unoccupied spaces are protected from
unauthorised access (e.g. a bolted hatch and operational procedures) and are not regularly
accessed for maintenance or inspections.

Response
To facilitate rapid evacuation and/or protection, it may be appropriate for accommodation spaces
to have a lower detection limit than other spaces, especially if the space has a ‘large’ occupancy
(e.g. a large number of passengers). Similarly, a higher detection limit might be appropriate for
spaces that are unmanned and have controlled access for trained personnel.

Detection for Fuel Tank Pressure Relief Valves (PRVs)

Comment
Clarity was requested from one respondent on the purpose of ammonia detection downstream
of each PRV, and whether common detection at the vent mast outlet was preferable.

Response
The purpose of detection downstream of a PRV is to identify if the valve is ‘passing’ ammonia
during normal operational conditions. If it is ‘passing’, then the PRV is defective and requires
repair. Unfortunately, if common detection was located at the vent mast outlet, it would not be
possible to determine which PRV was ‘passing’ ammonia.

This requirement is not common for PRVs. However, PRVs are a safety critical item and this
requirement is increasingly identified as a useful measure for all PRVs, not just for fuel tank PRVs.
This is because, such detection provides an early warning of PRV deterioration and unintentional
ammonia emission.

Tank Connection Space (TCS) Detection

Comment
For a cargo ship, the fuel storage tank may be located on open deck with tank connections
exposed to the weather (i.e. connections are not enclosed in a TCS). In this case, the detection
limits for a TCS are not applicable.

Response
Owing to the toxic hazard of ammonia, even for fuel storage tanks located on open deck it would
be inherently safer to use a TCS. This is because a TCS would prevent a release from spilling onto

th
[email protected] 11 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

the deck and/or dispersing uncontrollably in the wind. A TCS would contain the initial leak and
direct it to a safe location (i.e. to the vent mast).

Comment to Response
Agreed, as an enhanced safety system for ammonia as fuel. Reference can be made to Unified
Interpretations of the IGF Code (MSC.1/Circ 1558, paragraph 1) that states, “A tank connection
space may be required also for tanks on open deck….”.

Emergency Shutdown (ESD)

Comment
An ammonia leak detected at the upper set-limit (e.g. 1,000 ppm) in a space containing a
consumer should initiate closer of the ‘Master Valve’ and not the ‘ESD Valve’ (refer to point 6
above). This also applies to ammonia leaks into the annular space of double-walled piping and
the secondary enclosure of gas valve units (refer to point 12 above).

Response
The proposed wording tried to convey the message that upon detection at the upper-limit, the
ammonia supply should be isolated, and consumers should change-over to fuel oil (this is a
potential emergency). Unfortunately, the wording “closure of Emergency Shutdown Valves” was
vague and caused confusion over which valves should close. The text will be reworded.

Comment to Response
With reference to Unified Interpretations of the IGF Code (MSC.1/Circ 1558, paragraph 6),
activation of the safety system alone is not deemed an emergency situation. Therefore,
‘emergency shutdown valve’ could be replaced by ‘Master Gas Fuel Valve’ or ‘Tank Master
Isolation Valve’.

Comment
The gas valve unit or train (GVU) may be located outside the Engine Room in a ‘hazardous zoned
space’ and ‘combined’ with the Master Gas Fuel Valve (MGFV) and ‘double-block-and-bleed’
arrangement. Hence, clarification is required to ensure the above applies to the ‘secondary
enclosure of gas valve units’ within the ER (i.e. within a gas safe machinery space).

Response
To improve clarity, the text will be re-worded in future updates. As an aside, if the GVU is located
outside the ER, this space will need appropriate hazardous zoning, detection and means to safely
contain, handle and/or vent an ammonia release.

Comment
The term ‘Tank Master Isolation Valves’ should replace the term ‘Emergency Shutdown Valves’ in
the above sections headed ‘Fuel Preparation Room (FPR)’ and ‘Tank Connection Space (TCS)’.
Similarly, the term ‘Master Gas Fuel Valves’ should replace the term ‘Emergency Shutdown Valves’

th
[email protected] 12 7 December 2020
 Detection Limits
Ammonia as Fuel – Discussion Note

in the above sections headed ‘Machinery Spaces Containing Ammonia Pipework, Equipment and
Consumers (M/C)’ and ‘Double-walled Pipework/Duct’.

Response
The proposed wording and terms used need to be reviewed, revised as appropriate, and clarity
improved.

Alarms/Warnings

Comment
Ammonia detection within a secondary barrier should also initiate an alarm in the surrounding
space that is being protected. For example: detection within the TCS should provide an alert
within the FSHS; and, detection within the annular space of a double-walled pipe passing through
the Engine Room should alert occupants in the Engine Room.

Response
Providing a visual and audible alarm to spaces protected by a secondary barrier would reduce
possible delays in alerting crew to a release (i.e. by reducing reliance on those manning the
navigation bridge/control station to inform those within, for example, the FSHS or Engine room).

Occupational Exposure

Comment
Ammonia levels within the workplace need to be monitored as indicated by recognised
organisations. This could be achieved by using an integrated ammonia detection system or by
using personal monitoring devices.

Response
Occupational exposure does need to be appropriately monitored and controlled, as required by
established regulations.

Environmental Emissions

Comment 28th May 2020

Ammonia leaks and emissions should be monitored to ensure any environmental limits are not
exceeded. This is particularly important considering the application of ammonia as fuel is driven
by environmental concerns.

Response
Environmental emissions do need to be appropriately monitored and controlled, as required by
established regulations.

---------------------------------------------------------

th
[email protected] 13 7 December 2020
Lloyd’s
Lloyds. Register Marine & Offshore
Global Technology Centre
Boldrewood Innovation Campus
Burgess Road
Southampton, UK
SO16 7QF

T: 44 330 414 1000

E: [email protected]
W: www.lr.org
Typo... @lr.org

www.lr.org

Lloyd’s Register Group Limited, its subsidiaries and affiliates and their respective officers, employees or agents are, individually and collectively,
referred to in this clause as ‘Lloyd’s Register’. Lloyd’s Register assumes no responsibility and shall not be liable to any person for any loss,
damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a
contract with the relevant Lloyd’s Register entity for the provision of this information or advice and in that case any responsibility or liability is
exclusively on the terms and conditions set out in that contract.

Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates.
Copyright © Lloyd’s Register EMEA. 2016
A member of the Lloyd’s Register group.