Directorate-General for Maritime

Affairs,
Fisheries and aquaculture

Fleet and Marine Services

Sub-Directorate for Ship Safety and Ecological
Transition

RECOMMENDATIONS FOR THE CARRIAGE OF ELECTRIC AND HYBRID

VEHICLES ON BOARD SHIPS

Document produced by the Sub-Directorate of Maritime Safety in

collaboration with the Battalion of Sailors Firefighters of Marseille and
Armateurs de France
1. INTRODUCTION

The development of battery electric vehicles (BEVs) in industry has led to an increase
in the number of electric cars and vehicles manufactured worldwide.

Over the past ten years, BEV sales have grown from around 100,000 to 6,750,000
per year, with a 108% increase between 2020 and 2021 alone. They are expected to
increase significantly over the next decade.

The number of electric vehicles (EVs) sold worldwide reached 10 million units in
2023. Most of these vehicles are powered by lithium-ion batteries. Nearly one in
three cars on the roads in China is expected to be electric by 2030, and nearly
one in five cars in the United States and the European Union.

However, there may be other technologies using Li-metal that have a different
risk profile than Li-ion batteries and should be considered separately (as is the
case in the UN TDG Model Regulation).

In addition, there is a continuous increase in new orders from vehicle

transporters. According to data provided by Clarkson, by October 2023, new
orders for vehicle carriers had reached 60 vessels, with a carrying capacity of
488,600 vehicles. Currently, the orders for vehicle carriers on standby total 170
vessels, for a transport capacity of 1,300,000 vehicles, which represents 32.35%
of the existing fleet. For most of these pending orders, it is expected that
deliveries will take place after 2025.

These vehicles are therefore logically found on board ships, either transported as
goods from the countries of export on board car carriers, or embarked with
passengers on board ro-ro passenger ships. These two modes of transport have
different requirements from the point of view of transport: in the first case, the
vehicles are transported when they leave the ship to their destination; in the second,
the vehicles use their energy reserve to leave the ship and reach at least the nearest
charging point.

The reduced number of fires related to the transport of electric vehicles or new
electric mobility devices (bicycles, scooters) on board ships attests to the rarity of
this type of incident. This observation should not lead to a decrease in the vigilance
of operators, especially if we consider the increase in the volumes transported over
the coming years, and the ageing of the fleet of vehicles and equipment equipped
with batteries and the equipment of most existing ro-ro vessels with a fixed carbon
dioxide extinguishing system.

In particular, fires that occur aboard large cargo ships carrying thousands of
vehicles are alarming.
Fires in vehicles equipped with lithium batteries represent a higher danger, due to
the phenomenon of thermal runaway which makes the fire difficult to control and
various usage and geographical parameters (such as the increased use of super
chargers or exposure to the sun).

It is now generally accepted that shipboard fire-fighting systems are designed to

meet standards applicable to vehicles using conventional fuels, and are not fully
adapted to deal with the fire risks associated with the maritime transport of
lithium battery electric vehicles, for which there is a lack of effective firefighting
capabilities. Extinguishing battery fires is more difficult than that of conventional
fires, due to the extremely strong exothermic reaction that renders carbon dioxide
ineffective and requires prolonged cooling to large amounts of water. This reaction
also leads to significant projections of incandescent materials making the
intervention more difficult.

Electric vehicles have become a major area of attention for maritime transport due to
the increase in the number of fires on ships carrying this type of vehicles. The
operational constraints related to the prevention, detection and firefighting on board
a ship make the management of these risks even more complex and require a
specific approach.

The thermal runaway makes it difficult to extinguish the fire. An EV light without
thermal runaway is treated like a conventional vehicle light.

Without a clear international regulatory framework, it was considered useful to

propose a set of recommendations for the use of actors in the maritime transport
chain such as shipowners, shippers and charterers for example.

2. DEFINITIONS

In this document, the definition of "electric vehicle or EV" refers to vehicles powered
by lithium-ion (UN3556), Li-metal (UN3557), Na-ion (UN3558) batteries that include
the following:

- hybrid electric vehicles;

- plug-in hybrid electric vehicles; and

- battery electric vehicles known as EVs.

No difference should be made between fully electric and hybrid vehicles with regard
to the propulsion battery.

-Charging cables: a set consisting of a flexible cable or cord equipped with a plug
and/or vehicle connector used to establish the connection between an EV and its
charging station.

-Thermal runaway: uncontrolled reaction that can occur in lithium batteries when the
batteries are used outside their operating range (in temperature, voltage, current),
subjected to unsuitable environmental conditions (high humidity, dust, insufficient
ventilation), or have suffered damage or short circuit.
-Ro-ro ships: Ships used for the carriage of rolling stock also include the following
types of ships associated with rolling stock:

.1Ro-ro passenger ships (ro/pax, ferries);

.2RoRo-ro vessels;
.3Ro-ro container ships (ConRo);
.4Pure Car Transporters (PCC); and
.5Pure Car and Truck Transporters (PCTC).

-Thermal propagation refers to the sequential occurrence of a thermal runaway in a

REESS* triggered by the thermal runaway of a cell in this rechargeable electrical
energy storage system (REESS).

-Thermal propagation restart: involves the resumption of chemical reactions within a

module or battery pack after temporary stabilization, such as complete cooling

-SRSEE: "Rechargeable Electrical Energy Storage System" means the rechargeable

energy storage system that provides electrical energy for electric propulsion.

-EV charging station: A stationary device connected to the power grid, intended to
provide electrical energy to an EV to charge it.

-Electric vehicle (EV): vehicle powered by an electric motor, powered by a

rechargeable energy storage system such as lithium-ion (UN3556), Li-metal
(UN3557), Na-ion (UN3558) batteries.

-Plug-in hybrid electric vehicle (PHEV): an electric vehicle that can charge its lithium-
ion (UN3556), Li-metal (UN3557), Na-ion (UN3558) electrical energy storage device
rechargeable from an external electrical source and also draws part of its energy
from another on-board source.

-Damaged vehicle*: A damaged vehicle is defined as a vehicle that has suffered

damage of such a nature that it requires repairs that exceed the routine mechanical
and/or electrical maintenance defined by the manufacturer.

-New vehicle*: A new vehicle is defined as a vehicle that has never belonged to
anyone in particular, except car manufacturers, dealers and dealers, has never been
registered in the name of an owner or entity, and has no damage.

-Used vehicle*: A used vehicle is defined as a vehicle that does not fall under the
definition of a new vehicle or the definition of a damaged vehicle.

-Vehicle in service*: A vehicle in service is a vehicle transported in the presence of an

operator.
-Charging area: part of a ro-ro space or a space reserved for vehicles where electric
vehicles can be connected to charging stations for charging purposes.

*Some of these definitions are taken from documents reporting on discussions currently
underway
within the IMO to revise special provisions 961 and 962 of the IMDG Code...

3. SUMMARY

.1Lithium battery electric vehicle fires have certain characteristics, such as rapid
combustion, high temperature, difficult extinguishing, production of toxic
(hydrogen fluoride and others) and flammable gases, and a trend of thermal
runaway.
.2The current requirements of SOLAS Chapter II-2 Regulation 20 do not address
the fire hazards associated with the maritime transport of lithium battery
electric vehicles. In this regard, appropriate and targeted regulations for
firefighting and day-to-day management are needed.
.3Although imperfect, fixed fire extinguishing devices by drencher or high-
pressure water mist diffusion are considered to be quite effective in fighting the
spread of lithium battery fire.

4. RECOMMENDATIONS

VEHICLE IDENTIFICATION, LOADING AND SECUREMENT

- Before the trip, it is recommended to make it possible to check the transport

document and add a booking option on the website. During the booking process, it is
advisable to make the passenger aware of the risks, including those related to the
charging of new electric mobility vehicles and to inform them of the charging rate of
the vehicle expected when it is loaded, i.e. between 30 and 40%.

- A meeting should be held between all parties involved to confirm the arrangements
made and to discuss the loading plan.

- The authorized loading area or space for lithium battery electric vehicles must not
be adjacent to the tank in which lubricating oil, fuels or flammable products are
stored.

- The recommended charge rate of propulsion batteries at boarding should be

between 30% and 40%, without ever exceeding the manufacturer's instructions. Note
that the battery of hybrid vehicles is normally controlled automatically to have a
charge level of 50% during use and it is technically difficult to reduce the charge
level to less than 30%.

- EVs must be clearly identified by a visual device, of sufficient size and remarkable
colour, placed on the vehicle, so that they can be easily recognised at the level of the
ro-ro axles. The identification of EVs must be able to be done from a distance,
visually by the use of video surveillance. This type of visual could be the following:
- When prepared for loading, all vehicles are subject to a visual safety inspection to
ensure that they are safe to load and do not pose a fire hazard.

- It is recommended that airlines encourage passengers to unlock the hood of

their car when loading to allow for effective interventions in the event of a fire.

- On board PCTC and PCC vessels, EVs must be placed at known locations.

- These "known locations" must be identified by the companies after carrying out a
risk analysis that will have been carried out on each ship, taking into account the fire
protection system that equips each deck.

- On ships other than PCTC and PCC, all EVs must be loaded in strict accordance with
the cargo stowage manual and the pre-established stowage and segregation plan,
taking into account any vehicle separation requirements.

- Once in the final tie-down position, all vehicles must have the ignition turned off,
the keys removed, the parking brake applied and the transmission in the park
position or, for manual vehicles, left in the gear position. EVs and hybrids must be
made safe according to the manufacturer's instructions.

-It is essential to maintain a fire watch at all times, especially if fire detection
systems have been disabled during loading, to ensure that potential problems are
identified at an early stage; As soon as the beginnings of a fire appear, emergency
measures must be taken.

- Fire and smoke detection systems and ventilation systems must be used in
accordance with company procedures. All emergency evacuation routes must be
confirmed as clear and accessible.

All vehicles must be stowed in accordance with the ship's CSM and stowage plan.
During vehicle securement, additional visual checks should be carried out to ensure
that they are safe to transport and do not pose a fire hazard. By
For example, these checks must ensure that there are no apparent defects or leaks.

- Mechanical ventilation systems in covered vehicle spaces, special category spaces

and ro-ro spaces shall take full account of the diffusion property of combustible
gases that may be released from vehicle batteries, to prevent air stratification and
the formation of gas pockets.

- Electrical equipment installed in exhaust ducts and flues must comply with
Directive 2014/34/EU of the European Parliament and of the Council of 26 February
2014 on
the harmonisation of the laws of the Member States concerning protective equipment and
systems
intended for use in potentially explosive atmospheres, for use in an explosive gas
environment where air can mix with the combustible gas that can be released from
the vehicle's battery.

- Cables, if any, that are located in ventilation ducts and flues must be armoured
or they must be placed in metal conduits.

Special case of propulsion batteries in damaged electric vehicles and hybrid

vehicles*:

.1the propulsion battery must be transported separately in another transport unit

and not inside the vehicle;

.2the propulsion battery shall be carried in accordance with the requirements of

the IMDG Code and Special Provision 376* and

.3A label marked "damaged/defective" must be provided to the carrier and

affixed to the battery with the safety certificate.

* A damaged or defective lithium battery must be transported in accordance with special

provision 376
of the IMDG Code, shall be accompanied by a transport document in accordance
with Chapter 5.4 of the IMDG Code, packaged in accordance with P908 or 911 as the
case may be. Finally, the package must be marked "damaged/defective". It is
recommended that a battery from a vehicle that has been involved in an accident be
considered damaged.

DURING THE TRIP

- All vehicles must be regularly inspected during the journey to ensure that all
means of lashing are properly secured, when control equipment is available, that
no vehicle has an increase in temperature.

- If electrolyte leaks are found on electric and hybrid vehicles, these leaks should
only be cleaned with appropriate PPE. An electrolyte leak should be considered
major damage to the battery pack and the vehicle should be safely isolated in
accordance with each vessel's own emergency response procedures.

- If an increase in temperature is observed, it must be dealt with promptly in

accordance with each vessel's emergency response procedures. This temperature
increase can be observed, for example, by the temperature differential of more than
20°C between vehicles of the same type on the same deck. A crackling sound can
also be heard, usually
heralding a thermal runaway.

- Fire and smoke detection systems on vehicle decks must be fully operational for
the duration of the journey.

-The fixed fire detection and alarm system must be able to identify the exact
location, the type of detector that has activated and differentiate the signal of this
device from all others.

- The frequency of fire patrols should be increased in EV transport areas and crews
should be trained to fight EV fires. The roundmen can be equipped with portable
thermal cameras to identify any abnormal heating.
ELECTRICAL CHARGING

In general, electric charging on board is strongly discouraged and presents significant risks.

- Offering an electric vehicle charging service on board ro-ro passenger ships should
be subject to specific risk analyses, based on recognised certifications. This service
should also benefit from full insurance coverage.

- In a logical and environmentally friendly way, electric charging must be powered by an

energy source
carbon-free on board.

-Electric charging of EVs and hybrids must be done according to the manufacturer's
instructions.

- This service must be supervised with particular attention to innovations in charging

equipment (in particular the development of intelligent systems with anomaly
detection, and the possibility of eventually stopping charging). If the electrical charge
is carried out, it must be done only with cables supplied by the ship that are subject
to certification and maintenance monitoring recorded by the ship.

- Cable and connector aspects must be covered by the certification of the installation of
electric charging.

- Electric charging must only be done from a dedicated charging station approved by
the classification society in charge of the ship. A system for de-energizing these
stations must be able to be done remotely in case of need or fire.

- Charging or recharging operations must be preferred before the start of disembarkation.

- Charging operations must be carried out at all times under human supervision or via
surveillance cameras.

- The recommended charging rate for unaccompanied electric vehicles on ro-ro

vessels should be between 30% and 40%, but never exceed the manufacturer's
instructions.

- Charging stations should be located, as far as possible, away from means of evacuation.

- A specific storage space must be provided near the charging station to allow the
storage of electrical cables intended for the charging of vehicles when they are not in
use in such a way that they are protected against damage due to loading and
unloading operations.

- Clearly visible markings must be installed in the charging area and in the vicinity of
each charging station.

- A risk assessment must be carried out to ensure that any risks related to EV
charging affecting the people on board, the environment or the integrity of the vessel
are taken into account.

- A fixed fire detection and alarm system, ensuring combined heat and smoke
detection in the charging area must be installed.
- The power supply to the charging stations must be automatically switched off in the event
of activation
at least one fire detector.

- A video surveillance system must cover the charging area and allow continuous video
monitoring.

- The charging area must be covered by a suitable fixed fire-extinguishing system.

- Confined spaces for vehicles containing charging areas must be equipped with a
mechanical ventilation system capable of providing continuous air renewal that is
sufficiently suitable to prevent the ambient temperature from overheating while
electric vehicles are being charged. Fans and fire dampers must be able to be
operated from outside the vehicle area.

FIRE DETECTION

- It is essential to maintain a fire watch at all times, particularly if fire detection

systems have been disabled during loading, to ensure that potential problems are
identified at an early stage. As soon as the beginnings of a fire appear, the
emergency measures specified in the individual procedures must be taken.

- An additional detection system such as a video surveillance system must be

installed in the loading areas intended for the transport of EVs. The aim is to quickly
identify the location of the fire and quickly activate the firefighting system. The
purpose of this complementary system is to detect any heating or the start of a fire
as early as possible.

- A suitable video surveillance system must be provided for open bridges.

- Appropriate detection methods should be able to detect the beginnings of thermal

runaway before it starts a fire.

- The frequency of fire patrols should be adapted to the specific hazards of EV

transport areas and the crew should be trained to fight related fires. Portable thermal
imaging devices may be provided and used by the crew conducting these rounds.

- The fixed fire detection and alarm system must be able to identify the exact
location, the type of detector that has activated and differentiate the signal of this
device from all others.

FIREFIGHTING

-The standards of applicability and performance of fixed fire-extinguishing

devices in ro-ro spaces, special category spaces and vehicle spaces must be
evaluated by an authorized classification society.

To date:

-A fixed diffused water extinguishing system of the deluge or water mist type is
effective in covering EV storage areas.

-A remotely operable gun sprinkler system is effective in covering EV storage areas on

the outside deck.
-Carbon dioxide extinguishing systems have no cooling effect. As a result, carbon
dioxide systems are not recommended as a fixed extinguishing system for
extinguishing electric vehicle fires. The best way to extinguish a fire involving a
vehicle equipped with a lithium battery is to diffuse large quantities of water, in order
to limit the effects of thermal runaway.

- The accessibility of EVs is a key point in firefighting.

- Fire integrity is important to enable the use of fixed fire-extinguishing devices

and safe evacuation. The latest fire test results show that the intensity of vehicle
fires exceeds the fire resistance of normal fire partitions. Currently, ro-ro spaces
and special category spaces are required to be equipped with A-30 divisions. In
vehicle fire tests, the temperature limits for Type A-30 divisions were exceeded
after 11 minutes. In view of the very short time frames, it may be necessary to
modify the procedures for activating the fire extinguishing device. In addition,
stricter fire containment provisions for muster stations and other crew vital
spaces for new vessels should be considered. For example, A-60 divisions
adjacent to ro-ro spaces and special category spaces may be required for lifeboat
stowage areas to ensure the safe evacuation of all persons on board in the event
of a fire.

- It is very important to contain the fire as much as possible, in order to prevent it from
turning into a higher-level fire. It is difficult to extinguish it at this stage, which is why
the goal of the firefighting system should be to contain it as much as possible by
preventing its spread until the affected battery cells are completely burned. Cooling
can play an important role in this. Ventilation can also be important to prevent the
buildup of toxic and explosive gases in the battery space.

- Battery fires can be rekindled after an initial extinguishment. A post-chilling

strategy is therefore necessary to prevent the fire from resuming. Watering of the
batteries during the first few hours followed by a succession of watering when the
temperature rises. This would limit the amount of water required and its
management.

- Firefighting can vary in terms of water use depending on whether the burning
vehicle is powered by lithium-ion (UN3556), Li-metal (UN3557) or Na-ion (UN3558)
batteries. It is important to take into consideration; in the event that the battery type
is known; that the use of water for Li-metal battery extinguishing has specific
drawbacks such as the formation of hydrogen and an increase in the production of
toxic gases. Watering the environment is more recommended than directly on the
battery given the reaction between the Li metal and the water. In general, Li-metal
batteries induce a lot of molten material projections.

CREW TRAINING

- Specific and regular training on the risks (fire, electrification, etc.) inherent in EV
and lithium-ion battery fires should be provided to crew members, in particular those
who are likely to intervene in this type of fire.
- The team responsible for patrolling areas containing EVs can be equipped with
thermal cameras and toxic gas detectors and must be trained in-house in their use.

- The crew members concerned must be trained in the intervention on battery fires, in the
Electrical hazards and risks relating to toxic and explosive fumes.

- Teams potentially engaged in the fight against a battery fire should be subject to
dedicated training, including the use of thermal cameras in operation.

- Dedicated exercises with fire and rescue services should be encouraged to

ensure the effective implementation of procedures (detection, extinguishment).

- These procedures should be integrated into a company's safety management system.

PASSENGER AND SHIPPER AWARENESS

- Passengers should be made aware of the risks, including those related to the
recharging of new electric mobility devices such as EVs and light mobility devices
such as scooters, for example, with dedicated communications by the shipowner at
any appropriate time.

- Shippers should also be made aware of these risks and urged to be as diligent as
possible in transmitting information on the goods to the carrier.

DEWATERING DEVICE

- Pumping devices in vehicle spaces, ro-ro spaces and special category spaces
must ensure the effective drying of the water that has accumulated therein.

- Bailout and dewatering should be sized to evacuate a capacity greater than the
combined capacity of the water spray system pumps and the required number of fire
hoses.

The collection and treatment of extinguishing water must be

taken into account. SPECIAL CASES:

Containerized vehicles on MAFI carts or trailers

A dedicated deployment system must be provided in the vicinity of EVs transported

in containers. Ideally, a device for connecting the fire hoses should be provided in
order to be able to flood the container. The risk of explosive atmosphere forming
within the container must be taken into account.

Special loading of EVs on open decks of ro-ro passenger ferries operated on a

shore to shore

In view of the fact that the vehicles arriving and being embarked are generally carried along the
water by a single lane without any real possibility of segregation; that the number of daily rotations is high
and very short in distance and duration; that the vehicles are transported on the open deck and that the
passengers very generally remain on board the vehicle because of this duration, The recommendations
proposed in this document cannot be applied in their entirety to this type of navigation.
5. CLASSIFICATION

Where optional class endorsements exist, shipowners are invited to take them into account.