Maritime Alert - November 2025
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DIRECTOR'S RESOLUTION NO. 836-2025-MGP/DICAPI
The Director General of Captaincies and Coast Guard of the Peruvian Navy has issued Director's Resolution No. 836-2025-MGP/DICAPI, approving the incorporation into the national regulations of the National Maritime Authority of the International Code for the Application of Fire Exposure Test Procedures, 2010 (PEF Code 2010), adopted by the International Maritime Organization (IMO).
By incorporating this international technical instrument and its amendments, Peru strengthens the alignment of its national maritime regulations with the fire safety standards recognized by the IMO and establishes a detailed framework for the approval, monitoring, and eventual renewal of fire protection products and materials installed on ships subject to the SOLAS Convention.
Main additions:
- Incorporation of the 2010 PEF Code as a mandatory technical reference: The 2010 PEF Code (hereinafter, the “PEF Code”) is the international technical instrument that establishes the fire exposure testing procedures that Administrations and competent authorities must use when approving products intended for installation on ships subject to the fire safety requirements of the SOLAS Convention. Therefore, through Directoral Resolution No. 836-2025-MGP/DICAPI, the PEF Code becomes part of the Maritime Authority's national standards, specifically Resolutions MSC.307(88) and MSC.436(99), so that products subject to requirements for fire resistance, flame spread, smoke production, and toxicity must be evaluated and approved in accordance with the procedures set forth in the 2010 PEF Code.
- Scope and Covered Products: The PEF Code applies to products that must be tested, evaluated, and approved in accordance with the references to the Code of Fire Exposure Test Procedures contained in the SOLAS Convention. When the Convention requires that a product meet certain fire characteristics, that product must be subjected to the fire exposure test procedures indicated therein. The PEF Code is structured into a general section and Annex 1, which details the various test procedures. These procedures cover, among others, tests for incombustibility, smoke production and toxicity, fire resistance of Class A, B, and F partitions, fire door systems, flammability of surfaces, vertically mounted textiles and films, upholstered furniture, bedding, and fire-resistant materials for high-speed craft. Annex 3 details fire protection materials (Class A, B, and C bulkheads, roofing, cladding, ceilings, fire doors and windows, among others) and the prescribed test methods for their approval, linking them to the applicable regulations of Chapter II-2 of the SOLAS Convention and the High-Speed Craft Code.
- Testing, Laboratories, and Product Approval: The PEF Code specifies that testing must be carried out in testing laboratories recognized by the Administration. These laboratories must have the appropriate equipment, facilities, personnel, and calibrated instruments to perform the described tests and operate under a supervised quality control system. Regarding approval, two procedures are provided: (a) type approval and (b) approval in specific cases.The Administration may issue type-approval certificates based on test reports no more than five years old. Such certificates are valid for up to five years from the date of issue and may be renewed without a new test when the report is no more than fifteen years old and the components or construction of the product have not been altered. The PEF Code also establishes the minimum content of type-approval certificates (product identification, tests, classification criteria, restrictions on use, among others), as well as the requirements for approval in specific cases when approval is limited to a specific vessel without issuing a type-approval certificate
- Grace Period for Type Approvals Issued Under the Previous Code: The PEF Code provides a grace period for type approvals issued under the previous version of the Fire Exposure Test Code, during which the Administration may continue to issue certificates based on tests carried out up to one year after the entry into force of the new PEF Code. The aim is to grant testing laboratories a grace period to acquire the necessary testing equipment to comply with the PEF Code.It should be noted that tests carried out more than one year after the PEF Code comes into force will be performed in accordance with the current version. Furthermore, the possibility of renewing product approvals for products tested under the previous version, without retesting, is contemplated, provided the report is no more than fifteen years old and the product's components and construction have not been modified.