Japanese comments on ISO/CD 17631
Clause 1
"and fire detection systems" should be inserted after "structural fire protection".
Reason: "structural fire protection" is not suitable to cover fire detection system.
"structural fire protection" should be replaced by "fire protection construction".
Reason: Structural fire protection is not a physical object whereas the other items are.
Clause 2.3
"fire plan" should be replaced by "fire control plan".
Reason: So as to be consistent with the term used in SOLAS.
Clause 2.4
The words "fixed" and "portable" should be deleted.
Reason: There are non-portable fire extinguishers.
"as addressed by SOLAS 74 Chapter II-2 as amended" should be added at the end.
Reason: In the same manner as the definition for "life-saving appliances".
Clause 2.5
"primary and secondary" should be deleted.
Reason: No distinction between escape routes by "primary" and "secondary" is made in the relevant SOLAS provisions.
Clause 2.7
"as amended" should be added at the end of the sentence.
Clause 2.8
"as addressed by SOLAS 74 Chapter II-2 as amended" should be added at the end.
Reason: In the same manner as the definition for "life-saving appliances".
Clause 2.9
"safety plan" should be replaced by "life-saving plan".
Reason: A fire control plan is also a kind of safety plan. "life saving plan" is more appropriate as the counterpart to "fire control plan".
Clause 2.10
"structural fire protection" should be replaced by "fire protection construction".
Reason: See the third comment for clause 1.
The definition should be replaced by "A" class and "B" class divisions required by SOLAS 74 Chapter II-2 as amended"
Reason: It is not appropriate to include ventilation systems and fire detection and alarm systems in "structural fire protection" (or "fire protection construction").
Clause 3.1
This clause should be deleted.
Reason: Requirements related to the provision of plans on board are given in SOLAS Reg.II-2/20. ISO requirements should not overlap SOLAS requirements.
Clause 3.1.2
This clause should be divided into two clauses at between the second and third sentences. The latter part should be put in sub-paragraph 3.1.1.
