b'The technology associated with lithium-ion fire protectionfoam(AFFF)orsyntheticfluorinefreefoam(SFFF), FOGHORN FOCUS ischangingrapidlyandshouldbecarefullyevaluated.Itis doestheSFFFcarryCoastGuardapproval?Hasthatspe-crucialtogowithaprovenlithium-ionbatterycompany cific SFFF passed the rigorous testing for UL Solutions with a strong battery management system (BMS).and Coast Guard compliance here in the United States? These questions should be considered by all stakeholders Regulatory Stance in a project. The U.S. Coast Guard had issued guidance that their pre-ferredmethodofprotectinglithium-ionbatterieswasaItisessentialforengineeringanddesignfirmstowork water-basedsolution.Intheyearssince,developmentshave with reputable lithium-ion battery manufacturers, as well continued to be made in this field.asindustry-provenexpertstomitigatethisrisk.Otherwise,there may be a stall in this industry because of both the Thetechnologyofeachbatteryandbatterycompanyfinancial risk for the shipyards and the safety hazards for can affect how we would protect it, down to the agent orthe end user. volumeconcentratecenteredaroundthespecificelectronused in the lithium-ion battery reaction.Regulatory Follow ThroughInmultipleinstanceswehaveseenone-offacceptanceThe synopsis here is that we need further rules, regula- granted,andattimesthisisanappropriatemeasure. tions,orguidelinesthatdivedeeperintonotonlytodays In its original intentions, one-off acceptance can allow options, but where we think lithium-ion batteries will beustostepbackasanindustryanddiveintothecompo-ten and twenty years from now. After proper research andnents and practices to gauge if that will be a future path collaborationwithreputablecompanies,thestancethatforward while also allowing the project to continue to regulatorytakesshouldinfluencethetrendforbatteryprogress forward. manufacturers as a path forward. The market should adapt to the rules and regulations instead of regulatory attempt- While these one-off acceptances can start with the best ing to adapt to the market.ofintentions,deviationscanpropupsubparprotectionmethodsorcompaniesthatmayhavetakenshortcuts.Ac-Engineering Companies ceptancesatthelocalOCMIlevelcanbecomecontagious,Engineering firms play a crucial role in the design phasewith each following acceptance we push deeper down the ofnewprojectsandproductsthatenterthemarket.rabbitholeoffunctionalityversusaffordability.They have the challenging task of making an idea onpapercometofruitiononavesselwhilesimultaneously It is crucial that regulatory agencies follow through and providingacost-effectivesolutionthatoffersadequate holdthestandardacrosstheboardatalllevels.Theyshouldprotection for our mariners. While that goal is obtain- seek out the same reputable industry experts and ask the able it may open a project to loopholes and inadequatetoughquestionsthatwilldrivethisverticalofthemarineprotection methods.marketforwardinapositiveandsafermanner.Design basis agreements from the Coast Guard that grantAdaptability with Researcha form of acceptance can become a false leg to stand onI do feel that the lithium-ion propulsion industry must when the build cycle begins. This can come in forms ofcontinue to grow. As an industry we must learn and auxiliary protection methods where water-based protec- improvethelithium-ionpropulsionverticalforittobetion is included to check the box but the Trojan horsesustainable in the maritime propulsion market. Com-for primary protection is in fact the auxiliary protection.panieslikeCorvushavedoneagreatjobofansweringAt times the components of auxiliary protection systemsthis call. Aggressive developments and improvementshavenotbeenvettedatthegranularlevel.Thesystem in the BMS platform offer a key safety and informa-may work, and it may be accepted elsewhere, but does ittiveplatformofthesystemsoverallstatus.Singlecellmeet U.S. Coast Guard and Department of Transporta- isolation greatly decreases (if not eliminates) cell to cell tion requirements? In the case of aqueous film formingfire propagation. FOGHORN 16'