🔍 Key Concepts

• 46 CFR requirements for unmanned tank barges during cargo transfer • The difference in fire extinguisher requirements when a barge has its own cargo pumps versus no cargo pumps • Location-based requirements (e.g., at or near the manifold or cargo handling area)

💭 Think About

• Ask yourself: Does the regulation require extinguishers in the cargo tank area only when pumps are installed, or regardless of pumps? • Think about who controls the transfer operation when the barge has no pumps of her own—how might that affect where extinguishers are required? • Consider whether the rule is focused on the source of ignition (pumps/motors) or the cargo transfer area itself.

✅ Before You Answer

• Verify in 46 CFR that you are looking at the section specific to unmanned tank barges during cargo transfer, not self-propelled tank vessels. • Check the exact wording about extinguishers: does it say a specific minimum number for the cargo tank area, or does it tie the requirement to having cargo pumps or machinery on board? • Confirm whether the barge without pumps relies entirely on shore-side or attending vessel equipment and how that affects on-barge extinguisher requirements.