Fire safety at sea entered a more demanding phase in 2026. Amendments to SOLAS Chapter II-2 and the Fire Safety Systems (FSS) Code, came into force on 1 January 2026 and placed stronger emphasis on early fire detection, improved containment, and more effective suppression, particularly in ro-ro (Roll on Roll off), vehicle, and special category areas, as well as across a wider range of spaces on newly built cargo ships.
While EEBD carriage requirements themselves have not been fundamentally rewritten, they remain a core part of the life-support framework that underpins safe evacuation. As detection systems become more sophisticated and suppression standards more robust, regulators increasingly expect the entire safety chain to function coherently, from detection, to alarm, to escape.
For Marine Safety Officers, this means EEBDs are no longer viewed in isolation. Inspectors are paying closer attention to whether EEBD numbers, placement, accessibility, signage, and crew familiarity genuinely support the way people escape in a real emergency.
This article explains:
- What EEBDs are designed to do, and their limitations
- The SOLAS EEBD requirements currently in force
- How those requirements apply across different marine and offshore environments
- How expert assessment can help ensure compliance and move beyond minimum legal thresholds to improve real safety outcomes
Understanding EEBDs in the context of modern fire safety
An Emergency Escape Breathing Device (EEBD) is a short-duration breathing apparatus intended to support evacuation when smoke, toxic gases, or oxygen-deficient atmospheres make escape routes unsafe.
EEBDs are designed to be:
- Quickly accessible
- Simple to don, even under stress
- Reliable after long periods of storage
The most advanced modern marine EEBDs use chemical oxygen technology rather than compressed air. In these systems, moisture from the user’s exhaled breath activates an oxygen-generating compound. This process removes carbon dioxide from the breathing loop while releasing breathable oxygen back to the user, allowing them to move safely along escape routes.
Equally important is clarity about what EEBDs are not intended for. They are not firefighting devices, they are not rescue apparatus, and they are not designed to allow prolonged activity in hazardous areas. Their purpose is singular: to provide enough breathable air to allow a person to escape safely.
This distinction is critical when writing procedures, running drills, and demonstrating compliance during inspections.
SOLAS fire-safety changes and why they matter for EEBDs
The most significant SOLAS fire-safety changes entering into force in 2026 relate to fire detection, monitoring, containment, and suppression, rather than to escape breathing equipment directly. However, these changes materially affect the environments in which EEBDs are needed.
Strengthened requirements in ro-ro, vehicle, and special category spaces
Amendments to SOLAS II-2/7 and II-2/20, supported by updates to the FSS Code, now explicitly cover:
- Vehicle spaces
- Special category spaces
- Open and closed ro-ro spaces
- Weather decks intended for the carriage of vehicles
These amendments introduce:
- Mandatory fixed smoke and heat detection systems designed to operate effectively under normal ventilation conditions
- Requirements for continuous video monitoring to support early detection and rapid response
- Stronger boundary protection to limit fire spread to accommodation, control stations, and survival craft areas
- Enhanced performance criteria for water-based fixed fire-extinguishing systems
From an EEBD perspective, these changes reinforce a key expectation: when a fire is detected earlier and suppressed more effectively, crew must also be able to escape just as effectively. EEBD availability, visibility, and placement are therefore being scrutinised more closely in high-risk spaces and along primary escape routes.
Expanded fixed fire detection on new cargo ships
For cargo ships constructed on or after 1 January 2026, fixed fire detection coverage must now extend beyond traditional accommodation corridors and stairways to include additional control stations and operational spaces.
While this does not alter EEBD quantities directly, it increases regulatory focus on how life-support equipment fits into the wider safety system on newer vessels.
Exact SOLAS requirements for EEBD carriage and placement
EEBD requirements are set out in SOLAS Chapter II-2, primarily under:
- Regulation 13.3.4 (Means of escape from accommodation spaces)
- Regulation 13.4.3 (Means of escape from machinery spaces)
Supporting guidance, including IMO circulars and flag-state interpretations, clarifies placement and accessibility principles.
Accommodation spaces
Cargo ships
- A minimum of two EEBDs must be carried within accommodation spaces.
Passenger ships
- Ships carrying 36 passengers or fewer:
At least two EEBDs per main vertical zone.
- Ships carrying more than 36 passengers:
At least four EEBDs per main vertical zone.
The intent behind these requirements is that crew and passengers can reach an EEBD without needing to travel long distances through smoke-affected corridors.
Machinery spaces
SOLAS requires EEBDs to be available where a person may need to commit to an escape route under degraded conditions. In practice, this usually means EEBDs are positioned:
- In or near engine control rooms (where located within machinery spaces)
- In workshops or machinery work areas
- Adjacent to secondary escape routes, such as escape ladders
The focus is not on a fixed number, but on ensuring no single point of failure along an escape path.
Spares and training equipment
In addition to operational units, SOLAS-aligned practice requires:
- Spare EEBDs, often expressed as a proportion of the total carried or a small minimum
- Clearly marked training EEBDs, stored separately from live units
Inspectors increasingly look for clear differentiation between training and operational equipment, supported by evidence of drills and familiarisation.
Applying SOLAS EEBD requirements by environment
Cargo ships
Cargo ships vary widely in layout, machinery density, and operational patterns.
Beyond the minimum carriage requirement, good practice focuses on:
- EEBD placement that reflects where crew actually work, not just where escape routes begin
- Avoiding reliance on a single corridor or access point
- Reviewing EEBD distribution in light of new 2026 fire detection requirements on newer vessels
Additional EEBDs are often justified where machinery layouts are complex or fire loads are high.
Passenger ships
Passenger vessels present unique challenges due to high occupancy and varying levels of familiarity with the ship.
In practice, operators often go beyond minimum EEBD numbers by:
- Providing additional units near high-traffic crew service areas
- Considering congestion points during evacuation
- Reinforcing crew training so EEBD use supports evacuation without encouraging prolonged exposure
Ro-ro passenger ships, ro-ro cargo ships, and vehicle carriers
Roll-on / Roll-off and vehicle spaces are a particular focus of the 2026 SOLAS amendments.
Given the strengthened detection, monitoring, and suppression requirements now in force, EEBD planning in these environments increasingly considers:
- Access routes to vehicle decks
- Vertical escape trunks and stair towers
- Whether crew can don an EEBD before conditions deteriorate
Even where minimum carriage requirements are met, additional EEBDs are often recommended to reflect the size, openness, and fire dynamics of these spaces.
Going beyond minimum compliance — expert support that adds real safety value
While SOLAS sets minimum expectations, it deliberately leaves room for professional judgement. Vessel layout, ventilation, occupancy patterns, and emergency movement all influence how many EEBDs are actually required to support safe escape.
Our specialists work with Marine Safety Officers to:
- Assess your specific operating environment
- Determine realistic EEBD quantities based on how people move during emergencies
- Validate placement against escape routes and Fire Control Plans
- Ensure compliance with SOLAS and the 2026 fire-safety amendments now in force
- Recommend practical improvements that go beyond minimum legal requirements, strengthening protection for crew and passengers
This approach supports inspections while also improving real-world safety performance.
Equipment that supports long-term compliance
Reliable, low-maintenance equipment plays a key role in sustaining compliance over time.
Semmco Life Protection Systems designs marine EEBDs to meet SOLAS and Marine Equipment Directive requirements while reducing inspection and maintenance burden. The Semmco Marine 15 EEBD, for example, is approved to EN 13794:2002 and ISO 23269-1:2008 and offers a service life of up to 15 years with simple visual inspections.
What this means for Marine Safety Officers
In 2026, EEBDs are best understood not as standalone devices, but as part of a wider safety system that regulators increasingly expect to function seamlessly.
Meeting the minimum requirements is essential. Ensuring that those requirements translate into effective escape under real conditions is where good safety management makes the difference.
If you’d like, we can support you, in conjunction with our specialist Distributors, with a vessel- or installation-specific EEBD assessment, mapping SOLAS requirements, 2026 fire-safety changes, and practical escape behaviour into a clear, inspection-ready plan.
