Start hereRules checked 20 October 2026
An emergency escape breathing device (EEBD) is a hood or mask with about ten minutes of air or oxygen. It is made for one job: getting out of a space full of smoke or toxic gas. In a machinery space fire, or after an accidental CO2 release, it buys the time to climb an escape ladder and reach fresh air. Ten minutes is plenty to get out and nowhere near enough to go in.
Because EEBDs are small, cheap and hung all over the ship, they are easy to misuse and easy to forget. This lesson covers the rules on what they are, how many the ship needs and where, how they are checked, and four decisions an officer has to get right.
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In this lesson
- Four EEBD decisions on a product tanker
- In plain words
- In detail
- What the rules say
- Flag and class notes
- Key numbers
- What inspectors find
- Quiz: 6 questions
Try it
Four EEBD decisions on a product tanker
In plain words
An EEBD is an escape set, not a fire-fighting set. Put it on the moment the air turns bad, then get out.
- It gives at least ten minutes of air or oxygen.
- It has a hood or full face mask that protects the eyes, nose and mouth, with a window to see through.
- You can carry it hands-free until you need it, and the instructions are printed on it.
- It is never used to fight a fire, to enter a tank or void, or by fire-fighters for their own use. For those jobs you need an SCBA.
Every ship has at least two in the accommodation, plus more in the machinery spaces near the escape routes, plus spares. The crew check the gauges every week. Once a year the devices are checked to the maker’s instructions. Expired units are replaced, and cylinders are hydrostatically tested when the maker or the flag requires it.
In detail
What an EEBD must be
FSS Code chapter 3, section 2.21:
- 2.2.1.1: a supplied air or oxygen device “only used for escape from a compartment that has a hazardous atmosphere”, of an approved type.
- 2.2.1.2: not used for fighting fires, entering oxygen-deficient voids or tanks, or worn by fire-fighters. Use an SCBA for those.
- 2.2.2.3: a hazardous atmosphere is one “immediately dangerous to life or health”.
- 2.2.3: a service duration of at least 10 minutes; a hood or full face piece of flame-resistant material with a clear window; hands-free carriage when not activated; protection from the environment in storage; brief instructions or diagrams printed on the device, with quick and easy donning.
- 2.2.4: each EEBD carries its maintenance requirements, the maker’s trademark and serial number, the shelf life with the date of manufacture, and the name of the approving authority. Training units are clearly marked.
MSC/Circ.849, the 1998 guidelines that came before these rules, adds one more use. An EEBD may be used to escape from a machinery space after an accidental release of a fixed CO2 system, and fire-fighters may carry one only to give it to a person who needs help.3
How many, and where
SOLAS regulation II-2/13.3.4 covers accommodation and regulation II-2/13.4.3 covers machinery spaces. MSC/Circ.1081 gives the interpretation24:
| Area | Requirement |
|---|---|
| Accommodation, cargo ships | 2 EEBDs and 1 spare |
| Accommodation, passenger ships up to 36 passengers | 2 per main vertical zone, 2 spares in total |
| Accommodation, passenger ships over 36 passengers | 4 per main vertical zone, 2 spares in total |
| Category A machinery spaces with main propulsion engines | 1 in the engine control room (if inside the space); 1 in the workshop (not needed if it opens straight onto an escape route); 1 on each deck or platform level near the escape ladder of the second means of escape |
| Other category A machinery spaces | At least 1 on each deck or platform level near the second-escape ladder |
| Other machinery spaces | As the Administration decides |
The machinery space EEBDs must be ready for use at easily visible places, reachable quickly, with their positions chosen for the layout and the number of people who work there. The number and locations go on the fire control plan (regulation II-2/13.4.3.2).2 MSC/Circ.849 suggests placing them along escape routes or at the foot of each escape ladder, and considering control rooms and workshops inside the machinery space.3
Checks and maintenance
- Weekly: check that every EEBD cylinder gauge is in the correct pressure range (MSC.1/Circ.1432 paragraph 4.5).5
- Annually: check EEBDs to the maker’s instructions (paragraph 7.8.3).5 This normally means the seals and tamper indicators, the condition of the bag or case, the hood and window, the gauge, the shelf-life date, and any service the maker requires.
- Maintenance plan: EEBDs are one of the items SOLAS regulation II-2/14.2.2.3 requires in the plan.2
- Training: EEBD training is part of on-board training (SOLAS regulation II-2/15.2.2.2).2 MSC/Circ.849 says people should be trained to put one on before leaving a space whose atmosphere becomes life-threatening, through routine escape drills for engine room crew.3
Shelf life and hydrostatic testing
The IMO texts leave cylinder testing to the maker. Flags differ, so check your own:
- Liberia: no periodic hydrostatic test unless the manufacturer requires one; units past their service life are discarded.6
- Marshall Islands: follow the maker. Where there are no maker’s instructions, hydrostatic test at intervals not exceeding five years unless the maker prohibits it. Devices with small oxygen cartridges (50.8 mm diameter or less) may have a fixed service life without testing.7
- Bahamas: at least annual inspection by a competent person; hydrostatic test at least every five years or more often if the maker says so, with test pressure and date marked on the cylinder; no test for small oxygen cartridge units with a fixed service life.8
- New ships (Marshall Islands): the first test may be harmonised with the first special survey dry-docking if the first date stamp is not more than six months before delivery.7
Spares and training units
SOLAS regulation II-2/13.3.4.1 requires spare EEBDs on board.2 Flags put numbers on it:
- Liberia: at least 1 spare for up to 10 EEBDs, 2 for 11 to 20, and 10% (no more than 4) above 20.6
- Bahamas: spares kept in a control station, at least 1 on cargo ships and 2 on passenger ships, plus either a dedicated training EEBD or the means to restore a training unit to full operating condition.8
- Cyprus: at least one extra EEBD for training only, marked “training”, whatever the number in place.9
What the rules say
- FSS Code chapter 3, paragraph 2.2.1.2, says EEBDs “shall not be used for fighting fires, entering oxygen deficient voids or tanks, or worn by fire-fighters”.1
- FSS Code chapter 3, paragraph 2.2.3.1, requires an EEBD service duration of at least 10 minutes.1
- FSS Code chapter 3, paragraph 2.2.4, requires maintenance requirements, serial number, shelf life with manufacture date and approving authority printed on each EEBD, and training units clearly marked.1
- SOLAS regulation II-2/13.3.4 requires at least two EEBDs within accommodation spaces on all ships, more on passenger ships, and spares on board.2
- SOLAS regulation II-2/13.4.3 requires EEBDs in machinery spaces at easily visible, quickly reached places, with their number and location shown on the fire control plan.2
- MSC/Circ.1081 interprets the minimum as two EEBDs and one spare in the accommodation of cargo ships, plus set positions in category A machinery spaces.4
- MSC.1/Circ.1432 paragraphs 4.5 and 7.8.3 call for a weekly gauge check and an annual check to the maker’s instructions.5
Flag and class notes
- Marshall Islands treats MSC/Circ.849 as mandatory, calls for at least two EEBDs on each level of the machinery space (one if there is an enclosed escape trunk with a door at each level), and counts as “levels” only decks where people work.7
- Bahamas requires a risk assessment, agreed with the recognised organisation, whenever the number or location of machinery space EEBDs changes, and has the RO verify records, instructions and spares at each Safety Equipment survey.8
- Liberia and Cyprus set spare and training unit numbers as above.69
- Class: at the Safety Equipment survey the recognised organisation (RO) surveyor checks the EEBDs and their records; Bahamas spells this out.8 SOLAS requires the number and location of machinery space EEBDs on the fire control plan, so if you move or add units, update the plan and tell the RO.2
Key numbers
| What | Value |
|---|---|
| Minimum service duration | 10 minutes1 |
| Accommodation, cargo ships | 2 EEBDs + 1 spare4 |
| Accommodation, passenger ships over 36 passengers | 4 per main vertical zone + 2 spares4 |
| Gauge check | Weekly5 |
| Check to maker’s instructions | Annually5 |
| Hydrostatic test without maker’s instructions (Marshall Islands) | Not exceeding 5 years7 |
| Liberia spares for more than 20 EEBDs | 10%, maximum 46 |
What inspectors find
- Expired EEBDs still in their locations, past the shelf life printed on the device.16
- Gauges out of range with no record of the weekly check.5
- EEBDs missing from the positions on the fire control plan, or the plan not updated after units were moved.28
- No spares, or no training unit, where the flag requires them, often because the spare was used in a drill and never replaced.689
- Crew who think the EEBD is for tank entry or fire-fighting. PSC officers ask during drills, and the 2023 Tokyo MOU campaign found 8.44% of witnessed fire drills unsatisfactory.10
FAQ
Can an EEBD be used to rescue a casualty from an enclosed space?
No, not to go in. The FSS Code forbids its use for entering oxygen-deficient voids or tanks. MSC/Circ.849 allows fire-fighters to carry an EEBD only to give it to a person who needs emergency help. The rescuers themselves wear SCBA.
Does the EEBD count as one of the breathing apparatus for the fire-fighter's outfit?
No. It is a separate item under SOLAS regulation II-2/13. The fire-fighter’s outfit needs an SCBA that meets FSS Code chapter 3, paragraph 2.1.2.
Who decides how many EEBDs the engine room needs?
SOLAS sets the principle, MSC/Circ.1081 sets the usual positions, and the Administration may decide a different number or location for the layout and manning. Some flags, such as Bahamas, require a risk assessment agreed with the RO.
Do oxygen-cartridge EEBDs need hydrostatic testing?
Several flags accept the maker’s fixed service life without hydrostatic tests for devices with small oxygen cartridges, for example the Marshall Islands and Bahamas. Follow the maker’s instructions and your flag notice.
Quiz6 questions
Sources
- 1
IMO Resolution MSC.98(73), International Code for Fire Safety Systems (FSS Code), adopted 5 December 2000, chapter 3, section 2.2. https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MSCResolutions/MSC.98(73).pdf
- 2
IMO Resolution MSC.99(73), revised SOLAS chapter II-2, adopted 5 December 2000, regulations II-2/13.3.4, 13.4.3, 14.2.2.3 and 15.2.2.2 (consolidated numbering). https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MSCResolutions/MSC.99(73).pdf
- 3
IMO MSC/Circ.849, Guidelines for the performance, location, use and care of emergency escape breathing devices (EEBDs), 8 June 1998, annex sections 2, 4, 5 and 6 (copy published by the German flag administration). https://www.deutsche-flagge.de/de/redaktion/dokumente/interpretationen/solas/ii-2/msc-1-circ-849-guidelines-for-the-performance-location-use-and-care-of-emergency-escape-breathing-devices-eebds.pdf
- 4
IMO MSC/Circ.1081, Unified interpretation of the revised SOLAS chapter II-2, 13 June 2003, interpretations of regulations II-2/13.3.4 and 13.4.3 (copy published by Traficom, Finland). https://www.traficom.fi/files/media/regulation/22660-MSC_1-Circ_1081_-_tulkinta_SLS_II-2.pdf
- 5
IMO MSC.1/Circ.1432, Revised guidelines for the maintenance and inspection of fire protection systems and appliances, 31 May 2012, paragraphs 4.5 and 7.8.3 (copy annexed to Cayman Islands Shipping Notice 01/2014 Rev 2). https://www.cishipping.com/system/files/notices/documents/CISN%202014_01%20Rev%202%20with%20Annex.pdf
- 6
Liberia Maritime Authority, Marine Notice FIR-001 Rev. 02/26, Fire-protection systems and appliances, section 8. https://www.liscr.com/sites/default/files/online_library/FIR-001.pdf
- 7
Republic of the Marshall Islands Maritime Administrator, Marine Notice 2-011-14 Rev. Aug/2025, section 11. https://www.register-iri.com/wp-content/uploads/MN-2-011-14.pdf
- 8
Bahamas Maritime Authority, Marine Notice 81 version 1.1, Emergency escape breathing devices (EEBDs), 31 January 2023, sections 4 to 7. https://www.bahamasmaritime.com/wp-content/uploads/2023/01/MN081-Emergency-Escape-Breathing-Devices-EEBDs.pdf
- 9
Cyprus Shipping Deputy Ministry, Circular No. 41/2021, section 8 (annexed to IRClass Technical Circular 008/2022). https://www.irclass.org/media/5913/technical-circular-no008.pdf
- 10
Tokyo MOU, Report of the 2023 Concentrated Inspection Campaign (CIC) on Fire Safety, section 2.1 and table 1. https://www.tokyo-mou.org/wp/wp-content/uploads/CIC-ON-FIRE-SAFETY-2023-Report-public.pdf
Rules checked 20 October 2026. VSL Safety is not an approved training provider and doesn't issue certificates. These lessons don't replace STCW training, or the manufacturer's training and certification that service technicians need.
