It has been brought to our attention that it is common practice in many yards to use rubber based insulation materials such as Kaiflex, Armaflex or similar to insulate sanitary piping (hot and cold water) in the accommodation.

These types of insulation are not non-combustible and shall not be used other than for piping for cold service systems, meaning refrigerated system.
SOLAS Ch. II-2 Reg. 5.3.1 regulates the use of combustible materials on board ships:

"3.1.1 Insulating materials
Insulating materials shall be non-combustible, except in cargo spaces, mail rooms, baggage rooms and refrigerated compartments of service spaces. Vapour barriers and adhesives used in conjunction with insulation, as well as the insulation of pipe fittings for cold service systems, need not be of non-combustible materials, but they shall be kept to the minimum quantity practicable and their exposed surfaces shall have low flame spread characteristics."

A definition of ‘cold service’ can be found in IACS UI SC 102 and MSC/Circ.1120.
The limitation mentioned on page 2 of DNV type approval certificates for these products reads:

"May be used on cold service pipe work/ fittings for refrigeration system everywhere onboard, and for pipe work, fittings, air ducts and tanks insulation in cargo areas, mail rooms, baggage rooms and refrigerated compartments of service spaces, and exterior locations. Extent of application is to be considered and accepted for each case/project. Each product is to be supplied with its manual for installation and use. The use of such insulation materials is limited to what the type approval certificate and SOLAS allows. Piping for hot and cold sanitary water cannot be considered ‘cold service pipe work/fittings’, and therefore this kind of insulation is not accepted for use on such pipes."