The EU Ship Recycling Regulation, that entered into force on 30 December 2013, aims at facilitating early ratification of the Hong Kong Convention 2009, both within the EU and in other countries, by applying controls to ships and ship recycling facilities. It aims to ensure that vessels are recycled in EU-approved facilities worldwide.
EU legislation sets additional requirements compared to the Hong Kong Convention for the Inventory of Hazardous Materials (IHM), by including the substances Perfluorooctane sulfonic acid (PFOS) and Hexabromocyclododecane (HBCDD) in the list of hazardous substances.
As explained, firefighting foam is expected to have the highest concentration of PFOS and the most relevant material to analyse and check for inclusion in the IHM Part I.
Protective coatings for fabrics such as carpets, textiles, upholstery and electronics such as semiconductors not integral to ship in operation, is also relevant, however falling out of scope with regards to IHM Part I in general. Paint and coatings may be relevant but it is not expected to find PFOS in paint and coatings because other surfactants are probably used and it is not detected in paint in any samples looked at (inventories in 21 ships).
For PFOS in firefighting foam, global, regional and national legislation as well as shelf life need to be taken into consideration.
After 2010, PFOS containing firefighting foams is less likely on board vessels at all, unless vessels built in China, where it at that time and still is legal to produce and sell. Having in mind that the reporting limit is set to 0,001%, incomplete emptying of tanks and hoses, previously holding PFOS containing foam concentrate, may contaminate new non-PFOS containing foam above the threshold level, hence sampling and analysis is recommended.
Sampling should in general follow the EMSAS’s Best practice guidance on the inventory of hazardous material (2016) and the IMO resolution MEPC.269(68) Guidelines for inventory of hazardous material. Health, safety and environmental (HSE) aspects during sampling should be focused on proper ventilation, especially if working in confined spaces, use eye protection and gloves and have available safety data sheets and eye wash bottles.
The Basel Convention technical guidelines for the environmentally sound management of wastes consisting of, containing or contaminated with PFOS, its salts and PFOSF, list two methods for destruction and irreversible transformation:
- Cement kiln co-incineration and
- Hazardous waste incineration.
Destruction and irreversible transformation methods applicable for the environmentally sound disposal of wastes with a content of PFOS, its salts or PFOSF at or above 50 mg/kg.
HBCDD in polystyrene foam (EPS and XPS) is the most relevant area of use. HBCDD is found in textiles (carpets) in IHM’s and can be found on board all vessels types and should in particular be considered in the IHM Part I for insulation used in the walls and ceiling of cold provision rooms.
Special attention is recommended to insulation on board reefers, insulation in refrigerated containers and tank insulation of LPG, LEG and LNG cargo tanks.
As for PFOS, sampling should in general follow the EMSAS’s Best practice guidance on the inventory of hazardous material (2016) and the IMO resolution MEPC.269(68) Guidelines for inventory of hazardous material. Particular HSE aspects have not been identified for sampling, as the most relevant is polystyrene foam.
No standards exist for analysis of HBCDD. Existing standards used in IHMs is for brominated flame retardants in general and it is uncertain to what extent these standards are quantitative for HBCDD, and they cannot discriminate between the most common “types” of HBCDD.
As described for PFOS, the same methods listed by Basel Convention are applicable to HBCDD as well.
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