A recent experience not only highlights the value to ship owners of having an approved Inventory of Hazardous Materials (IHM) for their vessels, but also reaffirms the need to ensure that surveys are undertaken correctly.
Lucion Marine was recently appointed to assist a major cruise line with work on one of their 2008-built cruise vessels. In this particular case a shipyard, on a pre-refit visit, claimed that an area where a new scrubber installation was planned contained asbestos in the bulkhead fire insulation.
At the request of the ship’s technical manager, Lucion Marine subsequently met the shipyard and its asbestos surveyor onboard the ship in Jamaica. Following discussions we then took mutual testing in three on-board locations where the shipyard claimed asbestos was present. In addition, over the course of six hours, we took an additional 90 samples throughout the uptakes and rushed the samples back to our laboratory for analysis.
Within two days of leaving the ship and completing our testing, we were able to confirm to the vessel owner that NO asbestos was present. In our opinion, we believe that the situation was caused through the initial use of an inexperienced company involved in the first assessment; in fact we have learned that it was the surveyors first time on a ship.
We also suspect that some of the sampling equipment used in the initial ship survey may have been contaminated from a previous job and subsequently contaminated the samples taken from the cruise liner.
So in the end this may appear to be a satisfactory outcome for the cruise liner, with work on the refit being able to proceed unhindered, but that does not take into account the extra costs and working disruption involved. For example, there is the lost time and additional surveying costs incurred, as well as the travel expenses involved in sending specialist surveyors to the shipyard, not to mention the lost management and working time after the shipyard first mentioned their concerns.
Unfortunately, this sort of situation is not an isolated case. Lucion has been involved with two other ship owners that have been accused of having asbestos insulation in a work area, only these other situations proved to be more aggravating as the claims happened during refit works, which were then stopped causing considerable consequential delays and costs until thorough testing had been carried out.
Of course, many Government marine authorities already recommend that all ship owners should have an ISO17020 specialist asbestos survey carried out to eliminate the asbestos risk to demonstrate that a ship is asbestos free.
However, during our work we have found asbestos in over 80% of new ships and we work regularly with prudent ship owners such as Maersk, BP and the Royal Navy to have their new ships surveyed before delivery from the shipyard.
This is a very sensible approach and the need for this has been created because ship builders only base their "asbestos free certificate" on suppliers’ material declarations, with no direct testing of supplied parts or components.
In addition, the term ‘asbestos free’ can itself be very misleading as a result of different international thresholds that govern and control its precise definition. For example, in the USA up to 1.0% asbestos content can be permitted, while in the EU it is 0.1% and 0% in Australia. In China there is no official standard and in our work with ship owners and shipyards there we have found as much as 15% asbestos in materials that have been declared ‘asbestos free’.
On the same theme it also cannot be assumed that sister ships built to the same design by the same shipyard will be the same in terms of potential asbestos content. Recently we surveyed a series of six French new builds in Korea and found asbestos in the fire door seals of the fourth ship, highlighting that the supply chain can be affected at any time.
In such circumstances it is worth noting that 60% of an IHM inspection is an asbestos survey, so having a professional and effective IHM completed will eliminate the risk of any contamination claims during a refit or with owner-supplied items.
With reference to the regulations, the Hong Kong Convention requiring all ships to have an IHM was implemented to ensure a ship had a formal record of any hazardous materials on board, to ensure that when the ship is recycled an accurate ship demolition plan can be produced, with specific attention to the safe handling of any hazardous materials present.
This regulation is still awaiting ratification and we expect, if the Ballast Water Treatment regulation is a guide, that this could be achieved by 2022. In the meantime to advance the situation, the EU has issued a regulation that all ships with EU flag, or any ship visiting an EU port, must have a Classification society approved IHM by December 2020.
It is important that a ship owner selects an experienced ISO 17020 accredited marine specialist company, as the IHM process requires that the sampling plan has to be first approved by class prior to the survey being undertaken. This can be timely and costly if the plan is not approved on the first submission. After the survey the class society will then review the report and either approve or make recommendations on the report, so it is cost effective to get the report correct on the first submission, then class can issue a certificate of compliance which is a component of the ships annual certification.
In summary, it is short sighted for ship owners to take the view that only those vessels visiting EU ports require an IHM and clearly, in time, all ships will have to be compliant with the Hong Kong Convention.
But more than this, the benefits of an IHM can go much further. In the longer term, proving a ship is asbestos free can of course remove the risk of potential exposure claims from crew members and, as Lucion’s recent experiences have shown, in the short term a proactive decision to implement IHM surveys across a fleet can remove the possibility of the wrong diagnosis of a shipyard or contractor during refit or repair works – avoiding additional costs and unnecessary delays.
The views expressed in this article are solely those of the author and do not necessarily represent those of SAFETY4SEA and are for information sharing and discussion purposes only.
About John Chillingworth, Senior Marine Principal, Lucion Marine
John Chillingworth is a former chief engineer on Cunard Line’s QE2 liner and marine technical manager who has over 27 years’ experience in dealing with marine asbestos and hazardous materials. He is currently a senior marine principal at Lucion Marine. The firm provides specialist environmental services to the international marine sector, specifically providing advice on the management of hazardous materials to both working and end-of-life vessels. The firm’s team of surveyors are experienced and accredited by both Lloyds Register for the completion of Inventory of Hazardous Materials documents and UKAS accredited for the inspection and testing of asbestos.