Asbestos Free Ships- “Certificate is NO Warranty”

By

Narayana Prakash Project Manager, [New Buildings]

G.T.R. Campbell Marine Consultants Ltd, Nassau, Bahamas

Abstract:

Asbestos containing materials are used on almost all vessel in some form even if originally not installed. Valued for its resistance to heat and fire, asbestos was once widely used throughout the 20th century, as well as being a relatively low cost construction material. However, the high serious health risks outweigh its benefits. Asbestos is banned in many countries due to the dangers it is known to cause to both health and the environment. Now a stage has come that Asbestos has been put in a place of no importance and banned. To ensure smooth access to international ports and recycling yards, now is the time to have inventory of hazardous materials documents for all the vessels. There lies another “real challenge” that even scrap vessels must be devoid of these materials. The momentum for a global asbestos ban is escalating day by day and more nations joining in but the time lost in getting to a total asbestos ban still leaves a death sentence hanging over hundreds of thousands of people.

The need to address asbestos-containing materials (ACM) as a hazard is no longer under debate but a widely accepted fact

Introduction:

Asbestos has been a long-standing problem for ships , IMO has dealt with the issue under the SOLAS Convention since 2002,.The SOLAS Convention implemented a ban on installation of asbestos on newbuildings and for existing ships.

Before SOLAS convention 2002 all ships had a concession , where new installation ACM’s shall be prohibited except for:

• vanes used in rotary vane compressors and rotary vane vacuum pumps; • watertight joints and linings used for the circulation of fluids when, at high

temperature (in excess of 350ºC) or pressure (in excess of 7 x 106 Pa), there is a risk of fire, corrosion or toxicity; and

• supple and flexible thermal insulation assemblies used for temperatures above 1000ºC.

All new buildings since 2002 have had a certificate called ”Asbestos Free ”.It has come to light that it is only in ”Paper” called ”Certificate” by the Builder .The certificate is not a Warranty for asbestos free ships. Recently according to the IMO draft report: “The [Dutch] delegation reported that they were, recently, confronted with a new building ship, provided with statutory certificates, and with an asbestos free declaration, that appeared to have more than 1,000 gaskets containing asbestos in the piping systems on board.It took nearly six months to remove the huge quantity of asbestos and that the ship was misleadingly declared asbestos free.

Asbestos on ships is now a hot topic as the International Maritime Organization looks to introduce the Inventory of Hazardous Materials and the European Union begin to crack down on safety inspections at its ports.

As of January 1, 2011, the installation on ships of all types of asbestos-containing material was prohibited by the International Maritime Organization (IMO), the United Nations agency responsible for the “safety and security of shipping and the prevention of marine pollution by ships.”

What is Asbestos, and Why are We Concerned with its Use?

Asbestos means “Unquenchable” in Greek

Asbestos is a group of naturally occurring fibrous silicate minerals. Asbestos fibres are 50 to 200 times thinner than a human hair, can float in the air for a long time, can be invisible to the naked eye and can be breathed into the lungs. Asbestos includes chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these materials. It was once used widely in the production of many industrial and household products (such as building materials and vehicle brakes, to resist heat and corrosion)because of its useful properties, including fire retardation, electrical and thermal insulation, chemical and thermal stability, and high tensile strength and absorbs sound.

Figure : Some asbestos forms (Image courtesy of QBM)

Today, however, asbestos is recognized as a cause of various diseases and cancers and is considered a health hazard if inhaled. The ILO estimates that over the last several decades 100,000 deaths globally have been due to asbestos exposure, and the

WHO states that 90,000 people die a year globally because of occupational asbestos exposure.

Asbestos only becomes a danger when it is disturbed, causing the fibers to become airborne. This is commonly referred to as friable asbestos, while intact asbestos is referred to as non-friable asbestos. Friable asbestos has become airborne and the human lungs are now susceptible to breathing in the airborne fibers. Research has yet to determine a safe level of exposure to asbestos, but one thing is for certain; the more prolonged the exposure, the greater the risk becomes for developing an asbestos related disease.

Asbestos and Health Hazards:

Many leading environmental and worker safety groups, however, have maintained that there is no "safe" level of asbestos exposure.There is a longstanding scientific finding that asbestos exposure can lead to mesothelioma, a rare and often fatal form of cancer that targets the fluid sacs around the lungs.

Mesothelioma is a rare form of cancer almost exclusive to asbestos exposure. This is the most serious of the asbestos-related cancers, and may develop from exposures ranging from heavy, daily exposure to minimal exposure. Its latency period of from 20 to 50 years or more . it is often difficult for victims and their families to imagine that this can occur after so long a period of time.

World reaction:

The U.S. Environmental Protection Agency (EPA) tried to ban asbestos-containing materials (ACM) entirely by establishing a ban in 1989. The asbestos-producing companies sued to have the ban overturned and they succeeded in 1991 when the Fifth Circuit Court of Appeals revoked the ban. After this ruling, the ban was reduced to just six types of ACM, which included the manufacturing, importing, processing, or distribution of those six in commerce.The six types of ACM banned in the United States include:

1. Flooring felt 2. Commercial paper 3. Corrugated paper 4. Roll board 5. Specialty paper.

6. New uses of asbestos-products that have historically contained asbestos.

Today we can see the most of the countries have joined hands to save their population and has banned this life taking material.

INTERNATIONAL CONVENTION AND STANDARDS FOR WORKING WITH ASBESTOS . The International Labor Organization (ILO) established an Asbestos Convention (C162) in 1986 to promote national laws and regulations for the “prevention and control of, and protection of workers against, health hazards due to occupational exposure to asbestos.”17 The convention outlines aspects of best practice: Scope and Definitions, General Principles, Protective and Preventive Measures, Surveillance of the Working Environment, and Workers’ Health. As of March 4, 2008, 31 countries had ratified the Convention; 17 of them have banned asbestos.

Role of IMO:

Beneath the growing debate, IMO had put a total Ban on Asbestos in any form on new buildings with due verification to statement of facts.

Despite the clear and unambiguous prohibition of asbestos containing materials (ACMs), asbestos is still found on various locations on board ships. During inspections, asbestos has been found in such places as fire blankets, joints and insulation materials, types of sealants, friction material for brakes, wall and ceiling coverings, cords, remnants, electric fuses, etc. Moreover, ships that initially were free of asbestos appear to have asbestos on board as a result of repairs at shipyards and/or of purchasing spare parts at a later stage. Implementation by Regulations: IMO’s intentions was very clear: 1. Raise awareness among maritime Administrations, recognized organizations, Shipbuilders and ship repairers, equipment suppliers and all other parties concerned of the fact that asbestos is still being used on ships, notwithstanding its prohibition . 2 .Highlight that the principal means of addressing the issue of asbestos being found on board ships in contravention of the aforementioned provisions of SOLAS rests with shipyards and ship suppliers purchasing and installing asbestos free material; 3. Underline the importance of proper training of surveyors and inspectors in detecting asbestos and ACMs on board ships;

4. Prevent any further use of asbestos on board ships; and 5. Stress the importance of maritime Administrations taking appropriate action in case ACMs are found on board ships, in contravention of the aforementioned provisions of the SOLAS Convention

NEW INSTALLATIONS OF MATERIALS CONTAINING ASBESTOS SOLAS 74- Chapter II-1 – Reg. 3-5 Applicability on seagoing ships 1. Ships built before 1st July 2002 are allowed to have ACMs (Asbestos Containing Materials) on board. However, the ACMs are only allowed as long as they did not pose risk to the crew’s health. The crew should be aware of the dangers of asbestos and should know how to deal with asbestos in case disturbance of the ACMs cannot be avoided . 2.Since 1st July 2002, new installation of ACMs on board ships has been allowed only in exceptional cases. 3. From 1st January 2011, new installation of ACMs on board all ships will, without any exception, no longer be allowed. When asbestos is detected on board, in contravention with SOLAS Chapter II-1 Reg. 3-5, action should be taken to have it removed. The removal – assigned to professional asbestos removal companies – should take place within a frame of three (3) years from the date when the contravention has been found and should be conducted in close consultation with this Administration. In such cases, a suitable Exemption Certificate should be issued by this Administration.

Recognizing asbestos containing materials 1 Asbestos is used for its specific characteristics such as fire resistance, thermal insulation, electrical insulation, strength, flexibility, etc. Therefore, asbestos is used in various locations throughout a ship. Inspectors should be aware of the large number of probable asbestos applications on board. 2 Asbestos is a fibrous material and can often be identified visually on that basis. However, most asbestos is used on board in materials where it cannot easily be identified visually. 3 It is recommended that, whenever an item or material is to be installed, it is ensured that the item or material has a statement of compliance, or similar, with the relevant SOLAS regulation. This may take the form of an "asbestos free declaration". 4 Although asbestos in most ACMs can only be ascertained by experts in specialized laboratories, it is possible to provide training to crew members, surveyors and inspectors in identifying materials that might be ACMs. As a result of such training, the crew and ship surveyors and inspectors can avoid health risks by having the suspected material sampled and analysed first. In case sampling and analysing by experts is not possible, the crew and ship surveyors and inspectors should treat the material as if it contains asbestos in order to avoid possible health risks. Training of surveyors and inspectors The first step in determining whether or not asbestos is present and a hazard is identifying the substance itself. Asbestos is frequently off-white in color, though less common types may be blue or brown. Its appearance generally depends on the material it was mixed with to make it workable: cement, polymers, starch, asphalt, or other binders. Here’s where to look for asbestos and asbestos containing materials:

1 Surveyors and inspectors that are charged with asbestos investigations on board ships should be trained in recognizing asbestos and ACMs. They should also be trained in taking samples and should be instructed when to call in experts to conduct the investigation. 2 Surveyors and inspectors should be aware of the dangers of exposure to asbestos and should, while performing their corresponding duties, take all necessary precautions. GUIDELINES FOR MAINTENANCE AND MONITORING OF ON-BOARD MATERIALS CONTAINING ASBESTOS A maintenance and monitoring programme with the principal objective of minimizing exposure to asbestos fibres of anyone on board (passengers, crew, riding crews, maintenance personnel in port) while the ship is in service. (i.e., as opposed to when the ship is in a repair or dry-dock status with minimal crew members or only shore-side personnel on board). Inventory and condition assessment of asbestos-containing materials 1 The Company should have an initial ship inspection performed by a qualified professional to investigate the possible presence of asbestos-containing materials on board the ship and, if any are identified, to locate them and assess their condition. The inspection should serve as the basis for establishing an effective maintenance and monitoring programme for dealing with the asbestos in the ship.

2 In the case of flake coatings, lagging or false ceilings containing asbestos, their condition should be assessed by completing the evaluation checklist , in particular, the accessibility of the materials and products, their degree of degradation, their exposure to shocks and vibration and the presence of air currents in the area. Air sampling of dust measurement may be used as one tool to help provide a more complete assessment of the ambient conditions on board. Maintenance and monitoring programme 1. If asbestos-containing material is located, a maintenance and monitoring programme should be developed for that ship, based on the inspection and assessment data. The programme should be implemented and managed conscientiously with due respect to Notification,surveillance,Control ,Work practices,Record keeping and training. 2. In the case of flake coatings, lagging or false ceilings containing asbestos, depending on the diagnosis , the company should establish appropriate thresholds and timescales for undertaking any necessary repairs or abatement, taking into account any national regulations. Abatement actions, planned repair and removal of asbestos-containing materials Abatement actions should be selected and implemented when necessary. In some instances, due to the condition of asbestos-containing materials or upcoming ship repairs or modifications, a Company may decide to take other abatement actions to deal with asbestos-containing materials in the ship. These response actions could include: encapsulation (covering the asbestos-containing materials with a sealant to prevent fibre release), enclosure (placing an air-tight barrier around the asbestos-containing materials), encasement (covering the asbestos-containing materials with a hard-setting sealing material) or repair or removal of the asbestos-containing materials. Qualified, trained and experienced contractors should be used for any of these actions. The Company should be aware of any national and local regulations that pertain to abatement actions to deal with asbestos-containing materials.

Scrapping vessels in India:

INDIA has become the preferred dumping ground for the world's hazardous substances and industrial wastes, which are often toxic and life-threatening. Much of all this waste reaches Indian shores on ships. Interestingly, these vessels are also sent to India when they complete their sailing life. While developed countries can afford the luxury of banning the use of hazardous substances and even the processes that generate them,

governments of developing nations such as India seem to think that they need every dollar and every job that the processing of such substances creates.

Indeed, the international waste industry has arrived in India and is dumped on India, as Asbestos ,an item , carcinogenic that is banned in all developed countries. Of the 1.2 lakh tonnes of asbestos used in India every year, India imports over one lakh tonnes. Over 80 per cent of the imports come from Canada (which exports nearly all the asbestos it mines) where its use is banned. India's asbestos industry, with a turnover of Rs. 800 crores, is spread over 15 States. India imports raw asbestos worth over Rs.40-50 crores every year. Although it banned the import of asbestos waste in 1998, over 500 tonnes were imported in 1999-2000.

The Indian Government must ban asbestos containing materials coming by way of vessels for scrap.

Impact for Shipowners and Charterers:

The solution is for ship owners, operators and class societies to only accept asbestos certification from independent and appropriately skilled providers especially where asbestos registers and risk assessment are undertaken.

Ship owners need to become more aware of the presence of asbestos on ships, as an increasing amount of the world’s ports will now turn away new build ships that do not possess the correct asbestos surveys to prove they are asbestos free. Especially in Australian waters it is difficult to operate .An Australian operator has been fined $180,000 for failure to maintain a safe workplace by not properly managing the presence of asbestos on the ship.

Charterers of some vessels have in their interest included “asbestos free” as part of charter party requirements. Off hire costs when asbestos is found on board after contract has started may be significant.

Certificate has no Warranty:

The certificate issued builders, is only valid at the time of delivery and true in every respect . Now that every New Builds must maintain a File containing all equipment and material suppliers who give a asbestos free certificate . Subsequent entry of spares and stores will need am “Asbestos Free Certificate”

Subsequent entry of the ACM on board must be regulated and this can be achieved by following IMO regulations. Surveyors and Inspectors will need to inspect the Asbestos free Certificates and the stores and spares list when last supplies were made and check if any possible of new entry of asbestos could have been made on board.

Substitution products : Experience has shown that all of the mentioned fields are by now covered by suitable substitution products. It is possible to find substitutes in all the above mentioned cases, however, there is not one universally applicable material suitable for all the cases above, but specific ones exist for all technical problems. It is therefore necessary to identify the specific needs of a given application beforehand, and then to find the suitable substitution product. Experience has shown that in many cases where asbestos had been used before, substitution products need not fulfill the high requirements for example with regard to thermal stability that were guaranteed by asbestos itself. Substitution products are by now available which are tailored to the specific necessities of a given application. A very important aspect is in all cases that some of the substitution products may have hazardous properties themselves. So a very careful analysis in this respect must be performed as well. Efforts must be to develop asbestos free graphite ,fibre ,PTFE and Mica based gaskets and new testing techniques to help harmonise standards Surviving amidst Asbestos: As a general recommendation the following steps should be performed when a company tries to solve the asbestos problems in their workplaces. 1. Get a clear picture about what your asbestos containing product can do, and what

the substitution product needs to be able to do! This will lead to a better understanding of the acquisition process and a list of available substitution products from a technical viewpoint.

2. Check possible health risks from available substitution products. This will lead to a narrowing of possibilities.

3. Weigh your substitution work according to cost, effort, and necessity. It will also result in a proper action list.

4. Then go to work according to the action list as of above – but do not forget that the substitution process can be hazardous as well! Workers' protection is very important here.

5. Stop only when you have replaced all asbestos containing materials and processes. The question is not whether to perform substitution but when to start which part of this process.

Experience has shown that substitution can be done, but that it is a long and sometimes tiresome procedure a procedure without alternative.

Challenge with Goal Based Regulation:

Goal based regulations require higher level of training in order to result in same practice. Assurance Evidence Level [ AEL] must be introduced for verification and must be accepted by all parties. Establishing a risk based regulatory framework to facilitate first principle approaches to safety. Applying the safety level approach to verifying whether the new regulations comply with Goal based standards.

Phasing out asbestos containing materials from older ships is a challenge and Ship staff and operators must come forward with phasing out procedures by saying “NO” to ACM.

Global Ban: A global ban on commercial use of asbestos has been urged by the Building and Wood Workers Federation (IFBWW), the International Metalworker’s Federation, the International Trade Union Confederation, the government of France, and the distinguished scientific group Collegium Ramazzini. In June 2006, the General Conference of the ILO adopted a resolution to “promote the elimination of all forms of asbestos and asbestos-containing materials.” Now with IMO’s TOTAL BAN –there is NO ENTRY region in sea and seagoing vessels.

Conclusion:

Good practice is to minimize the health risks associated with ACM by avoiding their use in new construction and renovation, and, if installed asbestos-containing materials are encountered, by using internationally recognized standards and best practices to mitigate their impact.

In case of Asbestos containing Materials (ACM’s) “Earlier the better “ is the preferred choice and will in long way save many life’s who were born in this ACM earth and who are due to be born.

References:

1. MSC/Circ.1045- GUIDELINES FOR MAINTENANCE AND MONITORING OF ON-BOARD MATERIALS CONTAINING ASBESTOS .

2. SAFETY | Netherlands raises asbestos ship case at IMO-source-lloyds list 3. . Pelucchi C, Malvezzi M, La Vecchia C, Levi F, Decarli A, Negri E.: "The

mesothelioma epidemic in Western Europe: an update." British Journal of Cancer. 2004; 90(5): (pp) 1022-1024.

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5. Hemminki K, Li X.: "Mesothelioma incidence seems to have leveled off in Sweden." International Journal of Cancer. 2003;103: (pp) 145-146.

6. OSHA Fact Sheet-US Dept of Labour Occupational Safety and Health Administration 2002.

7. MSC.1/Circ.1379, 8 December 2010 UNIFIED INTERPRETATION OF SOLAS REGULATION II-1/3-5.

7. MSC.1/Circ.1374, 3 December 2010INFORMATION ON PROHIBITING THE USE OF ASBESTOS ON BOARD SHIPS

8. Landrigan PJ, Soffritti M. “Collegium Ramazzini Call for an International Ban on Asbestos.” Am. J. Ind. Med. 47: 471-474 (2005).

8. The International Ban Asbestos Secretariat keeps track of national asbestos bans. http:// bassecretariat .org./ lka_alpha_asb_ban_280704 .php.

10. Targeted prevention strategies for asbestos related diseases Substitution of asbestos Dirk Dahmann

11. Magic Mineral to Killer Dust- Dr Geoffrey Tweedale -PPT Presentation. About Author: Mr.Narayana Prakash is Ex-Chief Engineer working as Project Manager [ New Buildings] with G.T.R.C. Marine Consultants Ltd, Nassau ,Bahamas, leading a Team of Naval Architects /Chief Engineers/Coating supervisors for a 20 K Bulk Carrier Project in India.