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Asbestos on ships

How to manage it safely



Lloyd’s Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually andcollectively, referred to in this clause as ‘Lloyd’s Register’. Lloyd’s Register assumes no responsibility and shall not be liable to any personfor any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that

person has signed a contract with the relevant Lloyd’s Register entity for the provision of this information or advice and in that case anyresponsibility or liability is exclusively on the terms and conditions set out in that contract.



Asbestos on ships – how to manage it safely

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Contents

Foreword 3

Part 1 – A history of asbestos 41 What is asbestos 42 The rise of asbestos 73 Health and regulation 104 Testing for asbestos 14

Part 2 – Asbestos on board ships 171 The increased risk in shipping 17

2 Where is asbestos found on ships 183 Regulation 214 How the marine industry’s stakeholders

can protect their workers 275 Tools for achieving best practice in management 30

Appendix – Common asbestos areason board ships 36




2




3

Foreword

This publication should help shipowners and operators understand how to deal with asbestos on board their shipsand fleets and ultimately achieve compliance with maritime asbestos regulations from the International MaritimeOrganization (IMO).

But it also takes a wider look at the material, exploring its history, composition and health effects in order tounderline the vital importance of managing it correctly.

The worldwide death toll due to asbestos-related diseases is sobering. Globally, it is estimated that more than107,000 people die each year from mesothelioma, lung cancer and asbestosis (the three major asbestos-relateddiseases) as a result of occupational exposure1. And due to the material’s delayed health effects we have yet to

reach the predicted peak in fatalities in many places.

Far from being a problem of the past, asbestos is still produced in many countries (including China and Russia) andis still widely used, particularly in developing countries. And it is of course present in many existing buildings andstructures, including ships.

Yet management of asbestos around the world is improving. Most industries and countries are increasingly awareof the risks and huge advances have been made in the amount of asbestos used and particularly the type: nearlyall of the asbestos produced worldwide is now chrysotile, or ‘white’ asbestos2 which is considered the leastdangerous form.

What is vital is that we continue to guard against the risks that asbestos presents. Within the maritime industry,this publication should help further this aim.

Lloyd’s Register is particularly indebted to the Imperial War Museum and HMS Belfast for many of the photographsthis publication contains. These have been invaluable in helping us illustrate where asbestos can be found on boardships and how it should be managed.

Robin TownsendRegulatory Affairs Lead Specialist, Lloyd’s Register

1 World Health Organization (2010). Elimination of asbestos-related diseases (Fact sheet N°343).Available at: http://www.who.int/mediacentre/factsheets/fs343/en/index.html

2 U.S. Geological Survey (USGS) (2013). Asbestos Statistics and Information.Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/#pubs (Accessed: March 11, 2013)




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1. What is asbestos?

Asbestos is a generic name given to the fibrous varietyof six naturally occurring silicate minerals3. Silicateminerals make up a large proportion of the rocks onthe planet. All asbestos rocks occur in, or separate veryeasily into, very small fibres or fibrils with a diameter ofonly a few nanometres.

The two groupsAsbestos is generally categorised in two groups:amphibole and serpentine. There are five amphibole

asbestoses and one serpentine. Amphibole asbestos isconsidered more dangerous than serpentine.

Table 1: Types of asbestos and their relative uses and dangers

Part1

Ahistoryo

fasbestos

A s b e s t o s f a m i l y

Type Name CAS Number Relative use in

A: shipbuilding

B: other industries

C: total use today

Relative danger

A: mesothelioma

B: lung cancer

Actinolite

Amphibole

(five types)

Short, sharp fibres

77536-66-4

A: Low

B: LowC: 0

Amosite

(grunerite) (brown)12172-73-5

A: Medium

B: Low

C: 0

A: 100

B: 10-50

Anthophyllite 77536-67-5A: Low

B: Low

C: 0

Crocidolite (blue) 12001-28-4

A: Medium

B: LowC: 0

A: 500

B: 10-50

Tremolite

Chrysotile

Amphibole

(serpentine

one type)

Long, curly fibres

77536-68-6A: Low

B: Low

C: 0

12001-29-5A: high

B: high

C: 100

A: 1

B: 1

The big three: blue, brown and whiteThe most commonly recognised types of asbestosare blue, brown and white, and these are properlycalled crocidolite, amosite and chrysotile asbestos.Crocidolite and amosite are amphiboles andchrysotile is the only serpentine. Their commonnames relate to their natural colour and have nothingto do with how they appear in products: it is infact impossible to tell the type of asbestos fromthe colour of a product.

3 R.L. Virta (2006). Worldwide asbestos supply and consumption trends from 1900 through 2003: USGS Circular 1298.Available at http://pubs.usgs.gov/circ/2006/1298/




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Crocidolite asbestos (blue)Crocidolite asbestos is considered the most dangerousform (see Table 1 for the relative risks it presents).Some medical reports describe it as 100 times moredangerous than chrysotile asbestos. It has smaller,more jagged particles than either amosite or chrysotileasbestos, and has a higher iron content4. It is alsohighly resistant to acid – a feature that might havefavoured its use in some applications.

It is thought that the characteristics of crocidoliteasbestos allow it to easily penetrate the outer coatingof the lungs (the pleura) where it can cause some ofthe worst asbestos-related diseases. We also knowfrom studies that crocidolite asbestos is far morepersistent in the body than other forms.

Amosite asbestos (brown)Amosite5 asbestos is considered to be a little lessdangerous than crocidolite, but still considerablymore dangerous than chrysotile.

Amosite asbestos, like other amphibole forms ofasbestos, consists of straight fibrils with a smalldiameter which migrate more readily to theperiphery of the lungs and penetrate the pleurawhere they can cause the disease mesothelioma(see page 12).

Chrysotile asbestos (white)Chrysotile asbestos is considered significantly lessdangerous than crocidolite or amosite asbestos.

Its fibrils consist of double layers which roll upinto hollow tubes with a diameter of around25 nanometres. When these long curly fibres arebreathed in they often stop in the upper respiratorytract and are therefore more readily cleared from thelungs. Despite chrysotile asbestos’s reputation as aless dangerous form, it is often contaminated withother more hazardous forms (see “A closer look atchrysotile asbestos contamination“on page 6).

Chrysotile asbestos from Brazil (image taken from Wikimedia Commons).

4 L. Prandi, M. Tomatis, N. Penazzi and B. Fubini (2002). Iron Cycling Mechanisms and Related modifications at the Asbestos Surface. TheAnnals Of Occupational Hygiene, Volume 46, Supplement 1.Available at http://annhyg.oxfordjournals.org/content/46/suppl_1/140.abstract?sid=5d1b03f7-bd7f-4bea-9cfe-f3c7bbb8faad

5 Its proper name is actually grunerite, but it is more commonly known as amosite after the company that ran the site in South Africa whereit was mined.




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Other asbestos types

ActinoliteActinolite shares the basic characteristics of crocidoliteand amosite asbestos. It has been used, and thereforeresearched, far less than crocidolite, amosite orchrysotile. A significant characteristic of actinolite isthat it is a common contaminant of talc (see page 26)and chrysotile asbestos.

TremoliteTremolite has similar characteristics to actinolite andits use has been equally rare. It is also a commoncontaminant of chrysotile asbestos. Significantly,the amount of tremolite found in the lungs of peoplewho have died from exposure to it far outweighsthe amount they were apparently exposed to.

AnthophylliteAnthophyllite shares the characteristics of tremoliteand actinolite. It is common to see it mentioned inpaint contents as ‘non asbestos’ anthophyllite. Thisrefers to one of the major characteristics of asbestos,which causes understandable confusion – the existence

of non-hazardous types in which the fibres do nothave the same crystalline characteristics as those inthe ‘true’ asbestos forms.

Other substancesThis section leaves us with two questions which arebeyond the scope of this publication. Firstly, are thereother asbestos-like minerals that are not presentlyconsidered dangerous which might be added to thelist in the future? The brief answer is yes, one examplebeing a mineral called soda tremolite or winchiteasbestos. The other question is whether the materialsbeing used to replace asbestos may prove to behazardous in the future.

6 D. Loomis et al (2009). Lung cancer mortality and fibre exposures among North Carolina asbestos textile workers.Occupational & Environmental Medicine, Volume 66, Issue 8. Available at http://oem.bmj.com/content/66/8/535

7 Xiaorong Wang et al (2011). A 37-year observation of mortality in Chinese white asbestos workers. Thorax, Volume 67, Issue 2.Available at http://thorax.bmj.com/content/67/2/106.abstract

8 Antti Tossavainen et al (2001). Amphibole fibres in chinese chrysotile asbestos. The Annals Of Occupational Hygiene, Volume 45, Issue 2.

Available at http://annhyg.oxfordjournals.org/content/45/2/145.abstract?sid=26e21abb-5ce8-4c60-a9fd-4be5a6cc711b9 Murray M. Finkelstein and Andre Dufresne (1999). Inferences on the kinetics of asbestos deposition and clearance among chrysotile miners and

millers. American Journal of Industrial Medicine, Volume 35, Issue 4.Available at http://onlinelibrary.wiley.com/doi/10.1002/(SICI)1097-0274(199904)35:4%3C401::AID-AJIM12%3E3.0.CO;2-4/abstract

10 R.L. Virta (2006). Worldwide asbestos supply and consumption trends from 1900 through 2003: USGS Circular 1298 .Available at http://pubs.usgs.gov/circ/2006/1298/

A closer look at chrysotile asbestos contaminationChrysotile asbestos may be considered less deadly thancrocidolite or amosite but a study published in 2009 on5,770 workers at chrysotile asbestos plants in North Carolinastill showed a significantly increased risk of asbestos-relateddiseases6. A similar study in China also demonstrated strongevidence for increased mortality risks.7

One of the reasons cited for this risk is that chrysotile asbestosis often contaminated with the more harmful amphibole typesof asbestos. A number of studies have found the lungs ofvictims who were expected to have been exposed to chrysotileasbestos to contain a large proportion of amphiboles suchas tremolite.

In China, ten samples from six mines were tested and all werefound to be contaminated with tremolite although at verylow quantities.8 Another study which tested the lung tissuesof seven dead workers who had worked in a pure chrysotileasbestos mine showed the fibres in the lungs were 71%anthophyllite, 9% tremolite and just 10% chrysotile asbestos.And yet another study of chrysotile asbestos workers showed34 of 35 fibres were amphiboles.

These latter two studies showed that chrysotile asbestos hadnaturally left the workers’ bodies but that the amphibolecontaminants had persisted. These findings are reinforced byanother study which found that chrysotile asbestos fibres tendto clear from the lungs, with a half life of less than 10 years,whereas amphiboles do not seem to clear.9

Chrysotile asbestos accounted for over 95% of all asbestosproduced and consumed between 1900 and 200310.




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2. The rise of asbestos

Asbestos has been used for thousands of years thanksto its extraordinary properties. Today, it is easy toforget how asbestos revolutionised our modern lives.It protects against fire and heat, adds strength tomaterials and insulates against electricity. It is pliable,forgiving, cheap and easy to use. No modern substancecan provide all these engineering benefits and it is stillwithout equal.

A brief history of asbestos production

Pre-historyEvidence of asbestos mining has been found inCyprus from as long ago as 3,000 B.C. Analysisof archaeological finds in Finland from a slightlylater date shows that asbestos fibres were used toreinforce earthenware pots, and there is evidence thatthis practice spread within Scandinavia and Russia.Tremolite and chrysotile asbestos were mined by theRomans in the Italian Alps.

Early reported usesIn AD 800, Emperor Charlemagne was reportedas having a tablecloth that never needed cleaning.When it became dirty, he simply threw it into the fire,and it came out clean and unburnt. The Greeks andRomans may have done the same thing, as reportedby the famous historian Strabo in his “Geography”and Pliny the Elder in his “Natural History”.Indeed, it seems to have been a global habit sinceMarco Polo reported a cloth that “thrown into the

fire, remains incombustible”.

First large commercial minesAsbestos is known to have been commerciallymined in Russia in 1720. Enormous deposits ofchrysotile asbestos were found in 1844 near Asbestcity. Even today the entire area looks like a vastopen cast mine.

The industrial revolution and the steam ageModern asbestos mining in industrialised nationsbegan expending rapidly from the late 1800s, probablydue to steam technology. Vast chrysotile asbestosreserves were discovered in 1877 at Danville in Quebec,

Canada, and have been mined until very recently(see case study overleaf).

A purse, made out of tremolite asbestos, brought to London by BenjaminFranklin, in 1725. He sold it to one of the founding fathers of the British Museum.It is presently in the Natural History Museum(Image courtesy of the Natural History Museum.)

A Roman glass crematorium urn,containing bones and traces ofasbestos burial shrouds(Image courtesy of the British Museum.)




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Crocidolite asbestos was discovered in the NorthernCape province of South Africa in 1812 but was notcommercially produced until 1893. The properties ofcrocidolite made it particularly well suited for spraying,and sprayed crocidolite asbestos products were firstmarketed in the UK in 1931 by J.W. Roberts Ltd (JWR)at its factory in Armley.

Amosite asbestos deposits in Penge in the Transvaalprovince went into proper production in 1916.

Mass production and usageBy 1920, the world was using nearly 200,000 tonnesof asbestos, of which 150,000 tonnes were consumedby the US, 40,000 by Europe, 7,000 tonnes by Asiaand the Middle East, and 2,000 tonnes by Africa11.

By 1930 this had almost doubled to 388,000 tonnes.By 1940 the figure was 522,000 tonnes. The secondworld war and subsequent re-construction led to aboom in the use of asbestos. The US alone used overhalf a million tonnes of asbestos every year from 1947to 1979. Interestingly, it only started using the mostdangerous types (crocidolite and Amosite) in 195611.

By 1960, global asbestos consumption was wellover 2 million tonnes. In 1970, consumption was at3.5 million tonnes and still rising. In 1975, it was4.3 million tonnes and in 1980 consumption was at4.7 million tonnes.

The declineThe decline in asbestos use only began in 1985 whenproduction fell to 4.3 million tonnes. The decline wasslow. In 1990 production was still 4 million tonnes,despite major bans already being in force around theworld. Finally, in 1995 significant reduction started totake place. Consumption had almost halved from the

peak to 2.5 million tonnes, although even by the year2000 consumption was still comparable with 1960 at2 million tonnes.

Today, world production remains relatively steady at2.03 million tonnes12.

11 R.L.. Virta (2006). Worldwide asbestos supply and consumption trends from 1900 through 2003: USGS Circular 1298 .Available at http://pubs.usgs.gov/circ/2006/1298/

12 R.L.. Virta (2011). USGS 2011 Minerals Yearbook – Asbestos.Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/myb1-2011-asbes.pdf

13 CBC (2011). Asbestos mining stops for first time in 130 years. Available at http://www.cbc.ca/news/canada/story/2011/11/24/asbestos-shutdown.html (Accessed 13 March, 2012)

14 Report of the Conference of the Parties to the Rotterdam Convention on the Prior Informed Consent Procedure for Certain HazardousChemicals and Pesticides in International Trade on the Work of its Fifth Meeting (2011).Available at http://www.pic.int/TheConvention/ConferenceoftheParties/Meetingsanddocuments/COP5/tabid/1400/language/en-US/Default.aspx

15 Source: USGS Asbestos Mineral Commodity Summaries 2012 and 2013.Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/mcs-2012-asbes.pdf andhttp://minerals.usgs.gov/minerals/pubs/commodity/asbestos/mcs-2013-asbes.pdf

Table 2: Recent global production of asbestos15

e = estimated

Country 2010 2011 2012e

Brazil

Canada

China

KazakhstanRussia

Others

Total

270,000 302,000 300,000

100,000 50,000 –

400,000 440,000 440,000

214,000 223,000 240,0001,000,000 1,000,000 1,000,000

21,000 19,000 20,000

2,010,000 2,030,000 2,000,000

Canada: asbestos mining stops forfirst time in 130 years13

Canada’s Lac d’Amiante (literally, ‘asbestos lake’)mine in Quebec shut down in early November,2011. This followed a shutdown at the only otheroperational asbestos mine in Canada, JeffreyMine about 90 kilometres away. Both shutdownsappeared to be for operational or financial reasonsand both mines are pursuing plans to re-open.

The Vancouver Sun, in its edition of 24 November,2011 reported: “Earlier this year, the CanadianGovernment had blocked the listing of chrysotileasbestos in Annex III of the Rotterdam Convention.This would have meant that exports and importswould have to have been declared and thuscountries could refuse to accept chrysotile asbestos”.

The report of the meeting published on theRotterdam Convention website14 does not recordan intervention from Canada, although Canadais conspicuous by its absence from the list ofsignatories to a ‘declaration’ against chrysotile

asbestos made at the conference in June 2011.

In September 2012, Canadian newspapers werereporting anti-asbestos sentiment in Canadabut also that the asbestos mines were hopingto re-open in spring 2013.




9

The Black Lake asbestosmines in Quebec, Canada




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3. Health and regulation

A health problem for the Greeksand Romans?There is conjecture over whether the Greeks andRomans recognised the health problems associatedwith asbestos. Some people assert that Pliny the Elder,the Roman author and naturalist, described protectionagainst asbestos, but others claim he was referring todifferent problems. His “Natural History” makes nodirect mention of asbestos.

The first recognised cases ofasbestos-related diseaseThe first report of asbestos-related disease in Englandwas in 1906 when Dr. Montague Murray reported anasbestosis fatality to the Parliamentary DepartmentalCommittee on Compensation for Industrial Diseases. Itwasn‘t until the mid 1920s that more reports started toappear and asbestosis became recognised as a medicalterm. Asbestosis became the first fatal disease to bedefinitively linked to asbestos exposure (see “The caseof Nellie Kershaw“).

In March 1928, at the inquest of Walter Leadbetterof Aviary Mount in Armley, Dr. H. De Carle Woodcock,a well-known lung specialist, drew attention tothe inhalation of asbestos dust as the cause of thedeceased’s fibrosis of the lungs.

In 1930, Merewether and Price, two medicalinspectors from the Factory Department17 deliveredresearch on the asbestos textile industry in Britain –it identified that 25% of the 363 workers examinedhad pulmonary fibrosis. It was in the 1930s thatworkers with asbestosis first started suing theiremployers.

The beginning of regulationThese reports and research led to the 1931 Asbestos

Industry Regulations. While this legislation onlyreduced the dust levels in factories, at the time it wasbelieved to have solved the problem of asbestosis.

Asbestos, cigarettes and the link tolung cancerSo far, no direct link had been established betweenasbestos and lung cancer (although a connectionbetween asbestosis and lung cancer had been made).Key to understanding this is the enormous increasein cigarette smoking after the First World War. Thenegative health effects of this trend were starting toappear at the same time as the effects of asbestosexposure. To the medical profession, they appeared

to be the same problem.

The link between lung cancer and smoking waseventually established in the 1950s, and it wasonly in 1955 that countries started recognisingunexpectedly high instances of lung cancer amongasbestos workers.

Mesothelioma and a problem that couldno longer be ignoredIn the 1960s an alarming rise in the previouslyextremely rare disease mesothelioma was attributedto asbestos. The rarity of the disease made its linkto asbestos exposure all the more dramatic, and it

became increasingly impossible to ignore asbestosrisks. This led the UK to revise its asbestos regulationsover a five year period resulting in new regulations in1969 which effectively banned crocidolite asbestos.

The response of industry It would be hard for major industry players to deny thatfrom the late 1950s to the late ‘70s there was systematicself protection and a lack of assistance to injured parties,ranging from a reluctance to undertake investigationsthat were clearly needed to deliberate suppression ofevidence. Such behaviour undoubtedly delayed actionand exacerbated an already dire situation.

The case of Nellie Kershaw

16

Nellie worked with asbestos for nearly 20 years. She died aged33 in 1924. She suffered from a series of health problems thatculminated in her being rendered permanently unfit for workin 1922. The primary cause of her death was established as‘pulmonary fibrosis of the lungs due to inhalation of mineralparticles’. Her GP, Walter Joss had characterised her illness as‘asbestos poisoning’. Nellie was unable to get health insuranceduring her life because the condition was not recognised.

However, Nellie’s case led to an inquest which ensured that apathological examination was carried out, by Dr. William Cooke.He subsequently published an article in the British MedicalJournal which attributed her death to asbestos. Three years

later, in 1927, he definitively attributed her death to ‘asbestosis’.This was the first time the term had been used in this wayin a medical publication. Nellie may be considered the firstrecognised victim of ‘asbestosis’ and the starting point for allthe investigation and research that followed.

16 Source: Peter W.J. Bartrip (2001). The Way from Dusty Death: Turner and Newall and the Regulation of the British Asbestos Industry,1890s-1970. Athlone.

17 “Factory inspectors were first appointed under the Factory Act of 1833. A central office, later named the Factory Department, wasestablished and supervised by the Domestic Department, and later the Industrial Department, of the Home Office.” Taken from the NationalArchives at http://discovery.nationalarchives.gov.uk/SearchUI/details?Uri=C10130 (Accessed 13 March, 2013)




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The industry attitude of the time could perhaps begauged from the words of E. A. Martin of BendixCorporation. He is reported in various sources (includingplaintiffs’ records and the Congressional Record) aswriting the following in a letter dated September 1966:“My answer to the problem is: if you have enjoyed agood life while working with asbestos products why notdie from it? There’s got to be some cause”.

The situation today

In 1983 Iceland became the first country to placea general ban on all recognised forms of asbestos,although with exceptions.

The European Commission announced its almostcomplete ban on all asbestos in July 1999. It came into effecton 1 January, 2005. However, Cyprus, Czech Republic,Estonia, Greece, Hungary, Lithuania, Malta, Portugal andSlovakia, are not presently verified as being compliantby the International Ban Asbestos Secretariat (IBAS)18.

Globally, IBAS lists 54 countries18 as having bannedasbestos. This means that the following countries stillallow it.

• US (2011 usagewas 1,100 tonnes)

• India • China • Russia• Brazil• Mexico

With India, China, Indonesia and the US on the list, itappears around half the global population does nothave proper protection from asbestos production.

Brazil, China, Kazakhstan and Russia still mine largequantities of asbestos (see page 8).

Asbestos-related diseasesAsbestos causes a number of health problems ofvarying severity.

Pleural diseases (non-malignant)Pleural diseases include two non-cancerousconditions – diffuse pleural thickening and pleuralplaques. They take their name from the ‘pleura’ –the two-layered membrane (or mesothelium20) whichencloses and protects the lungs.

Diffuse pleural thickening is general thickeningof the pleura which extends over a large areaand restricts expansion of the lungs. It is thoughtthat asbestos fibres cause the disease by irritatingthe pleura, causing scarring and hardening.

Pleural plaques are generally less serious thanpleural thickening and may not display anysymptoms. Many asbestos workers with pleuralplaques may never realise they have them unlessthey are X-rayed. The plaques occur as bundles ofcollagen (a fibrous protein that connects tissuesand other items in the body) on the pleura.

AsbestosisThe term asbestosis is commonly misused by the mediato describe any illness caused by asbestos exposure.It is in fact a form of pneumoconiosis – any lungdisease caused by breathing small particles; in thiscase, asbestos fibres. In an asbestosis sufferer, the airsacs (alveoli) which control gas transfer in the lungsbecome scarred and healthy lung tissue is replaced byfibrous tissue. This prevents the alveoli from workingand reduces the effectiveness of the lungs. Symptomsinclude shortness of breath, a persistent cough,fatigue, laboured and rapid breathing and chest pain.Asbestosis is irreversible, has no known cure and can

be fatal. In 2009, 411 deaths were attributedto asbestosis in the UK.

A look at asbestos exposure in IndiaIn India it has been estimated that 100,000 workershave been exposed to asbestos, but only 30 havebeen compensated. A study of 181 workers at just one asbestos composite mill in Mumbai foundthat 22% had asbestosis19. This echoes the lack ofrecognition of the problem experienced decadesearlier elsewhere in the world.

• Panama• Liberia • Philippines • Indonesia • Singapore • Taiwan

18 IBAS (2012). Current Asbestos Bans and Restrictions. Available at http://www.ibasecretariat.org/alpha_ban_list.php (Accessed 13 March, 2013)

19 V. Murlidhar and Vijay Kanhere (2005). Asbestosis in an asbestos composite mill at Mumbai: a prevalence study. Environmental Health,Volume 4. Available at www.ehjournal.net/content/4/1/24

20 The general term for membranes that protect organs in the body cavity (see also “Mesothelioma” on page 12)




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Pulmonary fibrosisPulmonary fibrosis is the general term for diseaseswhich progressively scar the lung, interfering with theability to breathe. It is used when the cause of scarringis not known and therefore appeared in the earlydescriptions of asbestosis.

MesotheliomaMesothelioma is a form of cancer which affects thebody’s mesothelial membranes, those surrounding

organs in the body cavity such as the heart, lungsand stomach. It is believed that asbestos fibresmigrate through the lungs to these areas. The mostcommon form of mesothelioma (and the one mostassociated with asbestos exposure) is malignantpleural mesothelioma which affects the pleura –the mesothelium surrounding the lungs.

Before the widespread use of asbestos, mesotheliomawas rarely diagnosed. Once asbestos exposure wasrecognised as a causal link, the reporting rate increasedand we now know that 80% of mesotheliomasare caused by asbestos. Mesothelioma is far moreindicative of asbestos exposure than lung cancer,

which is relatively common due to other factors suchas smoking.

Mesothelioma tends to appear as a series of tumours.The only possible cure is to completely remove them.However, because mesothelioma is normally diagnosedonly after significant spreading of the disease, surgeryis unlikely to do more than provide short term relieffrom certain symptoms. Most treatment for the diseaseis therefore palliative.

Mesothelioma is an aggressive cancer. Less than10% of sufferers survive more than two yearsafter diagnosis and sufferers of malignant pleuralmesothelioma often survive only a few months. In2009, 2,321 people died of the disease in the UK.Incidences of mesothelioma have yet to reach theirpeak because of the 15 to 40 year lag time betweenexposure and the appearance of tumours.

Lung cancer

Because lung cancer is caused by many factors,including smoking, it is difficult to definitively attributecases of the disease to asbestos exposure. In the UKit is thought that asbestos-related lung cancer is lesscommon than mesothelioma, but the US believesit is more common. Smoking appears to greatlyincrease the risk of lung cancer being caused byasbestos exposure.

The disease consists of the uncontrolled growth oftumours or lesions in the lung tissue. In malignanttumours, cells can break away (metastasise) andtravel to other parts of the body, normally via thebloodstream or lymph system, to form new growths.

Benign tumours do not metastasise: they can besafely removed via surgery and will not recur.

Lung cancer can be treated by chemotherapy,radiotherapy, surgery or all three. The level of surgeryvaries depending on the spread of the cancer. It ismore usual to remove one lobe of a lung than theentire lung.

Survival rates for lung cancer are better than formesothelioma: approximately 20% of peoplediagnosed with the disease may survive five years.

Other diseases

There is evidence that asbestos can cause othercancers such as bowel, stomach, oesophagus,pancreas and kidney.

The case of Shirley Gibson21

Shirley Gibson was a teacher in the London Borough ofGreenwich. She died of Mesothelioma in 1993 at the age of 37.The inquest concluded that the disease had probably been causedby exposure to asbestos in the classrooms of the school sheworked at. She only worked at the school from 1983 to 1993.

Greenwich council conducted a survey of the 120 schools inthe area, but initially refused to inform parents of the results.In 2004, Greenwich council paid £135,237 to the family ofShirley Gibson.

Cases like Shirley’s have led to better management of asbestosin the UK’s schools today.

21 Source: The Free Library (1996). One teacher dead and millions of children at risk...Available at http://www.thefreelibrary.com/One+teacher+dead+and+millions+of+children+at+risk...so+why+do+they...-a061158702(Accessed 13 March, 2013)




13

“One fibre can kill” – evaluating the real riskThe words “one fibre can kill” have appearednumerous times in relation to asbestos but they arehighly misleading. While it is true that any exposure toasbestos carries risk, ‘loading’ is highly significant, justas it is with smoking: in short, the more asbestos youare exposed to, the more risk you have.

A typical acceptable airborne concentration of asbestosspecified by health and safety regulation is

0.1 fibres per cubic centimetre (cm3) of air averagedover a four hour period. Simply put, if every breathyou take fills your lungs with two litres (20,000cm3) ofair, it is ‘acceptable’ for each breath to contain 2,000particles. The typical number of fibres found in themixing area of a typical asbestos textile factory in the1950s was between 2,000 and 4,000 per cm3,20,000 to 40,000 times higher than the presentlyacceptable limit.22

Of course, none of this means that people neverdie from small exposures to asbestos. The case ofShirley Gibson (see page 12) illustrates this point.And there are well documented cases of the wivesof asbestos workers who died from asbestos-relateddiseases, whose principle exposure was only fromwashing their husbands overalls. In the same way,people who smoke heavily all their life may neverget lung cancer while other people who have neversmoked may be killed by relatively minor exposure

to passive smoking.

Table 3 summaries the results from various studiesof people who worked in crocidolite asbestos minesor in manufacturing using crocidolite asbestos. Wheninterpreting figures like these, it is important to notethat many factors may have influenced the differencesin results, including cases not being reported.

Location Industry Number ofpeople studied

Timescale Number ofcases

Year of study

Canada Gas maskmanufacturer

200 1939-1942 9 ‘probablymesothelioma’

197823

Australia Mining 6,916 1943 – 1966 222 casesmesothelioma

200724

South Africa Mining 3,430 Before 1962 5 mesothelioma,circa 20%‘abnormalities’

1974-197825

UK Gas maskmanufacturing

435 1930s to 1969 5 mesothelioma 198226

Table 3: results of studies of crocidolite asbestos mine and manufacturing workers

22 K. Morinaga et al (2001). Asbestos-related lung cancer and mesothelioma in Japan. Industrial health, Volume 39.Available at https://www.jniosh.go.jp/old/niih/en/indu_hel/2001/pdf/IH39_11.pdf

23 Alison D. Mc.Donald and J. Corbett McDonald (1978). Mesothelioma after crocidolite exposure during gas mask manufacture.Environmental Research, Volume 17, Issue 3. Available at http://www.sciencedirect.com/science/article/pii/0013935178900385

24 A.W. Musk et al (2007). Mortality of former crocidolite (blue asbestos) miners and millers at Wittenoom. Occupational & EnvironmentalMedicine Volume 65, Issue 8. Available at http://oem.bmj.com/content/65/8/541

25 J.M. Talent et al (1980). A survey of black mineworkers of the Cape crocidolite mines. Biological Effects of Mineral Fibre 2.26 E.D. Acheson et al (1982). Mortality of two groups of women who manufactured gas masks from chrysotile and crocidolite asbestos – a 40

year follow up. British Journal of Industrial Medicine, Volume 39. Available at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1009064/




14

The subject of testing for asbestos could fill severalbooks by itself. There are many different testingtechniques which suit different circumstances, suchas the way an asbestos sample has been extractedand prepared or the substance it has been extractedfrom. All techniques have their own advantages andlimitations so it is often necessary to combine methodsin order to get the most accurate results. This sectiondescribes the principal methods.

The recognised International Standard for laboratoryquality is ISO 17025:2005. Many countries run‘proficiency programmes’, sending random samplesto laboratories to see how accurate they are. Most labsperform very well and easily exceed the criteriafor accuracy.

Stereoscopic microscopy (20x). This test quantifiesthe number of fibres in a sample but not the type.If you do not need to know what your fibres are– for example you are doing an air sampling filterexamination and you only expect asbestos fibres –then you can do this count to ensure you arebelow the required threshold. It is very quick, simple

and cheap.

Polarized light microscopy, PLM. This is one of thesimplest and most reliable methods, especially for bulksamples, and is probably the commonest. It identifiesthe type and percentage of asbestos using a phasecontrast microscope with polarising filters. Its limitof detection is somewhere between 0.1% and 1%which means it may be insufficient by itself if absoluteaccuracy is needed at these levels. In these cases itwill need to be supplemented by other techniques.It is a very fast technique and therefore good forstatistical analysis.

Scanning electron microscopy (SEM). SEM scans thesurface of the sample and uses the reflection from thescattered electrons to create a ‘picture’. The advantageof SEM is that it magnifies the image up to 300,000times. It is particularly useful for bulk sampling. SEMis normally the most definitive technique, and can beenhanced by x-ray spectrum analysis.

X-ray diffraction (XRD). In this technique the objectis bombarded with X-rays. The rays are reflected by theasbestos particles, producing an x-ray spectrum whichis characteristic of the substance. XRD is sometimesused instead of PLM, or to supplement it. However,XRD has limitations: it cannot describe size or shapeand so is only really quantitative.

Transmission electron microscopy (TEM). TEM usesa very thin section of the sample (unlike SEM, which

scans the surface). It works on the same principle asan ordinary light microscope but uses electrons insteadof light. Electrons are very much smaller than lightand so the resolution is correspondingly higher. It istherefore a more sensitive test than PLM. However, thissensitivity means that a coarse test sample can causeproblems. Further, because TEM relies on area ratioestimations to determine asbestos concentration, it canhave limitations at low asbestos levels. This can be aproblem if your legislation specifies a low asbestos limit(say, 1%) and can mean the same sample may pass atone lab and fail at another.

Gravimetric analysis. This test is used to determine

the quantity of asbestos in the sample and works byremoving all other substances. The sample is weighedand then ashed in a furnace to remove volatile organiccompounds (VOCs). It is then weighed again todetermine the amount of VOCs that have been lost.The sample may then be acid washed to remove otherlikely compounds such as carbonates and weighedagain. At this point a more sensitive analytical method,such as PLM or even TEM, is used to identify asbestosfibres so that the quantity of asbestos in the originalsample can be estimated. This test is fast and efficientbut is only really relevant when you know your samplecontains asbestos.

4. Testing for asbestos




15

Test type What does it do? Good for Speed Level of fibre

identification

Ease of use Investment/cost persample

Drawbacks

Stereomicroscopy

Magnifies thesample for initialchecking

Initialexaminationandscreening

Fast None.Only givesan indicationof likelymaterials

Simple touse.

Can be handcarried.

Can costless than$500.

Cheap.

Not a test forasbestos. It onlyperforms an initialcheck, to indicatehow the sampleshould be furtherprepared and whatproper tests arelikely to be best.

Polarisedlightmicroscopy(PLM)

Magnifies thesample 100 to 400times and usesother techniquessuch as polarisationand dyes to dobasic fibre andquantity analysis

Speed,simplicityand cost

Fast Medium.Can be verygood withspecific typesof asbestosbound upin a simplematrix

Simple touse.

Portable.Can be set upanywhere.

Less than$10,000.

Cheap.

Poor at levelsof accuracybelow 1% andlimited for fibreanalysis

Scanningelectronmicroscopy(SEM)

Uses electrons toscan the sampleand producesmassivelymagnified 3Dimages to find andidentify fibres

Accuracy,detail andimages

Slow Good Complex.

Non-portableequipment ina dedicatedlaboratory

Hugeinvestment.

High.

Cost. Very slowfor quantitiveanalysis.

X-raydiffraction(XRD)

Uses X-rays toexamine crystalproperties, butdoes not producean image

Speed ofquantitiveanalysis

Fast Poor. Cannotidentifybetweenasbestos andnon-asbestosforms of thesame material.

Moderatelyeasy to use

Largeinvestment.

Medium(dependson set upand usage).

Does not givefibre morphology

Transmissionelectronmicroscopy(TEM)

Fires electronsthrough a verythin slide of thematerial andproduces massivelymagnified images(10 to 20 000 x)to identify fibres

Accuracyand detail

Slow Good Complex.

Non-portableequipment ina dedicatedlaboratory

Largeinvestment.

High.

Cost

Gravimetricanalysis

Throughweighing andreduction of

the sample, itfinds the masspercentage ofasbestos

Quickquantitiveestimation

Fast (oncesamplehas been

prepared)

None. Doesnot identifyasbestos

and relieson othertechniques todo this first.

Moderatelyeasy

Low.

Cheap to

medium.

Preparation timecan be very slow

Table 4: Comparison of asbestos testing methods




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A steam plantcontaining asbestos




17

1. The increasedrisk in shipping

For a number of reasons, ships can present an increasedrisk of asbestos exposure. First, the use of asbestosin shipbuilding over the years has been unusually high,and has included a disproportionately large amount ofblue and brown asbestos – the worst types. Second,some of the most dangerous asbestos applicationmethods, such as spraying, have been particularlyprevalent in ship construction, and these methods alsoincrease friability (see “Friability – a vital consideration”).

Added to these construction factors is the fact thatships are not stable environments: they roll, pitch, yaw,heave, surge, sway, slam and vibrate, and in the engineroom these issues are magnified by vibrating machinery.These conditions make friable asbestos far more likelyto emit fibres.

A UK study estimated an increase of 61% over theexpected presence of asbestos in shipyard workers1.A similar study in Trieste, Italy, showed that of153 men who had died of malignant mesothelioma99 had worked in shipbuilding, 19 had been in thenavy/merchant marine and 7 had been dockworkers2.

P a r t 2 – A s b e s t o s o

n b o a r d s h i p s

Friability – a vital considerationThe level of danger presented by asbestos dependsmainly on the substance it is ‘bound up’ in andhow easily that substance can be damaged. This isreferred to as friability.

For example, asbestos solidly bound in concretewhich is well protected and in good conditionmight be considered safe, but exposed concretewhich can easily be damaged or become dusty ishighly friable and dangerous. Asbestos contained in

a plastic, such as a floor tile, is considered safe andeven if the tile is damaged it is unlikely to becomefriable and release fibres. The subject is explored inmore detail in the Appendix.

1 I. Doniach, K.V. Swettenham, and M.K. Hathorn (1975). Prevalenceof asbestos bodies in a necropsy series in east London; associationwith disease, occupation, and domiciliary address.

British Journal of Industrial Medicine, Volume 21.Available at http://www.ncbi.nlm.nih.gov/pmc/articles/MC1008017/

2 L. Giarelli, C. Bianchi and G. Grandi (1992). Malignant Mesotheliomaof the pleura in Trieste, Italy. American Journal of IndustrialMedicine, Volume 22, Issue 4. Available athttp://onlinelibrary.wiley.com/doi/10.1002/ajim.4700220407/abstract




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2. Where is asbestos found on ships

In the worst cases, you can find asbestos virtuallyeverywhere on a ship. It can be in:

• the concrete and tiling on the floor • the wall and ceiling panels and the fire insulation

behind them• the doors • the glues and sealants in the windows and furniture • heat insulation and lagging • electrical cables

• brake linings and gaskets

Pipes and cables. These could contain asbestos but if maintained in good condition they will be safe.

3 The International Maritime Organization is a specialised agency of the United Nations, with one hundred and sixty nine member states.The IMO’s main regulatory instrument is the Convention. Once a convention has entered into force, any ship trading internationally is boundto comply fully with it anywhere in the world. The list of asbestos areas was developed in support of the IMO’s 2009 Hong Kong InternationalConvention on the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention) and is used by The InternationalAssociation of Classification Societies (IACS) in its guidance on the subject.

• mooring ropes • firemen’s outfits • boiler cladding • furnace firebricks, and • welding shop curtains and welders gloves.

The list goes on.

The International Maritime Organization (IMO) haspublished a detailed list of areas where asbestos can

be found3 (see Table 4).




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Table 4: IMO list of areas where asbestos may be found on ships

Structure and/or equipment Component

Propeller shafting • Packing with low pressure hydraulic piping flange• Packing with casing • Brake lining• Clutch • Synthetic stern tubes

Diesel engine • Packing with piping flange • Lagging material for exhaust pipe• Lagging material for fuel pipe • Lagging material turbocharger

Turbine engine • Lagging material for casing• Packing with flange of piping and valve for steam line, exhaust line and drain line• Lagging material for piping and valve for steam line, exhaust line and drain line

Boiler • Insulation in combustion chamber • Gasket for manhole• Packing for casing door • Gasket for hand hole• Gas shield packing for soot blower and other hole• Packing with flange of piping and valve for steam line, exhaust line, fuel line and drain line• Lagging material for piping and valve for steam line, exhaust line, fuel line and drain line

Exhaust gas economizer • Packing for casing door • Packing with hand hole

• Packing with manhole • Gas shield packing for soot blower• Packing with flange of piping and valve for steam line, exhaust line, fuel line and drain line• Lagging material for piping and valve for steam line, exhaust line, fuel line and drain line

Incinerator • Packing for casing door • Packing with hand hole• Packing with manhole • Lagging material for exhaust pipe

Auxiliary machinery (pump,compressor, oil purifier, crane)

• Packing for casing door and valve • Brake lining• Gland packing

Heat exchanger • Packing for casing door and valve • Lagging material and insulation• Gland packing for valve

Valve • Gland packing with valve, sheet packing with piping flange• Gasket with flange of high pressure and/or high temperature

Pipe, duct • Lagging material and insulation

Tank (fuel, hot water, tank,condenser), other equipments(fuel strainer, lubricant oil strainer)

• Lagging material and insulation

Electric equipment • Insulation material

Airborne asbestos • Wall, ceiling

Ceiling, floor and wall inaccommodation area

• Ceiling, floor, wall

Fire door • Packing, construction and insulation of the fire door

Inert gas system • Packing for casing, etc.

Air-conditioning system • Sheet packing, lagging material for piping and flexible joint

Miscellaneous • Ropes • Moulded plastic products• Thermal insulating materials • Sealing putty• Fire shields/fire proofing • Shaft/valve packing• Space/duct insulation • Electrical bulkhead penetration packing• Electrical cable materials • Circuit breaker arc chutes• Brake linings • Pipe hanger inserts• Floor tiles/deck underlay • Weld shop protectors/burn covers• Steam/water/vent flange gaskets • Fire-fighting blankets/clothing equipment• Adhesives/mastics/fillers • Concrete ballast• Sound damping




20

A battery operated ‘sniffer’ mounted onthe stairs at the exit of a compartment. For areas of particular concern, airmonitoring can demonstrate they are safe.

The floor of a bridge showing damaged, friable asbestos-containing cement. Asbestos is often used to boost the fire-resistant properties of ‘A-60’ partitions4. The bottomlayer of concrete is likely to be a skimming layer, used to achieve a level surface. The asbestos-containing concrete layer may have been put down next, followed by a final finishing andlevelling layer before the vinyl floor was put down. The vinyl floor may contain asbestos too.

4 An A-60 partition is a particular type of fire-resistant partition designed to work for 60 minutes.

Thick insulation. All of this could be asbestos. This image demonstrates thepotential amount of asbestos that can be present on ships. If it is properlysealed and kept in good condition then the risk is acceptable.




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3. Regulation

The SOLAS ConventionThe use of asbestos on board ships is governed byChapter II, Regulation 3-5 of the International MaritimeOrganization’s Safety of Life at Sea (SOLAS) Convention.This introduced the first major asbestos ban on 1 July,2002, prohibiting the new installation of asbestos-containing materials on all ships, except for:

• vanes used in rotary vane compressors and rotaryvane vacuum pumps

• watertight joints and linings used for thecirculation of fluids when, at high temperature(in excess of 350º C) or pressure (in excessof 0.7 x 106 Pa), there is a risk of fire, corrosionor toxicity, and

• supple and flexible thermal insulation assembliesused for temperatures above 1,000º C.

An amendment which came into force on 1 January,2011, banned all new installations.

“New installation”

SOLAS bans the “new installation” of asbestos.This means that asbestos which is already in ship stores(in unused spare parts, for example) may remain onboard the ship, but may not actually be installed.This presumably avoids the expense of having to removesuch materials from the stores. It is recommended thatowners ensure asbestos or asbestos-containing materialswithin stores are properly managed and not used.

For newbuilds, this wording also means that itemscontaining asbestos purchased before 1 January, 2011,may not be installed. For example, a windlass purchasedand delivered to the yard before 31 December, 2010,which has asbestos brake linings would have to have the

linings removed if the yard wished to install it today.

How the SOLAS asbestos regulations apply to existing andnew ships is explored in more detail on pages 22 to 25.

The role of flag states and recognisedorganisations in ensuring compliancewith SOLASFlag states5 are responsible for ensuring that theprovisions of the SOLAS Convention are properlyrepresented in national law and for enforcing the

5 A flag state is the administration of the government where the ship is registered, whose flag a ship is entitled to fly.

6 United States Environmental Protection Agency (EPA) (2012). Asbestos Ban and Phase-Out Federal Register Notices.

Available at http://www.epa.gov/asbestos/ban.html (Accessed 13 March, 2013)

Convention’s requirements within their national limitsand on board ships which fly their flag. Recognisedorganisations (ROs) are authorised by the flag stateto carry out on their behalf the statutory surveys andcertification required to demonstrate compliance.Classification societies commonly act as ROs. Lloyd’sRegister is an RO for over 140 countries’ administrations.Flag states can also apply local laws and requirementsto ships which fly their flag (see page 26 for an examplefrom the Netherlands).

The ISM CodeAll SOLAS Convention ships must comply with theInternational Safety Management (ISM) Code. Thisrequires companies to identify safety risks, includingasbestos risks.

ISO standardsThe International Organisation for Standardization (ISO)publishes a number of standards on asbestos. These arenot legal requirements unless directly referenced by law.

The US legal position on banning asbestos6

On 12 July, 1989, the United States EnvironmentalProtection Agency (EPA) issued a final ruling banningmost asbestos-containing products. This was anearly move in comparison to other countries, andperhaps because of this it was overturned on appealin New Orleans in 1991. The ruling was clarified toban specific products (flooring felt, rollboard, andcorrugated, commercial, or specialty paper) and ‘newuses’ of asbestos. This meant that products alreadybeing made that contained asbestos could continue tobe manufactured.

This is of vital importance to the shipping industryas ”EPA does not track the manufacture processingor distribution in commerce of asbestos-containingproducts”. Therefore, many items which shipyards(or other manufacturers in the shipping supplychain) buy from the US might contain asbestosbut there is no legal requirement for the itemmanufacturer to declare this. The US consumesabout 1,100 tonnes of asbestos per year to makeasbestos-containing products.




22

Focus on existing shipsUnder the SOLAS asbestos regulations, existingships are split into two main groups. Those builtbefore 1 July, 2002, are allowed to have asbestoson board. Those built after this date are subject tothe ban on most new installations (see page 21) andshould only have very limited amounts of asbestoson board.

Ships built after 1 July, 2002

Ships containing asbestos in contravention of theSOLAS 2002 ban are governed by the IMO CircularMSC.1/Circ.1374 – Information on Prohibiting the Useof Asbestos on Board Ships.

This acknowledges that asbestos is still being foundon board ships despite the regulations. And it statesthat the principal means of addressing the problem isthrough the shipyards and suppliers.

Circular 1374’s main recommendation is that anyitem supplied to the ship has an ‘asbestos freedeclaration’. It also says that random confirmationsshould be carried out.

Asbestos found on board ships in contraventionof SOLAS is required to be removed. Shipownersneed to make sure that this is managed safely andcarefully,

The Circular allows a maximum of three years toremove the asbestos (subject to the flag state’sagreement). An exemption certificate is required tocontinue trading during this time. There is no wayto extend an exemption. If the ship has not had theasbestos removed after the three years, it must remainwhere it is until it has been removed. Even smallamounts of asbestos may take up to 10 weeks or

more to remediate, and work must continue until nomore asbestos is found.

Ships built before July 1, 2002Ships built before the 2002 ban can contain anyamount and type of asbestos in any location, providedit is managed properly. The IMO provides guidelineson this in Circular MSC/Circ.1045 – Guidelines forMaintenance and Monitoring of On-Board MaterialsContaining Asbestos.

Despite the IMO Guidelines, it appears that withinthe industry there is little impetus to ensure thatexisting asbestos on these ships is managed effectively.This leads to potentially strange situations such asrecently built ships being forced to remove smallamounts of asbestos at huge cost while shipscontaining many tonnes of blue asbestos in a badlymanaged condition continue sailing without anyrestriction. LR believes the greatest safety benefitsare to be gained by making sure that any asbestos is

managed properly, regardless of the ship’s age.

In this section, we look some of the text relating toasbestos management contained in IMO Circular 1045and provide additional recommendations.

2.4 Planned repairs or removal of such materialsshould be carried out by specialist personnel andnot normally by crew. In cases where the crewis involved in urgent repair work at sea, specialmeasures should be observed as listed in annex 1.Procedures should be developed for the saferetention of any waste asbestos on board theship before it can be transferred and disposed

of ashore.

This is vitally important. Ordinary crew must notinterfere with asbestos in any way. Any owner orperson involved with the ship who makes such arequest of ordinary crew could possibly be committingan illegal act and exposing the company toenormous liability.

If asbestos is known, or suspected, to be on boarda ship, owners should examine the requirements forits removal (including the experience, training andequipment needed) and, if appropriate, allow specialistcrew members to either undertake urgent repair work

in the presence of suspected asbestos, or undertakeminimum remedial action if suspected asbestosis damaged, exposed or friable. Such measures wouldnormally be limited to simply taping over, or similarlysealing. exposed areas, in accordance with a properprocedure and using specially provided materials.

In all cases it is vital to check local legislation first, butit should be reasonably simple to train senior crewmembers such as chief engineers to carry out this work.




23

An example of a good repair to an asbestos-containing item

3 General provisionThe Company should make provisions, includingthe nomination of a responsible person to controlthe maintenance and monitoring program forasbestos, in their Safety Management System(developed for compliance with the ISM Code)for the maintenance and monitoring of on boardmaterials containing asbestos in line with theprovisions of the present Guidelines.

A good land-based example of such provisions ismanagement of asbestos in schools. A typical school hasa person on site who is responsible for asbestos and hasthe necessary training to repair small areas of damageand to identify when the level of damage requiresoutside specialists. This means the school does notneed to remove the asbestos. This non-marine exampleshows that if we can manage asbestos in our schoolswe can certainly manage it on board ships (see “TheCase of Shirley Gibson” on page 12).

4 Inventory and condition assessment ofasbestos-containing materials

4.1 The Company should have an initial shipinspection performed by a qualified professionalto investigate the possible presence of asbestos-containing materials on board the ship and, ifany are identified, to locate them and assess theircondition. The inspection should serve as thebasis for establishing an effective maintenanceand monitoring programme for dealing with theasbestos in the ship.

This is self explanatory, but we would go furtherand recommend that a full Inventory of HazardousMaterials7 is prepared (as required by the HongKong Convention). This can give shipowners greaterconfidence in the safety of their crews and greaterawareness of potential liabilities. It will also helpensure early compliance with the Hong KongConvention requirements.

7 The Inventory of Hazardous Materials is a list of certain hazards onboard a ship, including asbestos, which is required to be compiled forthe Hong Kong Convention




24

4.2 In the case of flake coatings, lagging or falseceilings containing asbestos, their conditionshould be assessed by completing the evaluationchecklist shown in appendix 1 to annex 1, whichtakes into account, in particular, the accessibilityof the materials and products, their degree ofdegradation, their exposure to shocks and vibrationand the presence of air currents in the area. Airsampling of dust measurement may be used as onetool to help provide a more complete assessment

of the ambient conditions on board. The evaluationform contained in appendix 2 to annex 1 shouldbe used to make the diagnosis on the state ofconservation of these materials.

This assessment should be carried out by an expert(and in some countries a government-licensed expert).We strongly recommend that a company with marineexpertise is used. Experience shows that land-basedcompanies do not understand the complexities of shipstructures or operations. For example, ceilings on landare often ignored in asbestos assessments since they areout of reach. But the constant movement and vibrationon ships can cause highly friable asbestos above false

ceilings to shed fibres.

5 Maintenance and monitoring programme5.1 If asbestos-containing material is located, a

maintenance and monitoring programme shouldbe developed for that ship, based on the inspectionand assessment data. The programme should beimplemented and managed conscientiously andinclude the elements contained in annex 1.

Asbestos management is not only about safety, it is aboutcorporate risk management. Unmanaged asbestos is anunknown and potentially enormous long-term liability.Maintenance and monitoring programmes are cost-

effective tools designed to save lives in the long term.

5.2 In the case of flake coatings, lagging or false ceilingscontaining asbestos, depending on the diagnosisas described in paragraph 4.2, the company shouldestablish appropriate thresholds and timescales forundertaking any necessary repairs or abatement,taking into account any national regulations.

This paragraph highlights the fact that asbestos in somelocations may be so friable and subject to such frequentdisturbance that removal may be the only option. Asbestosmanagement must ensure that the relevant nationalregulations are properly followed and implemented.

6 Abatement actions, planned repair andremoval of asbestos-containing materials

6.1 Abatement actions should be selected andimplemented when necessary. In someinstances, due to the condition of asbestos-containing materials or upcoming ship repairs ormodifications, a Company may decide to takeother abatement actions to deal with asbestos-containing materials in the ship. These responseactions could include: encapsulation (covering

the asbestos-containing materials with a sealantto prevent fibre release), enclosure (placing anair-tight barrier around the asbestos-containingmaterials), encasement (covering the asbestos-containing materials with a hard-setting sealingmaterial) or repair or removal of the asbestos-containing materials. Qualified, trained andexperienced contractors should be used for anyof these actions. The Company should be awareof any national and local regulations that pertainto abatement actions to deal with asbestos-containing materials.

This provides further clarification on paragraph 5.2.

Encapsulation, enclosure and encasement can be veryeffective measures and can be much cheaper thanremoval, but they do require constant monitoring andprocedures must be put in place for potential repairs.

6.2 In the event of works requiring the removal ofasbestos-containing materials, they should beunloaded from the ship. On completion of thework, and before any restoration of the spaces,the Company should carry out dust measurementafter dismantling the enclosing mechanism. If thework does not result in the total removal of thematerials and products listed in this order, theCompany should carry out regular surveillance

of the asbestos-containing materials at intervalsidentified by the Company as being appropriate,but not exceeding 3 years.

Various studies have been carried out on the results ofasbestos concentration monitoring on board ships. Onestudy8 compiled evidence from 52 in-house studies and84 different vessels which included the analysis of over1,000 air samples under normal conditions (i.e., with noasbestos work underway). Nearly 99% of the sampleswere below the common health and safety limit of 0.1fibres per cubic centimetre (cm3) and all were below1 fibre per cm3.

8 One example is D. M. Murbach et al (2008). Airborne concentrations of Asbestos Onboard Maritime Shipping Vessels (1978 to 1992).The Annals of Occupational Hygiene, Volume 52, Issue 4. Available at http://annhyg.oxfordjournals.org/content/52/4/267.short




25

Specialist asbestos expertiseWhen specialist asbestos expertise is required (for worksuch as sampling, testing or removal) make sure thatthe company and its employees have the appropriatequalifications and certification. Many countries haverigid requirements for asbestos experts, including strictlicensing requirements. It is vitally important to checkthese requirements. Failure to do so may mean that youare breaking the law.

Items removed from existing shipsfor servicingRecently, we were asked: If you remove anasbestos-containing item from an existing ship forservicing (for example, a fire fighting appliancewhich needs recharging) is this classed as a newinstallation when it is put back?

We believe not, and Australian legislationclarifies this in Customs Notice No.2009/30, whichstates that

“new installation of asbestos is banned…

where asbestos…due to repairs, refits orrenovations…is re-fixed, re-installed, orreplaced with other asbestos” .

In other words, if you are keeping the old asbestos,and not replacing it with new asbestos, thenyou can put the item back on the ship, but anyasbestos being replaced must be replaced by anasbestos-free material. If your CO

2 system goes

ashore for servicing and recharging, for example,any worn asbestos gaskets should be replaced withnon-asbestos gaskets, but the servicing agency isnot mandated to open the entire object and ensurethat existing, good asbestos gaskets are replaced.

We would, however, always recommend replacingany asbestos in these cases, in agreement with theservicing company.

Focus on newbuildsFor newbuilds, the SOLAS regulations have prohibitedall new installations of asbestos since 1 January, 2011.Subsequent interpretation9 of the regulations meansthat ROs are now required to review ”asbestos freedeclarations” and supporting documentation providedby the manufacturer, shipyard or repair yard.

The importance of the supply chainfor newbuilds

In countries that allow the use of asbestos, manufacturersare perfectly entitled to use it in their products. Thereforeit is vitally important for the owner and the yard tostipulate compliance with SOLAS and any other asbestosregulations throughout the entire ship supply chain.

We recommend the supply chain is set up as follows:

1. The prospective owner or operator agrees theintended use of the ship and the specifications itmust comply with, including SOLAS, in the contractwith the shipyard.

2. The owner or operator also agrees with the yard

how checks will be carried out, including designspecification, sub-supplier specification, spot checks,documentation checks, label checks, witness andhold points, and samples and testing.

3. The owner or operator requests asbestos-freedeclarations from the shipyard, encompassing theentire supply chain.

4. The shipyard specifies, in each of its contractswith sub-suppliers and sub-contractors, that thecontracted item or work is intended for a ship andmust comply with a list of specifications, includingSOLAS. All stakeholders in the supply chain issue a

manufacturer’s declaration, stating that items areasbestos free.

5. The shipyard (or any sub-supplier who assemblesitems sent to him) checks that sub-suppliers and sub-contractors have delivered to specification, identifyinghigh-risk items, manufacturers or other ‘indicators’,and carrying out spot checks accordingly.

6. The shipyard supplies asbestos-free declarations tothe owner, including its own overall statement thatthe ship is free of asbestos.

This set up should ensure the yard is doing spot checks on

its sub-suppliers and that the owner is performing similarspot checks before accepting delivery of the vessel.

9 IMO Circular MSC.1/Circ 1426 – Unified Interpretation of SOLAS Regulation II-1/3-5




26

The importance of supply chain checks: asbestos inbaby talcum powderIn April 2009, three South Korean manufacturers had torecall baby powder products after the health authoritiesdiscovered they contained asbestos. The Korean Food and DrugAdministration initially confirmed asbestos in 11 talc productsbut then went on to discover 1,122 drugs and medical products

containing the contaminated talc.

The asbestos was understood to have come from talc minedoutside Korea and may have become contaminated duringthe milling process before import. The talc was imported by acompany which specialised in providing chemical ‘raw materials’to the pharmaceutical industry10.

While this didn’t occur within the maritime industry, it shows theimportance of having checks throughout the whole supply chain.Remember, the manufacturer may have been acting correctly interms of their contract and national law.

An example of good supply chainmanagement – steel platesSteel is manufactured in mills approved’ by themajor classification societies. Ladle analyses aredone of the melt, and composition checks areperformed on selections of the finished plate.Batches are random tested. Each and every platehas markings which relate to a certificate, and ifthe plate is cut, such markings are transferred untilthe plate is a known part of the ship. During thisprocess, random batches of steel are even testedby the shipyard – normally as a side product ofweld tests (a sub-standard plate will break before

the weld and thus the quality control departmentwill know the steel is faulty). All of these items arecontrolled by the shipyard and witnessed/reviewedby the classification society. All the results areavailable to the owner and normally he is allowedto witness or review any part.

This is a good example of material control that caneasily be applied to asbestos management.

How the Netherlands flag is guardingagainst asbestos on newbuildsThe Netherlands flag had particular concerns aboutthe amount of asbestos being found on newbuildsin countries that did not have proper asbestosregulations or enforcement of asbestos regulations.They came up with their own procedure for

ensuring asbestos was not introduced onto theirnewbuilds, as follows:

1. The shipyard provides evidence that theship is asbestos-free and the RO verifies the‘investigation documentation’.

2. The sub-contractors and shipyard supply‘asbestos free’ declarations or statements11.

3. Random samples are taken by a properlyauthorised and independent asbestos companyof the items listed in IMO Assembly ResolutionA197(62), to a maximum of 20 samples.

If asbestos is found then further tests arecarried out.

4. When the results of the tests are known, aremediation plan is agreed.

5. The asbestos company issues a report/ statement of its actions and recommendationsand the process is verified by the RO.

This is a simple, practical procedure that givesbetter assurance to all involved.

Caroline Essberger 12

The 8,400 dwt tonne chemical Tanker CarolineEssberger was built in the Eregli shipyard inIstanbul, Turkey in 2009 for German ShipownerJohn T. Essberger. She was found to be ‘riddledwith asbestos in thousands of gaskets and otherseals’. The asbestos was only found several monthsafter the ship was built and all the items had tobe replaced. It was estimated that the cost ofreplacement of the asbestos parts was in the orderof 10% of the original cost of the ship, although thework was carried out at Essberger’s own facilities.

10 Talc is commonly used as an ‘excipient’, the inactive ingredient that actually carries the drug – the bulking agent in a pill for example.

11 Note that Lloyd’s Register and other classification societies already check ships’ plans for comments regarding asbestos during plan approval.

12 Source: Lloyd’s List (2010). Chemtanker newbuilding loaded with asbestos.Available at http://www.lloydslist.com/ll/sector/ship-operations/article171747.ece?service=print (Accessed 13 March, 2013)

Supply chain case studies




27

The ultimate aim of managing asbestos is to protectworkers from exposure. It is vital that this is achievedthrough a simultaneous top-down and bottom-upmanagement approach.

Top-down management ensures that the top-level stakeholders are aware of asbestos problems.They should implement an effective asbestos riskmanagement system that provides training, awarenessand protection to the workers so that they can

recognise potentially dangerous situations and actaccordingly. Without top-down knowledge andcontrol, bottom-up management is impossible.

Bottom-up management provides education,training and awareness for workers so that they areproperly protected. It empowers them to look aftertheir own safety and to report any issues up to seniormanagement.

The outcome is that both senior managementand workers recognise the dangers. Workers areempowered and supported by senior managementto work safely and with confidence that their actions

are correct.

4. How the marine industry’sstakeholders can protect

their workersThis section focuses on the key shipping stakeholderswho need effective asbestos risk management systems,looks at their potential responsibilities for safeguardingworkers, and outlines our recommendations formanaging the risks of asbestos exposure.

ShipownersThe shipowner has the greatest direct responsibility for thepeople on board the ship – be they crew (either employeddirectly or by a crewing agency) or visitors (Surveyors, Port

State Control Officers, Cargo Assessors, or P&I).

Owners must ensure that effective top-down andbottom-up asbestos management is in place. A key toolthat a shipowner would be expected to use is a riskassessment (see page 33).

ShipyardsShipbuilders and repair yards not only have aresponsibility to protect their workers from asbestos,but they should be aware that the ship they arebuilding or repairing must comply with SOLAS (if itis governed by the Convention) and other relevantnational or international legislation. It is best for this

information to be included in the general and specificterms of the contract with the shipowner.

Clearly labelled asbestos-containing materials – an example of good asbestos management




28

Asbestos protection during ship recycling. The blue pipes contain asbestos and have therefore been wrappedin protective blue plastic. The white uptake (on the left) was presumed to contain asbestos and marked ‘a’. Testingrevealed it was clear of asbestos and so the ‘a’ has been crossed out. (Photo courtesy of Leyal Ship Recycling.)

28




29

Ship repair and conversion facilitiesShips coming into repair yards may well containasbestos. The yard must perform some sort of riskassessment for each ship coming into the facility andhave management procedures in place for cases whenasbestos is suspected. We would recommend that yards

assume every ship contains asbestos. Workers shouldknow what items might contain asbestos and be ableto respond accordingly. Certain workers carrying outhigh-risk tasks may benefit from special training. Thesemight include boiler and steam pipe fitters, peopleinstalling insulation in the accommodation, or peoplerenewing linings.

Ship recycling facilitiesA recycling facility is where ships are dismantled whenthey have reached the end of their life. Because recyclingfacilities commonly deal with older ships, they are certainto encounter asbestos. The IMO’s 2009 Hong KongInternational Convention on the Safe and Environmentally

Sound Recycling of Ships (the Hong Kong Convention)contains guidelines for recycling facilities covering how todeal with asbestos and other hazards.

Owner membership bodiesOwner membership bodies such as ICS, BIMCO andIntertanko work hard to bring dangers and problems totheir members’ attention in order to help them identifyand solve them. In the case of asbestos, we believethat the SOLAS asbestos regulations and the asbestos-related elements of the Hong Kong Convention (suchas the Inventory of Hazardous Materials) provide goodopportunities for membership bodies to check whethereverything possible is being done to protect against

asbestos exposure.

Port authoritiesThe main two responsibilities for port authorities are toensure the relevant national and international asbestosrequirements are enforced and to look after the safetyof people working inside the port, including people onships of other flag states in the port authority’s area

of responsibility.

Port authorities have the legal right and power toinspect ships, and these inspections should be carriedout thoroughly. Because many of the major maritimeconventions, such as SOLAS, rely on mutual acceptabilityof certificates, port authorities should have good reasonto perform extended surveys: normally there is anaccepted framework for establishing this.

Crew operators/crewing agentsCrew operators and crewing agents have a duty of carefor the crew they provide to ships. We recommend thatthese organisations examine their responsibilities and

liabilities, and the training, expertise and experience oftheir crews, to ensure that they are compatible with thetypes and ages of the ships they will be working on andthe duties they will be expected to perform.

Ship managersAs a ship manager stands in the place of the shipowner,our opinion is that they share identical responsibilities.Since managers are responsible for SOLAS compliancethey must be experts in the Convention’s asbestosrequirements.

The role of the ship manager does not necessarilylessen the responsibility or liability of the shipowner.

No matter what the involvement of the ship manager,the owner should independently examine their rolesand responsibilities.

Mixed glass wool and asbestos disposal facility. Note the bags which have been dumped at the entrance tothe pit, rather than in it. Some bags are torn and their contents are spilling out.




30

materials to contain asbestos unless there are goodreasons not to do so”.

This management plan is an excellent and internationallyrecognised way of managing asbestos and can be simplytailored to make it relevant to shipowners, as Figure 2demonstrates. It can also be applied to fleet management.

5. Tools for achieving best practicein asbestos management

Record

No further action

Appoint personto ’manage’

asbestos

Record asbestos

plan/drawing

Prepare

management

plan

Carry out

risk assessment

Are ACMs liable to be disturbed?

Who can be exposed?

Prioritise

Find out if ACMs

present: check

plan/drawings

carry out survey

RECORD

Prepare asbestos

register

Repair/removeMonitor Manage

• Train staff

• Manage contractors

• Checked all work againstplan/register

• Control of work itself: – Asbestos essentials – Compliance with CAR

No

Yes

ACMs in good

condition

Damaged

ACMs

Maintenance

work

Asbestos Management PlansFigure 1 is a land-based Asbestos Management Planfor ‘dutyholders’ who manage premises13 that maycontain asbestos, taken from Asbestos: The SurveyGuide, published by the Health and Safety Executive14.The Guide begins with a fundamental concept which isvitally important in managing asbestos risks: “Presume

13 Interestingly, under UK law, premises’ includes ships.

14 Available at http://www.hse.gov.uk/pubns/books/hsg264.htm

Figure 1: A typical land-based Asbestos Management Plan.




31

Figure 2: The land-based Asbestos Management Plan adapted for maritime use.

Record. Maintainevidence and

decision making

steps

Ensure effective

systems in place to

avoid purchasing

and installing ACMs

Monitor andreview

effectiveness

of system

Appoint person

to manage

asbestos

Prepare

management

plan

Find out if ACMs present:

check plans and drawings.

Carry out samples and surveys,

check procurement information

Identify ships

in fleet to be

managed

Prepare asbestos

register (Inventory

of Hazardous

Materials preferred)

Undertake risk

assessment

Monitor ACM

Measure performance

Update records

Document

Review

Policy

Procedures

Objectives and targets

Safety provision

Maintenance work

Equipment and

PPE provisionImprove

procedures

Training

Awareness

Procurement plan

Asbestos action

and work

Approved service

supplier

Approved servicesupplier

Approved service

supplier

Third party

verification

Implement effective management system




32

A typical plan showing where asbestos is present on board a ship.




33

How old is my ship: when was it built?

Have all the owners of the ship since newbuild maintained

accurate, documented information to prove that an asbestos free

procurement programme has been followed?

Is there a reputable

’asbestos free’ certificate

(or a list of asbestos available

from the time of construction)

Is there a reputable

’asbestos free’ certificate

available

Did the country of build

legally outlaw asbestos at the

time of build, or did the

contract specify ’asbestos free’

Have any large reputable

asbestos registers been done?

(has a list of asbestos

been provided?)

Note: you must follow the arrows directly down from the year of build unless an arrow takes you sideways.

Between

1 July, 2002 and

1 Jan, 2011

After

1 Jan, 2011

Before

1 July, 2002

High confidence

that ship is free of

asbestos (or that

a known list of

asbestos is available)

Low

confidence

that ship is

free of

asbestos

No

confidence

that ship is

free of

asbestos

No

No

No

No

No

Yes

Yes

Yes

Yes Yes

Yes

Yes

Figure 3: Asbestos assessment

Carrying out an asbestos assessment foryour shipFigure 3 is an asbestos assessment which allowsyou to determine the likelihood of asbestos being onboard your ship. By performing additional checks and

implementing management measures you can moveto the right of the diagram and increase confidence inyour ship’s asbestos status.




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A turbo-alternator withasbestos-lagged steam pipes




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36

Appendix –Common asbestos areas on board ships

This appendix contains images of the places whereasbestos is most likely to be found on board ships. Itis based on an educational powerpoint presentationused to train our surveyors, prepared in collaborationwith M.A.R.C – a Netherlands-based, licensedspecialist asbestos company. We are very gratefulfor their assistance and for the use of many of theirphotographs in this section.

Before we get on board the ship –

plan approvalA lot of information relating to asbestos will becontained in the ship’s plans. There may be statementsthat particular items are non-asbestos or details ofsubstitute materials like rockwool.

Plan approval surveyors, designers, and owners ofnewbuild ships or repair yard superintendents shouldcarefully check the plans of any item that mightcontain asbestos and ensure that a non-asbestos-containing material is specified. Plans are accompaniedby, or include, material lists and material specifications.These should be checked in a similar way.

If asbestos substitutes are specified in the plans, it isvital that the site surveyor checks these materials haveactually been used, both by inspecting the materialand by checking packages and invoices. Rockwoolpackaging is commonly found strewn around the shipor shipyard, often in bins. Every good surveyor shouldspend time hunting around bins in yards, repair yardsand on board ships.

pp

p

Close up of an asbestos blanket

Asbestos fire blanketsAsbestos fire blankets are a common nuisance.They are often brought on board ships by uncontrolledsub-contractors carrying out temporary work. Theyare extremely easy to damage and very friable, so theywill easily shed large numbers of fibres which can bedifficult to clean up. Their asbestos content will bevery high – well over 50% – but the good news is thatthey are likely to be new and therefore contain onlychrysotile asbestos.

Friable mess and fibres from an asbestos blanket. Note: a piece of cloth has been used toprotect the deck from the scaffolding – this will clearly cause large fibre releases.




37

A newbuild (or repair) asbestosblanket protecting the areaaround a proposed weld

Asbestos blankets being used to protect oil tanksfrom flame and sparks

Deckheads and ceiling and wall panelsAsbestos was regularly specified for use in ships’deckheads and panels because of its fire-resistantproperties. Because of this, original A-60 or similarpanels of a certain age will be almost guaranteed tocontain asbestos. But the asbestos content of otherordinary panels is harder to predict. Because of the

material’s great performance and low price, it wasoften used by panel manufacturers even whenfire protection wasn’t specified. The only wayto tell if ordinary panels contain asbestos isdestructive examination.

All panels sourced from countries that still allowasbestos should be suspected of containing it.A quick internet search will show how easy it is tofind asbestos boards for sale even today.

It is not only the panels that might contain asbestos –the glues, cements, putties, backing strips and shimsused in their construction are also likely to contain it.

The putties and adhesives are not likely to be friable.Cement may well be highly friable but should beunderneath items which will protect it.

In general the danger from panels is low. It is very easyto see if a panel is damaged and light damage canbe rectified very easily. Such work should normally beundertaken by specialist sub contractors. However,it can be carried out by suitably trained crew usingemergency repair kits if the ships has a good asbestosmanagement plan in place and legislation allows it.Training needs and repair methods should be includedin the ship’s ISM manual and crew training andprocedures documentation. This work should also be

monitored by specialists at the arranged intervals.

Panels in good condition can be safely managed in situ oreasily removed in one piece by specialist companies if theobjective is to reduce the amount of asbestos on the ship.

An asbestos blanket used as pipe lagging




38

Fire doors and surroundsFire doors have historically been made with asbestosbecause of its fire-retardant properties. The asbestosis commonly hidden in the core of the door. Moderndoors would be expected to contain mineral wool, butif doors are sourced from countries that allow asbestosthey should be suspected as containing it.

As you can see from the photograph below it is almostimpossible to tell what a fire door is made of just bylooking at its exterior. The photograph also shows thatasbestos is normally well encapsulated within fire doorsand can be managed safely in situ.

A typical bulkhead panel with the interior exposedThis is a typical sandwich board bulkhead panelfound in accommodation blocks. The exterior is formicawhich is asbestos free. This encapsulates the asbestos-

containing material in the middle. If the formica wasundamaged the panel would not present a problem.But exposed like this, the friable asbestos will beeasily disturbed.

Unrepaired damage like this is an example of poorasbestos management. It could be resealed with tape,adhesive or more formica.

Modern sandwich board panels are likely to containrockwool. Once you are familiar with it, rockwoollooks distinctly different from asbestos-containingmaterial. However, in Lloyd’s Register, in common withother class societies, we do not train our surveyors

to recognise unmarked rockwool as the risks ofmisidentification are very high.

Asbestos within a fire door

A damaged and friable asbestosmillboard ceiling

A Portland cement ceiling which is notdamaged or friable

It is very difficult to tell the difference between these two ceilings and both should besuspected as containing asbestos. But the key difference is that the first ceiling is damagedand friable. It should be repaired by a specialist or tested to ascertain if it is asbestos. Even ifthe second photograph is an asbestos ceiling it is not damaged or friable and therefore is notdemonstrating poor asbestos management.




39

Asbestos rope in a fire door frame. This is a veryinteresting photograph. Asbestos rope has been usedto improve the seal between the door and its frame.Asbestos rope is always friable and in this instance theproblem is exacerbated by the fact that the door bangs

into the rope every time it closes. It is certainly not anexample of good management and we would expectthe rope to be replaced by specialists.

Non-asbestos rope in a fire door frame. Comparethis to the asbestos-containing rope in the image

above. It is impossible to tell by looking which onecontains asbestos.

FloorsFloors present particular problems because they areoften multi-layered and any or all of these layers mightcontain asbestos. An A-60 floor, for example, mightcontain a bottom levelling layer (so that the fire layercan be accurately applied); several centimetres of ‘fireproof cement’; a levelling compound; an adhesive;and a fire-proof tile or carpet. Even within one layer,asbestos content may vary widely. This is particularlytrue of cement, where several different mixes may have

been used to complete the same floor.

To find out how much asbestos a floor contains,you would need to test each individual layer. Butin reality, asbestos testing on ships is a process ofestimating based on random testing. The more testsyou complete, and the better they are structured, thebetter the estimate you will achieve.

Asbestos vinyl floor tiles and asbestos glueAsbestos floor tiles are very common, but evenwhen damaged they are very unlikely to emit adangerous level of fibres since they are bound up inthe vinyl matrix. The glue may contain an even higherpercentage of asbestos than the tiles but it too isunlikely to be friable.




40

Crocidolite (blue) asbestos putty in anunauthorised repair to a non-asbestospenetration. This is almost certainly an unapprovedmodification to a cable penetration (the cables arenot properly installed on the cable tray and are notproperly secured). It is a common sight on board ships.In this instance the original penetration is asbestos-free, but the new penetration contains crocidolite(blue) asbestos. Although this is the most dangeroustype, because it is in putty and clearly not friable it canbe safely managed in situ.

This material is likely to have come on board the shipin the equipment box of a sub-contractor. Newbuildand repair yards therefore need to perform checkson sub-contractors’ activities and equipment. Goodsurveyors will surreptitiously peak into the tool boxes ofworkmen, not least because many glues and sealantscontain materials which present fire hazards or aretoxic when burnt.

Asbestos-containing material in a cable penetration

Putties and sealants used in penetrationsMany putties and sealants were manufactured withasbestos, and they still are in some countries. Asbestoscan also be added as a ‘bulking’ agent to an ‘asbestosfree’ putty, glue or sealant, to alter its properties ormake it go further. Older putties and sealants andthose manufactured in countries still using asbestosmust therefore be suspected of containing it. The goodnews is that provided they are not disturbed, and arenot brittle or aged, they are likely to last for the life of

the ship without becoming friable or causing a healthhazard. In these cases we would encourage propermanagement in situ rather than removal, unless relevantlegislation required it.

The substitute for asbestos in new putties and sealantsis often silicon. Silicon actually outperforms asbestos inmany areas, but can be a nuisance to work with.

Asbestos-containing putty in the ‘watertight’penetrations of cables

A common use of asbestos putty on small fitments




41

Using asbestos rope as a sealant in this way is unsafe.Seals on exhaust uptakes are subject to constant

thermal stress and vibration induced by waves andengines, which makes them potentially highly friable.This example clearly illustrates why shipowners tryingto risk assess their asbestos liability should use marineasbestos experts. A land-based inspector might assumethat a sealant like this is undisturbed and relativelysafe. An experienced and licensed marine asbestosassessor would understand the influence of theship’s movements.

Asbestos rope being used as a sealant forexhaust uptakes

Asbestos lagging on the exhaust pipe of an emergency generator




42

Asbestos insulation rope. This rope is highly friableand will contaminate the whole area, including therockwool below it. Rockwool can easily ‘absorb’asbestos waste fibres and so presents a danger evenif it is manufactured without asbestos. In some shiprecycling legislation, rockwool is mandatorily treated as

asbestos-containing waste.

Pipe insulation, covers, ropes andinsulated boardPipe insulation or lagging is one of the mostcommon uses of asbestos, especially lagging usedfor high-temperature steam or heating pipes. Thesematerials can be naturally quite friable and can bedamaged easily, especially in a busy engine room,but they can be reasonably easily sealed in place withthe right paints or adhesives. This needs to be managedcarefully. In some cases, asbestos lagging is so friable

that it must be totally encapsulated or removed.

Asbestos canvas

Asbestos insulation. This type of loose flock is so friable it will quickly contaminate the area it is in,and should be removed as soon as possible. Even if it is encapsulated in another material, it will quicklycover the internal surfaces of that material with fibres, leading to large releases if it is disturbed.

Asbestos canvas. This is also used on cold water pipesto avoid condensation.




43

Engine room stores – spare partsEngine room stores are some of the commonest areasfor new asbestos to get on board ships. The problem isunderlined by the IMO Circular, MSC.1/circ.1426. Thisrecognises that it is almost impossible to guaranteethat engine room stores do not contain asbestos, andtherefore states that asbestos is allowed in engineroom stores but that items containing it cannot actuallybe installed on board the ship.

A typical gland packing cupboard on a ship.

Without testing, it would be impossible to knowwhether all the materials in this cupboard were free ofasbestos. And with such a large selection its presenceis almost inevitable. It would also be impossible foranyone to know where these materials have been usedthrough the life of the ship.

Rolls of asbestos containing cardboard gasket

material. Gaskets are probably one of the biggestproblems on a modern ship. Gasket material isimpossible to trace over a whole ship’s lifecycle andtherefore on older ships all gaskets should be presumedto contain asbestos. The good news is that, unlessdisturbed, gaskets present a very low risk. The exposededge of a gasket may be friable but it is a very small areawhich is often protected by the flange or is otherwiseunlikely to be disturbed. We recommend that allgaskets are managed as if they contain asbestos andnot removed unless required by legislation.

It is common to find ships which state they have noasbestos onboard and yet have cupboards whichcontain items clearly marked “asbestos”. On one ship,an LR surveyor was given a long lecture by the ChiefEngineer on the dangers of asbestos, only to then finda freshly cut gasket, clearly labelled asbestos, sitting onthe cutting bench in the machinery area.

Engine room

The engine room store examples show that youare likely to find asbestos in the engine room itself.Any asbestos there is prone to damage due to theoperations taking place and the heat, humidityand vibration.

Sprayed blue asbestos on a steel engine room

bulkhead. This is blue asbestos sprayed onto anengine room bulkhead. As with the crocidolitepenetration on page 40, provided it is in goodcondition and managed properly it may be consideredsafe. However, if it has become exposed and friable,effective management can be very difficult. Inthese cases, properly stabilising the surface is highlyrecommended, Physical encapsulation is preferableto removal in cases where removal will causeunacceptable disturbance.




44

Asbestos lagging




45



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