Asbestos on Ships - Asbestos Testing and Asbestos Surveys
New regulations relating to Asbestos management in the shipping industry have come into effect as of January 2021, and these could have an impact on ship owners and operators.
Asbestos has been prohibited for use, and installation aboard commercial shipping vessels for many years now. Under the International Convention for the Safety of Life at Sea (SOLAS), 1974 (updated in December 2000 and coming in to force in July 2002), Asbestos was originally prohibited for installation in certain materials. The regulation applied to materials used for the structure, machinery, electrical installations and equipment covered by the SOLAS Convention. Minor exemptions were in place for very specialist applications (for example where insulation was needed for extreme temperatures above 1000ºC), however in January 2011 the presence of any Asbestos in new build ships was prohibited.
The identification of hazardous materials on a ship or vessel is covered in the The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the Hong Kong Convention), which is aimed at ensuring that ships, when being recycled after reaching the end of their commercial operation and utility, do not create any unnecessary risks to human health, safety and to the environment. Under the convention, any ships being sent for recycling will be required to carry an Inventory of Hazardous Materials (IHM).
Further strengthening of the regulations (specifically the EU Ship Recycling Regulation (EU 1257/2013)) now means that from 1st January 2021 all vessels that are above 500 Gross Tonnage (GT) and registered with an EU Member State, or wishing to call at a port or anchorage of an EU member state must have an Inventory of Hazardous Materials (IHM) and a Statement of Compliance (SoC) already completed.
Failure to meet the requirements of the aforementioned regulation could have significant negative financial and operational outcomes, including warnings, detainment of the vessel or exclusion of the vessel at offshore terminals and ports – all of which comes with costly consequences.
An ‘Asbestos free certificate’ was once thought of a way in which compliance could be met, however as has been established by many an Asbestos survey, it is often the case that a vessel is in fact not Asbestos free. Continued maintenance on vessels, even newly constructed ones, means that Asbestos may be brought aboard from suppliers in countries where Asbestos is not yet banned - resulting in Asbestos being installed in new vessels. Additionally, counterfeit goods such as gaskets and insulations purporting to be ‘Asbestos free’ are often Asbestos Containing Materials (ACMs), and only identified as such through sampling and analysis.
If Asbestos is identified, it is not a mandatory requirement for it to be removed, provided it is kept in good condition and appropriately managed.
The best way for shipping companies, owners and operators to comply with the new regulation is to ensure that they conduct the first step of the Asbestos management process, and have an Asbestos survey completed by a competent and specialist company.
If you have any Asbestos related concerns, contact us to see how Anthesis Consulting Middle East can help you:
Charles Faulkner (Head of Environment, Health and Safety and Asbestos Team Leader)
Phone: +971 (0) 50 5541 320
Email: asbestos@anthesisgroup.com