Hazardous Materials Inventory (HMI) surveys, when carried out correctly, can have a number of unexpected benefits for shipowners. Recent experience not only underscores the value for shipowners of having an approved inventory for their vessels, but also reaffirms the need to ensure that investigations are carried out properly.
The hazardous materials consultancy Lucion Marine was recently appointed to help a large cruise line work on a cruise ship built in 2008. In this particular case, a shipyard, on a pre-refit visit, claimed that an area where a new sewage treatment plant was planned contained asbestos in the firewall insulation.
At the request of the ship’s technical manager, Lucion Marine met the shipyard and its asbestos expert on board the ship in Jamaica. Following discussions, we then performed mutual testing at three locations on board where the shipyard claimed asbestos was present. In addition, in six hours, we collected 90 additional samples throughout the collection process and urgently returned them to our laboratory for analysis.
Within two days of leaving the ship and completing our tests, we were able to confirm to the shipowner that there was no asbestos. In our opinion, we believe that the situation was caused by the initial use of an inexperienced company involved in the first assessment; in fact, we learned that it was the first time the surveyor had boarded a ship.
We also suspect that some of the sampling equipment used in the original vessel investigation may have been contaminated from previous work and subsequently contaminated the samples taken from the cruise liner.
In the end, this may appear to be a satisfactory outcome for the cruise liner, since the refit can go smoothly, but this does not take into account the additional costs and work interruptions involved. For example, there is the lost time and additional surveying costs incurred, as well as the travel costs associated with sending specialist surveyors to the shipyard, not to mention the management and labor time lost after the shipyard raised concerns for the first time.
Unfortunately, this kind of situation is not an isolated case. Lucion was involved with two other shipowners who were accused of having asbestos insulation in a work area. These other situations turned out to be more aggravating: the claims arose during the refit work, which was then stopped, causing delays and considerable costs until extensive testing was carried out.
In the course of our work we have found asbestos in over 80% of new vessels and we work regularly with cautious shipowners such as Maersk, BP and the Royal Navy to have their new vessels inspected prior to delivery from the shipyard. . Many government maritime authorities recommend that all ship owners conduct a specialized ISO17020 asbestos survey to eliminate the risk of asbestos in order to demonstrate that a ship is free of asbestos. This need was created because shipbuilders only base their “asbestos-free certificate” on material claims from suppliers, without directly testing the parts or components supplied.
In addition, the term “asbestos-free” can be misleading due to the different international thresholds that govern and control its precise definition. For example, in the United States, up to 1.0% asbestos content may be allowed, while it is 0.1% in the EU and 0.0% in Australia. In China, there is no official standard, and in our work with ship owners and shipyards, we have found up to 15% asbestos in materials that have been declared “asbestos free”.
On the same theme, it cannot be assumed that sister ships built to the same design by the same shipyard will be the same in terms of potential asbestos content. Recently, we investigated a series of six French new builds in South Korea and found asbestos in the seals of the fire doors of the fourth ship, pointing out that the supply chain can be affected at any time. It should be noted that 60% of an HMI inspection is an asbestos investigation, so having a professional and efficient HMI will eliminate the risk of any contamination claims during a refit or with owner supplied items.
Regarding regulations, the Hong Kong Convention requiring all ships to have an HMI has been implemented to ensure that a ship has a formal record of all hazardous materials on board. This ensures that when the vessel is recycled, an accurate vessel demolition plan can be produced, with particular attention to the safe handling of all hazardous materials present.
This regulation is still pending ratification, and if the Ballast Water Treatment Regulation is any guide, we expect this could be achieved by 2022. In the meantime, the EU has published a regulation that all vessels flying the EU flag, or any vessel visiting an EU port must have a classification society approved HMI by December 2020.
It is important that a shipowner selects an experienced and ISO 17020 accredited marine company, as the HMI process requires that the sampling plan first be approved by class before the survey is undertaken. It can be quick and costly if the plan is not approved when first submitted. After the investigation, the classification society will review the report and approve or make recommendations on the report, so it pays to get the correct report on the first submission. Once the survey is completed and approved, the class can issue a Certificate of Compliance, which is part of the vessel’s annual certification.
In summary, it is shortsighted for shipowners to consider that only ships visiting EU ports need an HMI. Eventually, all ships will have to comply with the Hong Kong Convention. In addition, the benefits of an HMI can go much further. In the longer term, proving that a ship is asbestos free can eliminate the risk of potential exposure claims from crew members. And as recent Lucion experiences have shown, a proactive decision to implement HMI surveys on a fleet can eliminate the possibility of a misdiagnosis of a shipyard or contractor during refits or repairs. repair, thus avoiding additional costs and unnecessary delays.
John Chillingworth is Senior Marine Director at Lucion Marine. Lucion Marine has provided specialized hazardous materials management services to the global marine industry for ten years. Backed by internationally recognized and accredited laboratories, the company works with the major owners and operators of vessels, offshore platforms and all types of vessels, helping them to comply with SOLAS, the Hong Kong Convention and European regulations on ship recycling. More details on www.lucionservices.com.
The opinions expressed here are those of the author and not necessarily those of The Maritime Executive.