Hazardous Material Inventory (HMI) surveys, when done correctly, can have a range of unexpected benefits for vessel owners. Recent experience not only underscores the value for shipowners to have an approved inventory for their vessels, but also reaffirms the need to ensure that surveys are carried out correctly.
Hazardous materials consultancy Lucion Marine was recently appointed to assist a major cruise line with work on a cruise ship built in 2008. In this particular case, a shipyard, during a pre-refit visit, claimed that an area where a new scrubber installation was planned contained asbestos in the bulkhead fire insulation.
At the request of the ship’s technical manager, Lucion Marine met with the shipyard and its asbestos expert on board the ship in Jamaica. After discussions, we then carried out mutual tests in three locations on board where the shipyard claimed that asbestos was present. Additionally, within six hours, we collected 90 additional samples throughout the collection and returned them to our lab 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 present. 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 this was the first time the surveyor had been on a ship.
We also suspect that some of the sampling equipment used in the initial investigation of the ship may have been contaminated during previous work and subsequently contaminated the samples taken from the cruise liner.
In the end, this may seem like a satisfactory result for the liner, as the refit work can go smoothly, but this does not take into account the additional costs and work interruptions involved. For example, there is the time lost and the additional surveying costs incurred, as well as the travel costs of sending specialist surveyors to the shipyard, not to mention the management and labor time lost after the shipyard raised its 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 isolating asbestos in a work area. These other situations proved to be more aggravating: the claims occurred during refit work, which was then halted, causing considerable delays and costs until thorough testing was carried out.
During our work we have found asbestos in over 80% of new ships, and we regularly work with cautious shipowners such as Maersk, BP and the Royal Navy to have their new ships inspected before they are delivered from the yard. naval. Many government maritime authorities recommend that all ship owners have a specialist ISO17020 asbestos survey carried out to eliminate the risk of asbestos in order to demonstrate that a ship is free of asbestos. The need for this was created because shipbuilders base their “asbestos free certificate” solely on suppliers’ material declarations, with no direct testing of supplied parts or components.
Additionally, the term “asbestos-free” can be misleading due to the different international thresholds that govern and control its precise definition. For example, in the US an asbestos content of up to 1.0% may be permitted, 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 shipowners 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 inspected a series of six French new builds in South Korea and found asbestos in the seals of the fire doors of the fourth vessel, highlighting that the supply chain can be affected at any time. It should be noted that 60% of an HMI inspection is an asbestos survey. Therefore, carrying out a professional and efficient HMI will eliminate the risk of any contamination claims during a refit or with owner supplied items.
In terms of regulations, the Hong Kong Convention requiring all ships to have an HMI was implemented to ensure that a ship had a formal record of all hazardous materials on board. This ensures that when the ship is recycled, an accurate ship demolition plan can be produced, with particular attention to the safe handling of any hazardous materials present.
This regulation is still awaiting 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 issued a regulation that all EU-flagged vessels, or any vessel visiting an EU Port, must have a classification society approved HMI by December 2020.
It is important for a ship owner to select an ISO 17020 accredited marine specialist company, as the IHM process requires that the sampling plan be first approved by class before the survey is undertaken. This can be expedient and costly if the plan is not approved on first submission. After the investigation, the class society will then review the report and approve or make recommendations on the report, so it pays to get the report correct on the first submission. Once the survey has been completed and approved, the class can issue a certificate of compliance, which forms part of the annual certification of the vessel.
In summary, it is unwise for shipowners to assume that only ships visiting EU ports need an HMI. Eventually, all ships will have to comply with the Hong Kong Convention. Moreover, the benefits of an HMI can go much further. In the longer term, proving that a vessel is free of asbestos can eliminate the risk of potential exposure to crew members. And as Lucion’s recent experiences have shown, a proactive decision to implement HMI surveys on a fleet can eliminate the possibility of a shipyard or contractor misdiagnosing a shipyard or contractor during refit or repair, thus avoiding additional costs and unnecessary delays.
John Chillingworth is Senior Marine Manager at Lucion Marine. Lucion Marine has been providing specialist hazardous materials management services to the global marine industry for ten years. Supported by internationally recognized and accredited laboratories, the company works with major owners and operators of ships, offshore platforms and all types of marine vessels, helping them to comply with SOLAS, the Hong Kong and European ship recycling regulations. More details at www.lucionservices.com.
The opinions expressed here are those of the author and not necessarily those of The Maritime Executive.