Asbestos On Ships: How To Manage It Safely
Asbestos On Ships: How To Manage It Safely
Asbestos On Ships: How To Manage It Safely
Lloyds Register Group Limited, its afliates and subsidiaries and their respective ofcers, employees or agents are, individually and collectively, referred to in this clause as Lloyds Register. Lloyds Register assumes no responsibility and shall not be liable to any person for 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 Lloyds Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.
Contents
Foreword 3 Part 1 A history of asbestos 1 What is asbestos 2 The rise of asbestos 3 Health and regulation 4 Testing for asbestos Part 2 Asbestos on board ships 1 The increased risk in shipping 2 Where is asbestos found on ships 3 Regulation 4 How the marine industrys stakeholders can protect their workers 5 Tools for achieving best practice in management Appendix Common asbestos areas on board ships 4 4 7 10 14 17 17 18 21 27 30 36
Foreword
This publication should help shipowners and operators understand how to deal with asbestos on board their ships and eets and ultimately achieve compliance with maritime asbestos regulations from the International Maritime Organization (IMO). But it also takes a wider look at the material, exploring its history, composition and health effects in order to underline the vital importance of managing it correctly. The worldwide death toll due to asbestos-related diseases is sobering. Globally, it is estimated that more than 107,000 people die each year from mesothelioma, lung cancer and asbestosis (the three major asbestos-related diseases) as a result of occupational exposure1. And due to the materials 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) and is still widely used, particularly in developing countries. And it is of course present in many existing buildings and structures, including ships. Yet management of asbestos around the world is improving. Most industries and countries are increasingly aware of the risks and huge advances have been made in the amount of asbestos used and particularly the type: nearly all of the asbestos produced worldwide is now chrysotile, or white asbestos2 which is considered the least dangerous 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. Lloyds Register is particularly indebted to the Imperial War Museum and HMS Belfast for many of the photographs this publication contains. These have been invaluable in helping us illustrate where asbestos can be found on board ships and how it should be managed. Robin Townsend Regulatory Affairs Lead Specialist, Lloyds Register
World Health Organization (2010). Elimination of asbestos-related diseases (Fact sheet N343). Available at: http://www.who.int/mediacentre/factsheets/fs343/en/index.html 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)
1. What is asbestos?
Asbestos is a generic name given to the brous variety of six naturally occurring silicate minerals3. Silicate minerals make up a large proportion of the rocks on the planet. All asbestos rocks occur in, or separate very easily into, very small bres or brils with a diameter of only a few nanometres.
Type
Name
CAS Number
Actinolite
77536-66-4
A: Low B: Low C: 0 A: Medium B: Low C: 0 A: Low B: Low C: 0 A: Medium B: Low C: 0 A: Low B: Low C: 0 A: 500 B: 10-50 A: 100 B: 10-50
Amosite (grunerite) (brown) Asbestos family Amphibole (ve types) Short, sharp bres
12172-73-5
Anthophyllite
77536-67-5
Crocidolite (blue)
12001-28-4
Tremolite
77536-68-6
Chrysotile
12001-29-5
A: 1 B: 1
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/
Amosite asbestos, like other amphibole forms of asbestos, consists of straight brils with a small diameter which migrate more readily to the periphery of the lungs and penetrate the pleura where they can cause the disease mesothelioma (see page 12).
L. Prandi, M. Tomatis, N. Penazzi and B. Fubini (2002). Iron Cycling Mechanisms and Related modications at the Asbestos Surface. The Annals 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 Its proper name is actually grunerite, but it is more commonly known as amosite after the company that ran the site in South Africa where it was mined.
Other substances
This section leaves us with two questions which are beyond the scope of this publication. Firstly, are there other asbestos-like minerals that are not presently considered dangerous which might be added to the list in the future? The brief answer is yes, one example being a mineral called soda tremolite or winchite asbestos. The other question is whether the materials being used to replace asbestos may prove to be hazardous in the future.
D. Loomis et al (2009). Lung cancer mortality and bre exposures among North Carolina asbestos textile workers. Occupational & Environmental Medicine, Volume 66, Issue 8. Available at http://oem.bmj.com/content/66/8/535
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 Antti Tossavainen et al (2001). Amphibole bres 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-4be5a6cc711b
9 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/
Asbestos has been used for thousands of years thanks to its extraordinary properties. Today, it is easy to forget how asbestos revolutionised our modern lives. It protects against re and heat, adds strength to materials and insulates against electricity. It is pliable, forgiving, cheap and easy to use. No modern substance can provide all these engineering benets and it is still without equal.
Early reported uses In AD 800, Emperor Charlemagne was reported as having a tablecloth that never needed cleaning. When it became dirty, he simply threw it into the re, and it came out clean and unburnt. The Greeks and Romans may have done the same thing, as reported by the famous historian Strabo in his Geography and Pliny the Elder in his Natural History. Indeed, it seems to have been a global habit since Marco Polo reported a cloth that thrown into the re, remains incombustible. First large commercial mines Asbestos is known to have been commercially mined in Russia in 1720. Enormous deposits of chrysotile asbestos were found in 1844 near Asbest city. Even today the entire area looks like a vast open cast mine. The industrial revolution and the steam age Modern asbestos mining in industrialised nations began expending rapidly from the late 1800s, probably due to steam technology. Vast chrysotile asbestos reserves were discovered in 1877 at Danville in Quebec, Canada, and have been mined until very recently (see case study overleaf).
A Roman glass crematorium urn, containing bones and traces of asbestos burial shrouds (Image courtesy of the British Museum.)
A purse, made out of tremolite asbestos, brought to London by Benjamin Franklin, 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.)
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Crocidolite asbestos was discovered in the Northern Cape province of South Africa in 1812 but was not commercially produced until 1893. The properties of crocidolite made it particularly well suited for spraying, and sprayed crocidolite asbestos products were rst marketed in the UK in 1931 by J.W. Roberts Ltd (JWR) at its factory in Armley. Amosite asbestos deposits in Penge in the Transvaal province went into proper production in 1916. Mass production and usage By 1920, the world was using nearly 200,000 tonnes of asbestos, of which 150,000 tonnes were consumed by the US, 40,000 by Europe, 7,000 tonnes by Asia and the Middle East, and 2,000 tonnes by Africa11. By 1930 this had almost doubled to 388,000 tonnes. By 1940 the gure was 522,000 tonnes. The second world war and subsequent re-construction led to a boom in the use of asbestos. The US alone used over half a million tonnes of asbestos every year from 1947 to 1979. Interestingly, it only started using the most dangerous types (crocidolite and Amosite) in 195611. By 1960, global asbestos consumption was well over 2 million tonnes. In 1970, consumption was at 3.5 million tonnes and still rising. In 1975, it was 4.3 million tonnes and in 1980 consumption was at 4.7 million tonnes. The decline The decline in asbestos use only began in 1985 when production fell to 4.3 million tonnes. The decline was slow. In 1990 production was still 4 million tonnes, despite major bans already being in force around the world. Finally, in 1995 signicant reduction started to take place. Consumption had almost halved from the peak to 2.5 million tonnes, although even by the year 2000 consumption was still comparable with 1960 at 2 million tonnes. Today, world production remains relatively steady at 2.03 million tonnes12.
2010
2011
2012e
270,000 302,000 300,000 100,000 50,000 400,000 440,000 440,000 214,000 223,000 240,000 1,000,000 1,000,000 1,000,000 21,000 19,000 20,000 2,010,000 2,030,000 2,000,000
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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/ R.L.. Virta (2011). USGS 2011 Minerals Yearbook Asbestos. Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/myb1-2011-asbes.pdf CBC (2011). Asbestos mining stops for rst time in 130 years. Available at http://www.cbc.ca/news/canada/story/2011/11/24/asbestos-shutdown.html (Accessed 13 March, 2012)
12
13
14 Report of the Conference of the Parties to the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals 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 and http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/mcs-2013-asbes.pdf
In 1930, Merewether and Price, two medical inspectors from the Factory Department17 delivered research on the asbestos textile industry in Britain it identied that 25% of the 363 workers examined had pulmonary brosis. It was in the 1930s that workers with asbestosis rst started suing their employers.
It would be hard for major industry players to deny that from the late 1950s to the late 70s there was systematic self protection and a lack of assistance to injured parties, ranging from a reluctance to undertake investigations that were clearly needed to deliberate suppression of evidence. Such behaviour undoubtedly delayed action and exacerbated an already dire situation.
ource: Peter W.J. Bartrip (2001). The Way from Dusty Death: Turner and Newall and the Regulation of the British Asbestos Industry, S 1890s-1970. Athlone. Factory inspectors were rst appointed under the Factory Act of 1833. A central ofce, later named the Factory Department, was established and supervised by the Domestic Department, and later the Industrial Department, of the Home Ofce. Taken from the National Archives at http://discovery.nationalarchives.gov.uk/SearchUI/details?Uri=C10130 (Accessed 13 March, 2013)
17
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The industry attitude of the time could perhaps be gauged from the words of E. A. Martin of Bendix Corporation. He is reported in various sources (including plaintiffs records and the Congressional Record) as writing the following in a letter dated September 1966: My answer to the problem is: if you have enjoyed a good life while working with asbestos products why not die from it? Theres got to be some cause.
Asbestos-related diseases
Asbestos causes a number of health problems of varying severity.
Asbestosis
The term asbestosis is commonly misused by the media to describe any illness caused by asbestos exposure. It is in fact a form of pneumoconiosis any lung disease caused by breathing small particles; in this case, asbestos bres. In an asbestosis sufferer, the air sacs (alveoli) which control gas transfer in the lungs become scarred and healthy lung tissue is replaced by brous tissue. This prevents the alveoli from working and reduces the effectiveness of the lungs. Symptoms include 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 attributed to asbestosis in the UK.
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IBAS (2012). Current Asbestos Bans and Restrictions. Available at http://www.ibasecretariat.org/alpha_ban_list.php (Accessed 13 March, 2013) 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 The general term for membranes that protect organs in the body cavity (see also Mesothelioma on page 12)
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Pulmonary brosis
Pulmonary brosis is the general term for diseases which progressively scar the lung, interfering with the ability to breathe. It is used when the cause of scarring is not known and therefore appeared in the early descriptions of asbestosis.
Mesothelioma
Mesothelioma is a form of cancer which affects the bodys mesothelial membranes, those surrounding organs in the body cavity such as the heart, lungs and stomach. It is believed that asbestos bres migrate through the lungs to these areas. The most common form of mesothelioma (and the one most associated with asbestos exposure) is malignant pleural mesothelioma which affects the pleura the mesothelium surrounding the lungs. Before the widespread use of asbestos, mesothelioma was rarely diagnosed. Once asbestos exposure was recognised as a causal link, the reporting rate increased and we now know that 80% of mesotheliomas are caused by asbestos. Mesothelioma is far more indicative of asbestos exposure than lung cancer, which is relatively common due to other factors such as smoking. Mesothelioma tends to appear as a series of tumours. The only possible cure is to completely remove them. However, because mesothelioma is normally diagnosed only after signicant spreading of the disease, surgery is unlikely to do more than provide short term relief from certain symptoms. Most treatment for the disease is therefore palliative.
Mesothelioma is an aggressive cancer. Less than 10% of sufferers survive more than two years after diagnosis and sufferers of malignant pleural mesothelioma often survive only a few months. In 2009, 2,321 people died of the disease in the UK. Incidences of mesothelioma have yet to reach their peak because of the 15 to 40 year lag time between exposure and the appearance of tumours.
Lung cancer
Because lung cancer is caused by many factors, including smoking, it is difcult to denitively attribute cases of the disease to asbestos exposure. In the UK it is thought that asbestos-related lung cancer is less common than mesothelioma, but the US believes it is more common. Smoking appears to greatly increase the risk of lung cancer being caused by asbestos exposure. The disease consists of the uncontrolled growth of tumours or lesions in the lung tissue. In malignant tumours, cells can break away (metastasise) and travel to other parts of the body, normally via the bloodstream or lymph system, to form new growths. Benign tumours do not metastasise: they can be safely removed via surgery and will not recur. Lung cancer can be treated by chemotherapy, radiotherapy, surgery or all three. The level of surgery varies depending on the spread of the cancer. It is more usual to remove one lobe of a lung than the entire lung. Survival rates for lung cancer are better than for mesothelioma: approximately 20% of people diagnosed with the disease may survive ve years.
Other diseases
There is evidence that asbestos can cause other cancers such as bowel, stomach, oesophagus, pancreas and kidney.
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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)
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Of course, none of this means that people never die from small exposures to asbestos. The case of Shirley Gibson (see page 12) illustrates this point. And there are well documented cases of the wives of asbestos workers who died from asbestos-related diseases, whose principle exposure was only from washing their husbands overalls. In the same way, people who smoke heavily all their life may never get lung cancer while other people who have never smoked may be killed by relatively minor exposure to passive smoking. Table 3 summaries the results from various studies of people who worked in crocidolite asbestos mines or in manufacturing using crocidolite asbestos. When interpreting gures like these, it is important to note that many factors may have inuenced the differences in results, including cases not being reported.
Location
Industry
Timescale
Number of cases 9 probably mesothelioma 222 cases mesothelioma 5 mesothelioma, circa 20% abnormalities 5 mesothelioma
Year of study
Canada
1939-1942
197823
Australia
6,916
1943 1966
200724
South Africa
Mining
3,430
Before 1962
1974-197825
UK
435
1930s to 1969
198226
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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 & Environmental Medicine Volume 65, Issue 8. Available at http://oem.bmj.com/content/65/8/541 25 26
J.M. Talent et al (1980). A survey of black mineworkers of the Cape crocidolite mines. Biological Effects of Mineral Fibre 2.
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/
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The subject of testing for asbestos could ll several books by itself. There are many different testing techniques which suit different circumstances, such as the way an asbestos sample has been extracted and prepared or the substance it has been extracted from. All techniques have their own advantages and limitations so it is often necessary to combine methods in order to get the most accurate results. This section describes the principal methods. The recognised International Standard for laboratory quality is ISO 17025:2005. Many countries run prociency programmes, sending random samples to laboratories to see how accurate they are. Most labs perform very well and easily exceed the criteria for accuracy. Stereoscopic microscopy (20x). This test quanties the number of bres in a sample but not the type. If you do not need to know what your bres are for example you are doing an air sampling lter examination and you only expect asbestos bres then you can do this count to ensure you are below the required threshold. It is very quick, simple and cheap. Polarized light microscopy, PLM. This is one of the simplest and most reliable methods, especially for bulk samples, and is probably the commonest. It identies the type and percentage of asbestos using a phase contrast microscope with polarising lters. Its limit of detection is somewhere between 0.1% and 1% which means it may be insufcient by itself if absolute accuracy is needed at these levels. In these cases it will need to be supplemented by other techniques. It is a very fast technique and therefore good for statistical analysis. Scanning electron microscopy (SEM). SEM scans the surface of the sample and uses the reection from the scattered electrons to create a picture. The advantage of SEM is that it magnies the image up to 300,000 times. It is particularly useful for bulk sampling. SEM is normally the most denitive technique, and can be enhanced by x-ray spectrum analysis.
X-ray diffraction (XRD). In this technique the object is bombarded with X-rays. The rays are reected by the asbestos particles, producing an x-ray spectrum which is characteristic of the substance. XRD is sometimes used instead of PLM, or to supplement it. However, XRD has limitations: it cannot describe size or shape and so is only really quantitative. Transmission electron microscopy (TEM). TEM uses a very thin section of the sample (unlike SEM, which scans the surface). It works on the same principle as an ordinary light microscope but uses electrons instead of light. Electrons are very much smaller than light and so the resolution is correspondingly higher. It is therefore a more sensitive test than PLM. However, this sensitivity means that a coarse test sample can cause problems. Further, because TEM relies on area ratio estimations to determine asbestos concentration, it can have limitations at low asbestos levels. This can be a problem if your legislation species a low asbestos limit (say, 1%) and can mean the same sample may pass at one lab and fail at another. Gravimetric analysis. This test is used to determine the quantity of asbestos in the sample and works by removing all other substances. The sample is weighed and then ashed in a furnace to remove volatile organic compounds (VOCs). It is then weighed again to determine the amount of VOCs that have been lost. The sample may then be acid washed to remove other likely compounds such as carbonates and weighed again. At this point a more sensitive analytical method, such as PLM or even TEM, is used to identify asbestos bres so that the quantity of asbestos in the original sample can be estimated. This test is fast and efcient but is only really relevant when you know your sample contains asbestos.
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Test type
Good for
Speed
Ease of use
Drawbacks
Stereo microscopy
Fast
Not a test for asbestos. It only performs an initial check, to indicate how the sample should be further prepared and what proper tests are likely to be best.
Magnies the sample 100 to 400 times and uses other techniques such as polarisation and dyes to do basic bre and quantity analysis Uses electrons to scan the sample and produces massively magnied 3D images to nd and identify bres Uses X-rays to examine crystal properties, but does not produce an image
Fast
Medium. Can be very good with specic types of asbestos bound up in a simple matrix Good
Slow
Fast
Poor. Cannot identify between asbestos and non-asbestos forms of the same material. Good
Fires electrons through a very thin slide of the material and produces massively magnied images (10 to 20 000 x) to identify bres Through weighing and reduction of the sample, it nds the mass percentage of asbestos
Slow
Cost
Gravimetric analysis
None. Does not identify asbestos and relies on other techniques to do this rst.
Moderately easy
I. Doniach, K.V. Swettenham, and M.K. Hathorn (1975). Prevalence of asbestos bodies in a necropsy series in east London; association with 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 Mesothelioma of the pleura in Trieste, Italy. American Journal of Industrial Medicine, Volume 22, Issue 4. Available at http://onlinelibrary.wiley.com/doi/10.1002/ajim.4700220407/abstract
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In the worst cases, you can nd asbestos virtually everywhere on a ship. It can be in: the concrete and tiling on the oor the wall and ceiling panels and the re insulation behind them the doors the glues and sealants in the windows and furniture heat insulation and lagging electrical cables brake linings and gaskets
mooring ropes remens outts boiler cladding furnace rebricks, and welding shop curtains and welders gloves.
The list goes on. The International Maritime Organization (IMO) has published a detailed list of areas where asbestos can be found3 (see Table 4).
Pipes and cables. These could contain asbestos but if maintained in good condition they will be safe.
The International Maritime Organization is a specialised agency of the United Nations, with one hundred and sixty nine member states. The IMOs main regulatory instrument is the Convention. Once a convention has entered into force, any ship trading internationally is bound to comply fully with it anywhere in the world. The list of asbestos areas was developed in support of the IMOs 2009 Hong Kong International Convention on the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention) and is used by The International Association of Classication Societies (IACS) in its guidance on the subject.
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Component Packing with low pressure hydraulic piping ange Packing with casing Brake lining Clutch Synthetic stern tubes Packing with piping ange Lagging material for fuel pipe Lagging material for exhaust pipe Lagging material turbocharger
Lagging material for casing Packing with ange 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 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 ange 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 Packing for casing door Packing with hand hole Packing with manhole Gas shield packing for soot blower Packing with ange 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 Packing for casing door Packing with manhole Packing for casing door and valve Gland packing Packing for casing door and valve Gland packing for valve Packing with hand hole Lagging material for exhaust pipe Brake lining
Boiler
Incinerator Auxiliary machinery (pump, compressor, oil purier, crane) Heat exchanger Valve Pipe, duct Tank (fuel, hot water, tank, condenser), other equipments (fuel strainer, lubricant oil strainer) Electric equipment Airborne asbestos Ceiling, oor and wall in accommodation area Fire door Inert gas system Air-conditioning system Miscellaneous
Gland packing with valve, sheet packing with piping ange Gasket with ange of high pressure and/or high temperature Lagging material and insulation Lagging material and insulation
Insulation material Wall, ceiling Ceiling, oor, wall Packing, construction and insulation of the re door Packing for casing, etc. Sheet packing, lagging material for piping and exible joint Ropes Thermal insulating materials Fire shields/re proong Space/duct insulation Electrical cable materials Brake linings Floor tiles/deck underlay Steam/water/vent ange gaskets Adhesives/mastics/llers Sound damping Moulded plastic products Sealing putty Shaft/valve packing Electrical bulkhead penetration packing Circuit breaker arc chutes Pipe hanger inserts Weld shop protectors/burn covers Fire-ghting blankets/clothing equipment Concrete ballast
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Thick insulation. All of this could be asbestos. This image demonstrates the potential amount of asbestos that can be present on ships. If it is properly sealed and kept in good condition then the risk is acceptable.
A battery operated sniffer mounted on the stairs at the exit of a compartment. For areas of particular concern, air monitoring can demonstrate they are safe.
The oor of a bridge showing damaged, friable asbestos-containing cement. Asbestos is often used to boost the re-resistant properties of A-60 partitions4. The bottom layer of concrete is likely to be a skimming layer, used to achieve a level surface. The asbestoscontaining concrete layer may have been put down next, followed by a nal nishing and levelling layer before the vinyl oor was put down. The vinyl oor may contain asbestos too.
An A-60 partition is a particular type of re-resistant partition designed to work for 60 minutes.
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3. Regulation
Conventions requirements within their national limits and on board ships which y their ag. Recognised organisations (ROs) are authorised by the ag state to carry out on their behalf the statutory surveys and certication required to demonstrate compliance. Classication societies commonly act as ROs. Lloyds Register is an RO for over 140 countries administrations. Flag states can also apply local laws and requirements to ships which y their ag (see page 26 for an example from the Netherlands).
supple and exible thermal insulation assemblies used for temperatures above 1,000 C. An amendment which came into force on 1 January, 2011, banned all new installations.
ISO standards
The International Organisation for Standardization (ISO) publishes a number of standards on asbestos. These are not legal requirements unless directly referenced by law.
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 on board the ship, but may not actually be installed. This presumably avoids the expense of having to remove such materials from the stores. It is recommended that owners ensure asbestos or asbestos-containing materials within stores are properly managed and not used. For newbuilds, this wording also means that items containing asbestos purchased before 1 January, 2011, may not be installed. For example, a windlass purchased and 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 and new ships is explored in more detail on pages 22 to 25.
The role of ag states and recognised organisations in ensuring compliance with SOLAS
Flag states5 are responsible for ensuring that the provisions of the SOLAS Convention are properly represented in national law and for enforcing the
5 6
A ag state is the administration of the government where the ship is registered, whose ag a ship is entitled to y.
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)
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Despite the IMO Guidelines, it appears that within the industry there is little impetus to ensure that existing asbestos on these ships is managed effectively. This leads to potentially strange situations such as recently built ships being forced to remove small amounts of asbestos at huge cost while ships containing many tonnes of blue asbestos in a badly managed condition continue sailing without any restriction. LR believes the greatest safety benets are to be gained by making sure that any asbestos is managed properly, regardless of the ships age. In this section, we look some of the text relating to asbestos management contained in IMO Circular 1045 and provide additional recommendations. 2.4 Planned repairs or removal of such materials should be carried out by specialist personnel and not normally by crew. In cases where the crew is involved in urgent repair work at sea, special measures should be observed as listed in annex 1. Procedures should be developed for the safe retention of any waste asbestos on board the ship before it can be transferred and disposed of ashore. This is vitally important. Ordinary crew must not interfere with asbestos in any way. Any owner or person involved with the ship who makes such a request of ordinary crew could possibly be committing an illegal act and exposing the company to enormous liability. If asbestos is known, or suspected, to be on board a ship, owners should examine the requirements for its removal (including the experience, training and equipment needed) and, if appropriate, allow specialist crew members to either undertake urgent repair work in the presence of suspected asbestos, or undertake minimum remedial action if suspected asbestos is damaged, exposed or friable. Such measures would normally be limited to simply taping over, or similarly sealing. exposed areas, in accordance with a proper procedure and using specially provided materials. In all cases it is vital to check local legislation rst, but it should be reasonably simple to train senior crew members such as chief engineers to carry out this work.
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3 General provision The Company should make provisions, including the nomination of a responsible person to control the maintenance and monitoring program for asbestos, in their Safety Management System (developed for compliance with the ISM Code) for the maintenance and monitoring of on board materials containing asbestos in line with the provisions of the present Guidelines. A good land-based example of such provisions is management of asbestos in schools. A typical school has a person on site who is responsible for asbestos and has the necessary training to repair small areas of damage and to identify when the level of damage requires outside specialists. This means the school does not need to remove the asbestos. This non-marine example shows that if we can manage asbestos in our schools we can certainly manage it on board ships (see The Case of Shirley Gibson on page 12).
4 Inventory and condition assessment of asbestos-containing materials 4.1 The Company should have an initial ship inspection performed by a qualied professional to investigate the possible presence of asbestoscontaining materials on board the ship and, if any are identied, to locate them and assess their condition. The inspection should serve as the basis for establishing an effective maintenance and monitoring programme for dealing with the asbestos in the ship. This is self explanatory, but we would go further and recommend that a full Inventory of Hazardous Materials7 is prepared (as required by the Hong Kong Convention). This can give shipowners greater condence in the safety of their crews and greater awareness of potential liabilities. It will also help ensure early compliance with the Hong Kong Convention requirements.
The Inventory of Hazardous Materials is a list of certain hazards onboard a ship, including asbestos, which is required to be compiled for the Hong Kong Convention
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4.2 In the case of ake coatings, lagging or false ceilings containing asbestos, their condition should be assessed by completing the evaluation checklist shown in appendix 1 to annex 1, which takes into account, in particular, the accessibility of the materials and products, their degree of degradation, their exposure to shocks and vibration and the presence of air currents in the area. Air sampling of dust measurement may be used as one tool to help provide a more complete assessment of the ambient conditions on board. The evaluation form contained in appendix 2 to annex 1 should be used to make the diagnosis on the state of conservation 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 marine expertise is used. Experience shows that land-based companies do not understand the complexities of ship structures or operations. For example, ceilings on land are often ignored in asbestos assessments since they are out of reach. But the constant movement and vibration on ships can cause highly friable asbestos above false ceilings to shed bres. 5 Maintenance and monitoring programme 5.1 If asbestos-containing material is located, a maintenance and monitoring programme should be developed for that ship, based on the inspection and assessment data. The programme should be implemented and managed conscientiously and include the elements contained in annex 1. Asbestos management is not only about safety, it is about corporate risk management. Unmanaged asbestos is an unknown and potentially enormous long-term liability. Maintenance and monitoring programmes are costeffective tools designed to save lives in the long term. 5.2 In the case of ake coatings, lagging or false ceilings containing asbestos, depending on the diagnosis as described in paragraph 4.2, the company should establish appropriate thresholds and timescales for undertaking any necessary repairs or abatement, taking into account any national regulations. This paragraph highlights the fact that asbestos in some locations may be so friable and subject to such frequent disturbance that removal may be the only option. Asbestos management must ensure that the relevant national regulations are properly followed and implemented.
6 Abatement actions, planned repair and removal of asbestos-containing materials 6.1 Abatement actions should be selected and implemented when necessary. In some instances, due to the condition of asbestoscontaining materials or upcoming ship repairs or modications, a Company may decide to take other abatement actions to deal with asbestoscontaining materials in the ship. These response actions could include: encapsulation (covering the asbestos-containing materials with a sealant to prevent bre release), enclosure (placing an air-tight barrier around the asbestos-containing materials), encasement (covering the asbestoscontaining materials with a hard-setting sealing material) or repair or removal of the asbestoscontaining materials. Qualied, trained and experienced contractors should be used for any of these actions. The Company should be aware of any national and local regulations that pertain to abatement actions to deal with asbestoscontaining materials. This provides further clarication on paragraph 5.2. Encapsulation, enclosure and encasement can be very effective measures and can be much cheaper than removal, but they do require constant monitoring and procedures must be put in place for potential repairs. 6.2 In the event of works requiring the removal of asbestos-containing materials, they should be unloaded from the ship. On completion of the work, and before any restoration of the spaces, the Company should carry out dust measurement after dismantling the enclosing mechanism. If the work does not result in the total removal of the materials and products listed in this order, the Company should carry out regular surveillance of the asbestos-containing materials at intervals identied by the Company as being appropriate, but not exceeding 3 years. Various studies have been carried out on the results of asbestos concentration monitoring on board ships. One study8 compiled evidence from 52 in-house studies and 84 different vessels which included the analysis of over 1,000 air samples under normal conditions (i.e., with no asbestos work underway). Nearly 99% of the samples were below the common health and safety limit of 0.1 bres per cubic centimetre (cm3) and all were below 1 bre per cm3.
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
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Focus on newbuilds
For newbuilds, the SOLAS regulations have prohibited all new installations of asbestos since 1 January, 2011. Subsequent interpretation9 of the regulations means that ROs are now required to review asbestos free declarations and supporting documentation provided by the manufacturer, shipyard or repair yard.
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Supply chain case studies The importance of supply chain checks: asbestos in baby talcum powder
In April 2009, three South Korean manufacturers had to recall baby powder products after the health authorities discovered they contained asbestos. The Korean Food and Drug Administration initially conrmed asbestos in 11 talc products but then went on to discover 1,122 drugs and medical products containing the contaminated talc. The asbestos was understood to have come from talc mined outside Korea and may have become contaminated during the milling process before import. The talc was imported by a company which specialised in providing chemical raw materials to the pharmaceutical industry10. While this didnt occur within the maritime industry, it shows the importance of having checks throughout the whole supply chain. Remember, the manufacturer may have been acting correctly in terms of their contract and national law.
Caroline Essberger12
The 8,400 dwt tonne chemical Tanker Caroline Essberger was built in the Eregli shipyard in Istanbul, Turkey in 2009 for German Shipowner John T. Essberger. She was found to be riddled with asbestos in thousands of gaskets and other seals. The asbestos was only found several months after the ship was built and all the items had to be replaced. It was estimated that the cost of replacement of the asbestos parts was in the order of 10% of the original cost of the ship, although the work was carried out at Essbergers own facilities.
10 11 12
Talc is commonly used as an excipient, the inactive ingredient that actually carries the drug the bulking agent in a pill for example. Note that Lloyds Register and other classication societies already check ships plans for comments regarding asbestos during plan approval.
Source: Lloyds 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)
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Shipowners
The shipowner has the greatest direct responsibility for the people on board the ship be they crew (either employed directly or by a crewing agency) or visitors (Surveyors, Port State Control Ofcers, Cargo Assessors, or P&I). Owners must ensure that effective top-down and bottom-up asbestos management is in place. A key tool that a shipowner would be expected to use is a risk assessment (see page 33).
Shipyards
Shipbuilders and repair yards not only have a responsibility to protect their workers from asbestos, but they should be aware that the ship they are building or repairing must comply with SOLAS (if it is governed by the Convention) and other relevant national or international legislation. It is best for this information to be included in the general and specic terms of the contract with the shipowner.
Asbestos protection during ship recycling. The blue pipes contain asbestos and have therefore been wrapped in protective blue plastic. The white uptake (on the left) was presumed to contain asbestos and marked a. Testing revealed it was clear of asbestos and so the a has been crossed out. (Photo courtesy of Leyal Ship Recycling.)
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Mixed glass wool and asbestos disposal facility. Note the bags which have been dumped at the entrance to the pit, rather than in it. Some bags are torn and their contents are spilling out.
Port authorities
The main two responsibilities for port authorities are to ensure the relevant national and international asbestos requirements are enforced and to look after the safety of people working inside the port, including people on ships of other ag states in the port authoritys area of responsibility. Port authorities have the legal right and power to inspect ships, and these inspections should be carried out thoroughly. Because many of the major maritime conventions, such as SOLAS, rely on mutual acceptability of certicates, port authorities should have good reason to perform extended surveys: normally there is an accepted framework for establishing this.
Ship managers
As a ship manager stands in the place of the shipowner, our opinion is that they share identical responsibilities. Since managers are responsible for SOLAS compliance they must be experts in the Conventions asbestos requirements. The role of the ship manager does not necessarily lessen the responsibility or liability of the shipowner. No matter what the involvement of the ship manager, the owner should independently examine their roles and responsibilities.
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Record
No
Find out if ACMs present: check plan/drawings carry out survey Yes
No further action
Prepare management plan ACMs in good condition Monitor Damaged ACMs Repair/remove Maintenance work Manage
Train staff Manage contractors Checked all work against plan/register Control of work itself: Asbestos essentials Compliance with CAR
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Identify ships in eet to be managed Record. Maintain evidence and decision making steps Approved service supplier
Find out if ACMs present: check plans and drawings. Carry out samples and surveys, check procurement information
Implement effective management system Policy Procedures Objectives and targets Safety provision Maintenance work Equipment and PPE provision Monitor ACM Measure performance Update records Document Review
Improve procedures
Figure 2: The land-based Asbestos Management Plan adapted for maritime use.
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Did the country of build No legally outlaw asbestos at the time of build, or did the contract specify asbestos free Yes No Is there a reputable asbestos free certicate (or a list of asbestos available from the time of construction) Yes No Is there a reputable asbestos free certicate available Yes
Have any large reputable No asbestos registers been done? (has a list of asbestos been provided?) Yes
No
Have all the owners of the ship since newbuild maintained accurate, documented information to prove that an asbestos free procurement programme has been followed? Yes Yes Yes
High condence that ship is free of asbestos (or that a known list of asbestos is available)
Note: you must follow the arrows directly down from the year of build unless an arrow takes you sideways.
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This appendix contains images of the places where asbestos is most likely to be found on board ships. It is based on an educational powerpoint presentation used to train our surveyors, prepared in collaboration with M.A.R.C a Netherlands-based, licensed specialist asbestos company. We are very grateful for their assistance and for the use of many of their photographs in this section.
Asbestos re blankets
Asbestos re blankets are a common nuisance. They are often brought on board ships by uncontrolled sub-contractors carrying out temporary work. They are extremely easy to damage and very friable, so they will easily shed large numbers of bres which can be difcult to clean up. Their asbestos content will be very high well over 50% but the good news is that they are likely to be new and therefore contain only chrysotile asbestos.
Friable mess and bres from an asbestos blanket. Note: a piece of cloth has been used to protect the deck from the scaffolding this will clearly cause large bre releases.
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Asbestos blankets being used to protect oil tanks from ame and sparks
A Portland cement ceiling which is not A damaged and friable asbestos damaged or friable millboard ceiling It is very difcult to tell the difference between these two ceilings and both should be suspected as containing asbestos. But the key difference is that the rst ceiling is damaged and friable. It should be repaired by a specialist or tested to ascertain if it is asbestos. Even if the second photograph is an asbestos ceiling it is not damaged or friable and therefore is not demonstrating poor asbestos management.
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Floors
Floors present particular problems because they are often multi-layered and any or all of these layers might contain asbestos. An A-60 oor, for example, might contain a bottom levelling layer (so that the re layer can be accurately applied); several centimetres of re proof cement; a levelling compound; an adhesive; and a re-proof tile or carpet. Even within one layer, asbestos content may vary widely. This is particularly true of cement, where several different mixes may have been used to complete the same oor. To nd out how much asbestos a oor contains, you would need to test each individual layer. But in reality, asbestos testing on ships is a process of estimating based on random testing. The more tests you complete, and the better they are structured, the better the estimate you will achieve. Asbestos rope in a re door frame. This is a very interesting photograph. Asbestos rope has been used to improve the seal between the door and its frame. Asbestos rope is always friable and in this instance the problem is exacerbated by the fact that the door bangs into the rope every time it closes. It is certainly not an example of good management and we would expect the rope to be replaced by specialists.
Non-asbestos rope in a re door frame. Compare this to the asbestos-containing rope in the image above. It is impossible to tell by looking which one contains asbestos.
Asbestos vinyl oor tiles and asbestos glue Asbestos oor tiles are very common, but even when damaged they are very unlikely to emit a dangerous level of bres since they are bound up in the vinyl matrix. The glue may contain an even higher percentage of asbestos than the tiles but it too is unlikely to be friable.
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Crocidolite (blue) asbestos putty in an unauthorised repair to a non-asbestos penetration. This is almost certainly an unapproved modication to a cable penetration (the cables are not properly installed on the cable tray and are not properly secured). It is a common sight on board ships. In this instance the original penetration is asbestosfree, but the new penetration contains crocidolite (blue) asbestos. Although this is the most dangerous type, because it is in putty and clearly not friable it can be safely managed in situ. This material is likely to have come on board the ship in the equipment box of a sub-contractor. Newbuild and repair yards therefore need to perform checks on sub-contractors activities and equipment. Good surveyors will surreptitiously peak into the tool boxes of workmen, not least because many glues and sealants contain materials which present re hazards or are toxic when burnt.
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 and engines, which makes them potentially highly friable. This example clearly illustrates why shipowners trying to risk assess their asbestos liability should use marine asbestos experts. A land-based inspector might assume that a sealant like this is undisturbed and relatively safe. An experienced and licensed marine asbestos assessor would understand the inuence of the ships movements.
Asbestos canvas. This is also used on cold water pipes to avoid condensation.
Asbestos canvas
Asbestos insulation. This type of loose ock 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 quickly cover the internal surfaces of that material with bres, leading to large releases if it is disturbed.
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It is common to nd ships which state they have no asbestos onboard and yet have cupboards which contain items clearly marked asbestos. On one ship, an LR surveyor was given a long lecture by the Chief Engineer on the dangers of asbestos, only to then nd a freshly cut gasket, clearly labelled asbestos, sitting on the cutting bench in the machinery area.
Engine room
The engine room store examples show that you are likely to nd asbestos in the engine room itself. Any asbestos there is prone to damage due to the operations taking place and the heat, humidity and vibration.
Rolls of asbestos containing cardboard gasket material. Gaskets are probably one of the biggest problems on a modern ship. Gasket material is impossible to trace over a whole ships lifecycle and therefore on older ships all gaskets should be presumed to contain asbestos. The good news is that, unless disturbed, gaskets present a very low risk. The exposed edge of a gasket may be friable but it is a very small area which is often protected by the ange or is otherwise unlikely to be disturbed. We recommend that all gaskets are managed as if they contain asbestos and not removed unless required by legislation. Sprayed blue asbestos on a steel engine room bulkhead. This is blue asbestos sprayed onto an engine room bulkhead. As with the crocidolite penetration on page 40, provided it is in good condition and managed properly it may be considered safe. However, if it has become exposed and friable, effective management can be very difcult. In these cases, properly stabilising the surface is highly recommended, Physical encapsulation is preferable to removal in cases where removal will cause unacceptable disturbance.
A typical gland packing cupboard on a ship. Without testing, it would be impossible to know whether all the materials in this cupboard were free of asbestos. And with such a large selection its presence is almost inevitable. It would also be impossible for anyone to know where these materials have been used through the life of the ship.
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Asbestos lagging
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