Section 2 Hazards listed in Table A (HKC) / Annex II (EU SRR)
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Clasifications Register Guidance Information - Guidance Note for the Inventory of Hazardous Materials, July 2019 - Chapter 4 Hazards to be recorded in the IHM - Section 2 Hazards listed in Table A (HKC) / Annex II (EU SRR)

Section 2 Hazards listed in Table A (HKC) / Annex II (EU SRR)

2.1 Overview

2.1.1 According to Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials:

‘For existing ships it is not obligatory for materials listed in Table B to be listed in Part I of the Inventory. However, if they can be identified in a practical way, they should be listed in the Inventory, because the information will be used to support ship recycling processes.’

2.1.2 An ‘indicative list’ for Table B hazards, which can be found in Appendix 5 - Example of the Development Process for Part I of the Inventory for Existing Ships of the IMO Guidelines (Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials), is summarised in Table 4.2.1 ‘Indicative list’ of Table B (HKC) hazards.

Table 4.2.1 ‘Indicative list’ of Table B (HKC) hazards

Materials Component of equipment
Cadmium and cadmium compounds Plating film, bearing
Hexavalent Chromium compounds Plating film
Mercury and mercury compounds Fluorescent light, mercury lamp, mercury cell, liquid-level switch, gyro compass, thermometer, measuring tool, manganese cell, pressure sensors, light fittings, electrical switches, fire detectors
Lead and lead compounds Corrosion resistant primer, solder (almost all electric appliances contain solder), paints, preservative coatings, cable insulation, lead ballast, generators
Polybrominated biphenyls (PBBs) Non-flammable plastics
Polybrominated diphenyl ethers (PBDEs) Non-flammable plastics
Polychlorinated naphthalenes Paint, lubricating oil
Radioactive substances Appendix 10 of MEPC.269(68)
Examples of consumer products with radioactive materials
Ionisation chamber smoke detectors (typical radionuclides 241Am; 226Ra)
Instruments/signs containing gaseous tritium light sources (3H)
Instruments/signs containing radioactive painting (typical radionuclide 226Ra)
High intensity discharge lamps (typical radionuclides 85Kr; 232Th)
Radioactive lighting rods (typical radionuclides 241Am; 226Ra)
Examples of industrial gauges with radioactive materials
Radioactive level gauges
Radioactive dredger gauges*
Radioactive conveyor gauges*
Radioactive spinning pipe gauges*
Certain short-chain chlorinated paraffins Non-flammable plastics
* Typical radionuclides: 241Am; 241Am/Be; 252Cf; 244Cm; 60Co; 137Cs; 153Gd; 192Ir; 147Pm; 238Pu; 239Pu/Be; 226Ra; 75S; 90Sr (90Y); 170Tm; 169Yb

2.2 Cadmium and cadmium-containing compounds

2.2.1 Cadmium has historically had many uses. Cadmium is used on board ships as an alloy in bearings and other components. Another main use is as a dye for textiles and plastics. It is used to produce yellow or orange and so it may be present in any yellow or orange materials or plastics.

2.3 Hexavalent chromium and chromium-containing compounds

2.3.1 Hexavalent chromium is used in passivating layers, not only as an electroplated layer, but also, in high percentages, in passivating paints.

2.4 Mercury and mercury compounds

2.4.1 Elemental mercury is common in instruments for measuring temperature and pressure, and also in switches and fluorescent lights. Mercury can fatally damage the brain and the kidneys. Low levels of exposure in prospective mothers can severely damage babies and children. Inhaled mercury is very toxic and mercury will evaporate slowly; a broken thermometer can contaminate a room to toxic levels.

2.4.2 Mercury is found in switches, ballast gauge systems, thermometers and fluorescent lights.

2.4.3 Fluorescent lights generally contain small amounts of mercury; pre-1988 tubes may contain about 45 mg per tube. It is therefore recommended that all tubes are declared as containing mercury, unless other information is readily available.

2.5 Lead and lead-containing compounds

2.5.1 Lead is a very common additive; solder is a well-known use.

2.6 Polybrominated biphenyls

2.6.1 Polybrominated biphenyls (PBBs) are similar to PCBs. They are used as flame retardants, especially in textiles and plastics.

2.7 Polybrominated diphenyl ethers

2.7.1 Polybrominated diphenyl ethers (PBDEs) are used as flame retardants.

2.8 Polychlorinated naphthalenes

2.8.1 Polychlorinated naphthalenes (PCNs) have been used in many electrical devices, but also for the impregnation of woods and textiles to make them waterproof, flame-resistant and protect against moulds.

2.9 Radioactive substances

2.9.1 These items are relatively well understood and several recycling ports are known to require radiation surveys before arrival. The likelihood of genuine risk is thought to be exceptionally low.

2.9.2 The most common use of radioactive materials is in ionising smoke detectors. These generally use americium-241. All detector heads must be on the approved Fire Control/Safety Plan, and this can easily be checked and included in the IHM.

2.9.3 Radioactive elements may also be used in tank sounding and ullage devices, radars and radioluminescent (emergency) signs.

2.9.4 Other items that might need consideration include carriage of radioactive materials and cargo, such as drilling mud or spent nuclear fuel. Naturally occurring radioactive materials (radionuclides) may be present in drilling mud or firebricks. Once again, the services of a recognised expert would be recommended, especially if a heightened risk is associated with an offshore supply ship or a nuclear fuel carrier, for example.

2.10 Certain short-chained chlorinated paraffins

2.10.1 According to the US EPA the largest use of short-chained chlorinated paraffins is as a component of lubricants and coolants in metal cutting and metal forming operations. The second-largest use is as both a secondary plasticiser and a flame retardant in plastics, especially PVC. Other minor domestic uses are as a plasticiser and a flame-retardant additive to a variety of products including: rubber formulations, paints and other coatings, and adhesives and sealants.

2.11 Brominated flame retardant (EU SRR only)

2.11.1 Brominated flame retardant (HBCDD) is used as flame retardant additive, providing fire protection during the service life of vehicles, buildings or articles, as well as protection while stored. The main uses of HBCDD globally are in expanded (EPS) and extruded (XPS) polystyrene foam insulation while the use in textile applications and electric and electronic appliances is smaller.

2.11.2 An indicative list of materials/items which may contain HBCDD is summarised in Table 4.2.2 ‘Indicative list’ of components which may contain HBCDD which is adapted from EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials. The information in this Table is synthesised from both the EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials and EMSA Study of two hazardous substances (PFOS and HBCDD).

Table 4.2.2 ‘Indicative list’ of components which may contain HBCDD

Item Occurrence Relevance to IHM Other information
XPS and EPS foam
  • Flooring
  • Cold storage
  • Transportations
  • Tank insulation (LPG, LEG and LNG tank)
  • other foam insulation
Used in building and construction industry to meet fire safety standards, for insulation, moisture barrier, protect against damage from freezing, provide stable fill material and create high strength composite materials. Yes – but depends on the item for specific Part of IHM Profiles of HBCDD in European markets (year 2006/2007) indicate that 96% of HBCDD is related to EPS and XPS, meaning only a small fraction in HIPS and textiles. Typically content of 0.7% by weight in XPS and 0.5–2% in general.
Can be found on board all vessels and rig types and should be considered for insulation used in the walls and ceiling of cold provision rooms. In addition to the above, it is recommended that special attention is paid to insulation on board reefers, insulation in refrigerated containers and insulation of LPG, LEG and LNG tanks.
  • Flooring insulation – e.g. vinyl floorings in accommodation areas.
  • Cold storage – e.g. foam insulation of cold provision rooms, etc.
  • Transportation – e.g. shipping containers, electrical parts
  • Tank insulation – to achieve thermal efficiency, improved insulation lifetime and low need for maintenance.
Textile back coatings Used as flame retardant in textiles, carpets, rugs, furniture and fabrics. Part III Concentration 2.2–4.3% in the textiles
Can be found on board all vessels and rig types and relevant items are carpets, furniture and vinyl flooring in accommodation areas, offices and passageways especially.
High impact polystyrene (HIPS) Can be found on board all vessels and units and relevant for resistant plastic used computer housings and instrument panels especially. Relevant areas are bridge, offices and control rooms. Part III  

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