Section 1 Hazards listed in Table A (HKC) / Annex I (EU SRR)

1.1.1 In many countries the use of asbestos was not regulated for many years, so there was no requirement to state whether or not it was used. It was also cheap. Furthermore, asbestos not only tends to increase the fire-fighting capabilities of compound materials, but in many cases it assists bonding of compounds and improves strength characteristics. Therefore, it can be expected in any place where its attributes are important, and where its addition may not have been controlled.

1.1.2 Since 1 July 2002, the installation of materials that contain asbestos was prohibited (with the exception of certain vanes, joints and insulation) under Chapter II-1 - Construction - Structure, subdivision and stability, machinery and electrical installations, for all ships.

1.1.3 Resolution MSC.282(86) – Adoption of Amendments to the International Convention for the Safety of Life at Sea, 1974, as Amended – (adopted on 5 June 2009) introduced amendments to Regulation 3-5 - New installation of materials containing asbestos, prohibiting the new installation of materials containing asbestos, for all ships without exceptions, from 1 January 2011.

1.1.5 Although SOLAS now prohibits the new installation of materials containing asbestos, for all ships without exception, many countries have different asbestos legislation which means it is impossible to make generalisations.

1.1.6 Prior to January 2011, SOLAS did not prohibit all types of asbestos. Furthermore, there has never been one rigorously enforced law, governing all countries in the world, banning all types of asbestos. Therefore, unless there is reputable, traceable information that proves an item under consideration is free from asbestos, it should be treated as if it is asbestos. This is a safe basis from which to start.

1.1.7 Table 4.1.1 ‘Indicative list’ of components which may contain asbestos, shows an ‘indicative list’ of components which may contain asbestos, taken from Appendix 5 - Example of the Development Process for Part I of the Inventory for Existing Ships of the Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials.

1.1.8 If a ship has no asbestos-free certificate from build and/or no procurement policy in place to restrict asbestos from being brought on board since delivery, undertaking sampling is strongly recommended.

1.1.9 In the event that sampling is not possible due to ‘comprehensively justifiable reasons’, any unknown material likely to contain asbestos should be treated as ‘presumed asbestos containing materials’ and the IHM should reflect this. Furthermore, unless specific information is provided to the contrary, the ship should be presumed to contain asbestos.

Note, such ‘comprehensive justification’ is equally applicable to sampling for any other hazardous materials listed in the HKC or EU SRR.

1.2.1 Ozone-depleting substances (ODS) are gases, such as CFCs and halons. ODS have been controlled according to the Montreal Protocol and MARPOL - International Convention for the Prevention of Pollution from Ships.

1.2.2 The Montreal Protocol on Substances that Deplete the Ozone Layer was a convention signed by many countries in 1987. It set out to greatly reduce the production of materials such as CFCs and halons and has been amended several times since, generally to make the phase-out of materials quicker.

1.2.3 Although almost all substances have been banned since 1996, HCFCs can still be used until 2020 under the provision of the HKC. However the requirements of the EU SRR differ (see Ch 3, 1.1 IHM Part I hazards and their thresholds for details).

1.2.4 CFC gases were very common refrigerants on ships and halon was a popular fixed fire-fighting medium. These gases were also used extensively as blowing agents to produce plastics and plastic foams. Polyurethane, for example, was made using CFC gas, and most cold store insulation and refridgerator lining was made using CFC gases to produce the insulating foam.

1.2.5 An ‘indicative list’ for ODS can be found in Appendix 5 of the IMO guidelines (Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials), see Table 4.1.2 ‘Indicative list’ of components which may contain ODS.

1.3.1 Polychlorinated biphenyls (PCBs) are a family of chemicals that are good electrical insulators, chemically stable, fireresistant and do not easily give off a vapour. They were therefore seen as excellent components in any electrical system reliant on the above properties. PCBs are toxic, persistent and bioaccumulative. They are virtually insoluble in water, but highly soluble in fat (hence their bioaccumulative properties). Under certain combustion conditions they may form highly toxic dioxins.

1.3.2 PCBs are hard to quantify. They were generally globally phased out by legislation between the mid-1970s and the mid- 1980s. However, phase-out dates varied round the world and were also dependent on whether they were used in solid or liquid form.

1.3.4 In older vessels, these hazards are likely to exist in transformers, fluorescent lighting ballasts, paints, wire insulation and electric motor start up capacitors. An ‘indicative list’ for PCBs can be found in Appendix 5 of the IMO Guidelines MEPC.269(68), see Table 4.1.3 ‘Indicative list’ of components which may contain PCBs.

1.4.1 TBT is an organic compound containing tin. It was first used in the 1960s as an anti-fouling agent and was highly effective. However, it is an endocrine disrupting chemical which interferes with hormones, and adverse impacts became evident in shellfish from the 1970s. This led to the development and adoption of the International Convention on the Control of Harmful Anti-fouling Systems on Ships in October 2001 (AFS - International Convention on the Control of Harmful Anti-Fouling Systems on Ships, 2001), which will ultimately lead to the phase-out of TBT-based anti-fouling paints.

1.4.2 TBT paints are only expected to be found on the external underwater parts of the ship, unless there is a known reason why they are applied elsewhere. Most ships now comply with the AFS Convention. As such the AFS certificate should detail whether the ship uses, or has sealed, TBT anti-fouling.

1.5.1 Perfluorooctane sulfonic acid (PFOS) is chronically toxic, injurious to reproduction, carcinogenic, toxic to aquatic organisms and widely distributed in the global environment. In the marine industry, it can be found in fire-fighting foams on vessels carrying inflammable fluids and those with helicopter decks, rubber and plastic materials (i.e. cable sheaths, PVC flooring, gaskets and seals) and coatings (i.e. paint).

1.5.2 The main application on board ships is considered to be fire-fighting foams of the type AFFF (aqueous film forming foams). PFOS-containing AFFF could be applied on board a range of ship types, but the larger volumes are usually installed on vessels carrying inflammable fluids, and on vessels with helicopter decks. Volumes normally range from some 100 litres to 10 000 litres, depending on the type and size of the vessel. The foam is typically stored in one tank serving a main system, potentially with additional smaller and separate devices (e.g. 20 litres), usually in the machinery room(s).

1.5.3 An indicative list of materials/items which may contain PFOS is summarised in Table 4.1.4 ‘Indicative list’ of components which may contain PFOS, which is adapted from EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials and EMSA Study of two hazardous substances (PFOS and HBCDD).