Example of the development process for part 1 of the inventory for existing ships
1 Introduction
In order to develop Part I of the Inventory of Hazardous Materials for existing ships, documents of the individual ship as well as the knowledge and experience of specialist personnel (experts) is required. An example of the development process for Part I of the Inventory of Hazardous Materials for existing ships is useful to understand the basic steps as laid out in the Guidelines and to ensure a unified application. However, attention should be paid to variations in different
types of ships1.
Compilation of Part I of the Inventory of Hazardous Material for existing ships involves the following 6 steps which are described in paragraph 4.2 and appendix 4 of these Guidelines.
Step 1: Collection of necessary information;
Step 2: Assessment of collected information;
Step 3: Preparation of visual/sampling check plan;
Step 4: Onboard visual/sampling check; and
Step 5: Preparation of Part I of the Inventory and related documentation.
1) The example of a 28,000 gross tonnage bulk carrier constructed in 1985 is used in this appendix.
2 Step 1: Collection of necessary information
2.1 Sighting of available documents
A practical first step is to collect detailed documents for the ship. The shipowner should try to collate documents normally retained onboard the ship or by the shipping company as well as relevant documents that the shipyard, manufacturers, or classification society may have. The following documents should be used when available:
Ship’s specification
General Arrangement
Machinery Arrangement
Spare Parts and Tools List
Piping Arrangement
Accommodation Plan
Fire Control Plan
Fire Protection Plan
Insulation Plan (Hull and Machinery)
International Anti-Fouling System Certificate
Related manuals and drawings
Information from other inventories and/or sister or similar ships, machinery, equipment, materials and coatings
Results of previous visual/sampling checks and other analysis
If the ship has undergone conversions or major repair work, it is necessary to identify as far as possible the modifications from the initial design and specification of the ship
2.2 Indicative list
It is impossible to check all equipment, systems, and/or areas on board the ship to determine the presence or absence of Hazardous Materials. The total number of parts on board may exceed several thousand. In order to take a practical approach, an “Indicative list” should be prepared that identifies the equipment, system, and/or area on board that is presumed to contain Hazardous Materials. Field interviews with the shipyard and suppliers may be necessary to prepare such lists. A typical example of an “Indicative list” is shown below:
2.2.1 Materials to be checked and documented
Hazardous Materials, as identified in appendix 1 of these Guidelines, should be listed in Part I of the Inventory for existing ships. Appendix 1 of the Guidelines contains all the materials concerned. Table A shows those which are required to be listed and Table B shows those which should be listed as far as practical.
2.2.2 Materials listed in Table A
Table A lists the following four materials:
Asbestos
Polychlorinated biphenyls (PCBs)
Ozone depleting substances
Anti-fouling systems containing organotin compounds as a biocide
2.2.2.1 Asbestos
Field interviews were conducted with over 200 Japanese shipyards and suppliers regarding the use of asbestos in production. “Indicative lists” for asbestos developed on the basis of this research are shown below:
2.2.2.2 Polychlorinated biphenyl (PCBs)
Worldwide restriction of PCBs began on 17 May 2004 as a result of the implementation of the Stockholm Convention, which aims to eliminate or restrict the production and use of persistent organic pollutants. In Japan, domestic control began in 1973, with the prohibition of all activities relating to the production, use and import of PCBs. Japanese suppliers can provide accurate information concerning their products. The “Indicative list” of PCBs has been developed as shown below:
2.2.2.3 Ozone depleting substances
The “Indicative list” for Ozone depleting substances is shown below. Ozone depleting substances have been controlled according to the Montreal Protocol and MARPOL Convention. Although almost all substances have been banned since 1996, HCFC can still be used until 2020.
2.2.2.4 Organotin compounds
Organotin compounds include Tributyl tins (TBT), Triphenyl tins (TPT) and Tributyl tin oxide (TBTO). Organotin compounds have been used as anti-fouling paint on ships’ bottoms and the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention) stipulates that all ships shall not apply or re-apply organotin compounds after 1 January 2003, and that, after 1 January 2008, all ships shall either not bear such compounds on their hulls or shall bear a coating that forms a barrier preventing such compounds from leaching into the sea. The above-mentioned dates may have been extended by permission of the Administration bearing in mind that the AFS Convention entered into force on 17 September 2008.
2.2.3 Materials listed in Table B
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. The Indicative list of materials listed in Table B is shown below:
3 Step 2: Assessment of collected information
Preparation of a checklist is an efficient method for developing the Inventory for existing ships in order to clarify the results of each step. Based on collected information including the “Indicative list” mentioned in Step 1, all equipment, systems, and/or areas onboard assumed to contain Hazardous Materials listed in Tables A and B should be included in the checklist. Each listed equipment, system, and/or area on board should be analysed and assessed for its Hazardous
Materials content.
The existence and volume of Hazardous Materials may be judged and calculated from the Spare parts and tools list and the Maker’s drawings. The existence of asbestos contained in floors, ceilings and walls may be identified from Fire Protection Plans, while the existence of TBT in coatings can be identified from the International Anti-Fouling System Certificate, Coating scheme and the History of Paint.
When a component or coating is determined to contain Hazardous Materials, a “Y” should be entered in the column for “Result of document analysis” in the checklist, to denote “Contained”. Likewise, when an item is determined not to contain Hazardous Materials, the entry “N” should be made in the column to denote “Not contained”. When a determination cannot be made as to the Hazardous Materials content, the column should be completed with the entry “Unknown”.
Checklist (Step 2)
4 Step 3: Preparation of visual/sampling check plan
Each item classified as “Contained” or “Not contained” in Step 2 should be subjected to a visual check on board, and the entry “V” should be made in the “Check procedure” column to denote “Visual check”.
For each item categorized as “unknown”, a decision should be made as to whether to apply a sampling check. However, any item categorized as “unknown” may be classed as “potentially containing Hazardous Material” provided comprehensive justification is given, or if it can be assumed that there will be little or no effect on disassembly as a unit and later ship recycling and disposal operations. For example, in the following checklist, in order to carry out a sampling
check for “Packing with aux. boiler” the shipowner needs to disassemble the auxiliary boiler in a repair yard. The costs of this check are significantly higher than the later disposal costs at a Ship Recycling Facility. In this case, therefore, the classification as “potentially containing Hazardous Material” is justifiable.
Checklist (Step 3)
Before any visual/sampling check on board is conducted, a “visual/sampling check plan” should be prepared. An example of such a plan is shown below.
To prevent any incidents during the visual/sampling check, a schedule should be established to eliminate interference with other ongoing work on board. To prevent potential exposure to Hazardous Materials during the visual/sampling check, safety precautions should be in place on board. For example, sampling of potential asbestos containing materials could release fibres into the atmosphere. Therefore, appropriate personnel safety and containment procedures should be implemented prior to sampling.
Items listed in the visual/sampling check should be arranged in sequence so that the onboard check is conducted in a structured manner (e.g., from a lower level to an upper level and from a fore part to an aft part).
This plan is established in accordance with the Guidelines for the development of the Inventory of Hazardous Materials
5 Step 4: Onboard visual/sampling check
The visual/sampling check should be conducted according to the plan. Check points should be marked in the ship’s plan or recorded with photographs.
A person taking samples should be protected by the appropriate safety equipment relevant to the suspected type of hazardous materials encountered. Appropriate safety precautions should also be in place for passengers, crewmembers and other persons on board, to minimize the potential exposure to hazardous materials. Safety precautions could include the posting of signs or other verbal or written notification for personnel to avoid such areas during sampling. The personnel taking samples should ensure compliance with relevant national regulations.
The results of visual/sampling checks should be recorded in the checklist. Any equipment, systems and/or areas of the ship that cannot be accessed for checks should be classified as “potentially containing Hazardous Material”. In this case, the entry in the “Result of check” column should be “PCHM”.
6 Step 5: Preparation of Part I of the Inventory and related documentation
6.1 Development of Part I of the Inventory
The results of the check and the estimated quantity of Hazardous Materials should be recorded on the checklist. Part I of the Inventory should be developed with reference to the checklist.
6.2 Development of location diagram of Hazardous Materials
With respect to Part I of the Inventory, the development of a location diagram of Hazardous Materials is recommended in order to help the Ship Recycling Facility gain a visual understanding of the Inventory.
Example of the Inventory for existing ships
Inventory of Hazardous Materials for “Sample Ship”
Particulars of the “Sample Ship”
Distinctive number or letters |
XXXXNNN |
Port of registry |
Port of World |
Type of vessel |
Bulk carrier |
Gross Tonnage |
28,000 GT |
IMO number Name of shipbuilder |
NNNNNNN xx Shipbuilding Co. Ltd |
Name of shipowner |
yy Maritime SA |
Date of delivery |
MM/DD/1988 |
This inventory was developed in accordance with the Guidelines for the development of the Inventory of Hazardous Materials.
Attachment:
1: Inventory of Hazardous Materials
2: Assessment of collected information
3: Location diagram of Hazardous Materials
Inventory of Hazardous Materials : “Sample Ship”
Part I HAZARDOUS MATERIALS CONTAINED IN THE SHIP’S STRUCTURE AND EQUIPMENT
*1 Each item should be entered in order based on its location, from a lower level to an upper level and from a fore part to an aft part.
Example of location diagram of Hazardous Materials
1
The example of a 28,000 gross tonnage bulk carrier constructed in 1985 is used in this appendix.