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229-77031 AsbestosGuide2013 tcm155-247011 PDF
229-77031 AsbestosGuide2013 tcm155-247011 PDF
Contents
Foreword 3
1
Asbestos on ships how to manage it safely
2
Asbestos on ships how to manage it safely
Foreword
This publication should help shipowners and operators understand how to deal with asbestos on board their ships
and fleets 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
1
World Health Organization (2010). Elimination of asbestos-related diseases (Fact sheet N343).
Available at: http://www.who.int/mediacentre/factsheets/fs343/en/index.html
2
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)
3
Asbestos on ships how to manage it safely
1. What is asbestos?
Part 1 A history of asbestos
Asbestos is a generic name given to the fibrous variety The big three: blue, brown and white
of six naturally occurring silicate minerals3. Silicate The most commonly recognised types of asbestos
minerals make up a large proportion of the rocks on are blue, brown and white, and these are properly
the planet. All asbestos rocks occur in, or separate very called crocidolite, amosite and chrysotile asbestos.
easily into, very small fibres or fibrils with a diameter of Crocidolite and amosite are amphiboles and
only a few nanometres. chrysotile is the only serpentine. Their common
names relate to their natural colour and have nothing
The two groups to do with how they appear in products: it is in
Asbestos is generally categorised in two groups: fact impossible to tell the type of asbestos from
amphibole and serpentine. There are five amphibole the colour of a product.
asbestoses and one serpentine. Amphibole asbestos is
considered more dangerous than serpentine.
A: Low
Actinolite 77536-66-4 B: Low
C: 0
Amphibole
A: Low
(five types) Anthophyllite 77536-67-5 B: Low
Short, sharp fibres C: 0
A: Medium A: 500
Crocidolite (blue) 12001-28-4 B: Low B: 10-50
C: 0
A: Low
Tremolite 77536-68-6 B: Low
C: 0
Amphibole
A: high A: 1
(serpentine
Chrysotile 12001-29-5 B: high
one type) B: 1
C: 100
Long, curly fibres
3
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/
4
Asbestos on ships how to manage it safely
4
L. Prandi, M. Tomatis, N. Penazzi and B. Fubini (2002). Iron Cycling Mechanisms and Related modifications 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
5
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.
5
Asbestos on ships how to manage it safely
One of the reasons cited for this risk is that chrysotile asbestos Tremolite
is often contaminated with the more harmful amphibole types Tremolite has similar characteristics to actinolite and
of asbestos. A number of studies have found the lungs of its use has been equally rare. It is also a common
victims who were expected to have been exposed to chrysotile contaminant of chrysotile asbestos. Significantly,
asbestos to contain a large proportion of amphiboles such the amount of tremolite found in the lungs of people
as tremolite. who have died from exposure to it far outweighs
the amount they were apparently exposed to.
In China, ten samples from six mines were tested and all were
found to be contaminated with tremolite although at very Anthophyllite
low quantities.8 Another study which tested the lung tissues Anthophyllite shares the characteristics of tremolite
of seven dead workers who had worked in a pure chrysotile and actinolite. It is common to see it mentioned in
asbestos mine showed the fibres in the lungs were 71% paint contents as non asbestos anthophyllite. This
anthophyllite, 9% tremolite and just 10% chrysotile asbestos. refers to one of the major characteristics of asbestos,
And yet another study of chrysotile asbestos workers showed which causes understandable confusion the existence
34 of 35 fibres were amphiboles. of non-hazardous types in which the fibres do not
have the same crystalline characteristics as those in
These latter two studies showed that chrysotile asbestos had the true asbestos forms.
naturally left the workers bodies but that the amphibole
contaminants had persisted. These findings are reinforced by Other substances
another study which found that chrysotile asbestos fibres tend This section leaves us with two questions which are
to clear from the lungs, with a half life of less than 10 years, beyond the scope of this publication. Firstly, are there
whereas amphiboles do not seem to clear.9 other asbestos-like minerals that are not presently
considered dangerous which might be added to the
Chrysotile asbestos accounted for over 95% of all asbestos list in the future? The brief answer is yes, one example
produced and consumed between 1900 and 200310. 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.
6
D. Loomis et al (2009). Lung cancer mortality and fibre exposures among North Carolina asbestos textile workers.
Occupational & Environmental Medicine, Volume 66, Issue 8. Available at http://oem.bmj.com/content/66/8/535
7
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
8
Antti Tossavainen et al (2001). Amphibole fibres 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/
6
Asbestos on ships how to manage it safely
Asbestos has been used for thousands of years thanks Early reported uses
to its extraordinary properties. Today, it is easy to In AD 800, Emperor Charlemagne was reported
forget how asbestos revolutionised our modern lives. as having a tablecloth that never needed cleaning.
It protects against fire and heat, adds strength to When it became dirty, he simply threw it into the fire,
materials and insulates against electricity. It is pliable, and it came out clean and unburnt. The Greeks and
forgiving, cheap and easy to use. No modern substance Romans may have done the same thing, as reported
can provide all these engineering benefits and it is still by the famous historian Strabo in his Geography
without equal. and Pliny the Elder in his Natural History.
Indeed, it seems to have been a global habit since
A brief history of asbestos production Marco Polo reported a cloth that thrown into the
fire, remains incombustible.
Pre-history
Evidence of asbestos mining has been found in First large commercial mines
Cyprus from as long ago as 3,000 B.C. Analysis Asbestos is known to have been commercially
of archaeological finds in Finland from a slightly mined in Russia in 1720. Enormous deposits of
later date shows that asbestos fibres were used to chrysotile asbestos were found in 1844 near Asbest
reinforce earthenware pots, and there is evidence that city. Even today the entire area looks like a vast
this practice spread within Scandinavia and Russia. open cast mine.
Tremolite and chrysotile asbestos were mined by the
Romans in the Italian Alps. 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).
7
Asbestos on ships how to manage it safely
Mass production and usage The Vancouver Sun, in its edition of 24 November,
By 1920, the world was using nearly 200,000 tonnes 2011 reported: Earlier this year, the Canadian
of asbestos, of which 150,000 tonnes were consumed Government had blocked the listing of chrysotile
by the US, 40,000 by Europe, 7,000 tonnes by Asia asbestos in Annex III of the Rotterdam Convention.
and the Middle East, and 2,000 tonnes by Africa11. This would have meant that exports and imports
would have to have been declared and thus
By 1930 this had almost doubled to 388,000 tonnes. countries could refuse to accept chrysotile asbestos.
By 1940 the figure was 522,000 tonnes. The second
world war and subsequent re-construction led to a The report of the meeting published on the
boom in the use of asbestos. The US alone used over Rotterdam Convention website14 does not record
half a million tonnes of asbestos every year from 1947 an intervention from Canada, although Canada
to 1979. Interestingly, it only started using the most is conspicuous by its absence from the list of
dangerous types (crocidolite and Amosite) in 195611. signatories to a declaration against chrysotile
asbestos made at the conference in June 2011.
By 1960, global asbestos consumption was well
over 2 million tonnes. In 1970, consumption was at In September 2012, Canadian newspapers were
3.5 million tonnes and still rising. In 1975, it was reporting anti-asbestos sentiment in Canada
4.3 million tonnes and in 1980 consumption was at but also that the asbestos mines were hoping
4.7 million tonnes. to re-open in spring 2013.
The decline
The decline in asbestos use only began in 1985 when
Country 2010 2011 2012e
production fell to 4.3 million tonnes. The decline was
slow. In 1990 production was still 4 million tonnes, Brazil 270,000 302,000 300,000
despite major bans already being in force around the
Canada 100,000 50,000
world. Finally, in 1995 significant reduction started to
take place. Consumption had almost halved from the China 400,000 440,000 440,000
peak to 2.5 million tonnes, although even by the year Kazakhstan 214,000 223,000 240,000
2000 consumption was still comparable with 1960 at Russia 1,000,000 1,000,000 1,000,000
2 million tonnes. Others 21,000 19,000 20,000
Today, world production remains relatively steady at Total 2,010,000 2,030,000 2,000,000
2.03 million tonnes12.
Table 2: Recent global production of asbestos15
e = estimated
11
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/
12
R.L.. Virta (2011). USGS 2011 Minerals Yearbook Asbestos.
Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/myb1-2011-asbes.pdf
13
CBC (2011). Asbestos mining stops for first time in 130 years.
Available at http://www.cbc.ca/news/canada/story/2011/11/24/asbestos-shutdown.html (Accessed 13 March, 2012)
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
8
The
Asbestos onBlack
ships Lake asbestos
how to manage it safely
mines in Quebec, Canada
9
Asbestos on ships how to manage it safely
A health problem for the Greeks In 1930, Merewether and Price, two medical
and Romans? inspectors from the Factory Department17 delivered
There is conjecture over whether the Greeks and research on the asbestos textile industry in Britain
Romans recognised the health problems associated it identified that 25% of the 363 workers examined
with asbestos. Some people assert that Pliny the Elder, had pulmonary fibrosis. It was in the 1930s that
the Roman author and naturalist, described protection workers with asbestosis first started suing their
against asbestos, but others claim he was referring to employers.
different problems. His Natural History makes no
direct mention of asbestos. The beginning of regulation
These reports and research led to the 1931 Asbestos
The first recognised cases of Industry Regulations. While this legislation only
asbestos-related disease reduced the dust levels in factories, at the time it was
The first report of asbestos-related disease in England believed to have solved the problem of asbestosis.
was in 1906 when Dr. Montague Murray reported an
asbestosis fatality to the Parliamentary Departmental Asbestos, cigarettes and the link to
Committee on Compensation for Industrial Diseases. It lung cancer
wasnt until the mid 1920s that more reports started to So far, no direct link had been established between
appear and asbestosis became recognised as a medical asbestos and lung cancer (although a connection
term. Asbestosis became the first fatal disease to be between asbestosis and lung cancer had been made).
definitively linked to asbestos exposure (see The case Key to understanding this is the enormous increase
of Nellie Kershaw). in cigarette smoking after the First World War. The
negative health effects of this trend were starting to
appear at the same time as the effects of asbestos
exposure. To the medical profession, they appeared
The case of Nellie Kershaw16 to be the same problem.
Nellie worked with asbestos for nearly 20 years. She died aged
33 in 1924. She suffered from a series of health problems that The link between lung cancer and smoking was
culminated in her being rendered permanently unfit for work eventually established in the 1950s, and it was
in 1922. The primary cause of her death was established as only in 1955 that countries started recognising
pulmonary fibrosis of the lungs due to inhalation of mineral unexpectedly high instances of lung cancer among
particles. Her GP, Walter Joss had characterised her illness as asbestos workers.
asbestos poisoning. Nellie was unable to get health insurance
during her life because the condition was not recognised. Mesothelioma and a problem that could
no longer be ignored
However, Nellies case led to an inquest which ensured that a In the 1960s an alarming rise in the previously
pathological examination was carried out, by Dr. William Cooke. extremely rare disease mesothelioma was attributed
He subsequently published an article in the British Medical to asbestos. The rarity of the disease made its link
Journal which attributed her death to asbestos. Three years to asbestos exposure all the more dramatic, and it
later, in 1927, he definitively attributed her death to asbestosis. became increasingly impossible to ignore asbestos
This was the first time the term had been used in this way risks. This led the UK to revise its asbestos regulations
in a medical publication. Nellie may be considered the first over a five year period resulting in new regulations in
recognised victim of asbestosis and the starting point for all 1969 which effectively banned crocidolite asbestos.
the investigation and research that followed.
The response of industry
It would be hard for major industry players to deny that
from the late 1950s to the late 70s there was systematic
In March 1928, at the inquest of Walter Leadbetter self protection and a lack of assistance to injured parties,
of Aviary Mount in Armley, Dr. H. De Carle Woodcock, ranging from a reluctance to undertake investigations
a well-known lung specialist, drew attention to that were clearly needed to deliberate suppression of
the inhalation of asbestos dust as the cause of the evidence. Such behaviour undoubtedly delayed action
deceaseds fibrosis of the lungs. and exacerbated an already dire situation.
16
S ource: Peter W.J. Bartrip (2001). The Way from Dusty Death: Turner and Newall and the Regulation of the British Asbestos Industry,
1890s-1970. Athlone.
17
Factory inspectors were first appointed under the Factory Act of 1833. A central office, later named the Factory Department, was
established and supervised by the Domestic Department, and later the Industrial Department, of the Home Office. Taken from the National
Archives at http://discovery.nationalarchives.gov.uk/SearchUI/details?Uri=C10130 (Accessed 13 March, 2013)
10
Asbestos on ships how to manage it safely
18
IBAS (2012). Current Asbestos Bans and Restrictions. Available at http://www.ibasecretariat.org/alpha_ban_list.php (Accessed 13 March, 2013)
19
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
20
The general term for membranes that protect organs in the body cavity (see also Mesothelioma on page 12)
11
Asbestos on ships how to manage it safely
Mesothelioma tends to appear as a series of tumours. Lung cancer can be treated by chemotherapy,
The only possible cure is to completely remove them. radiotherapy, surgery or all three. The level of surgery
However, because mesothelioma is normally diagnosed varies depending on the spread of the cancer. It is
only after significant spreading of the disease, surgery more usual to remove one lobe of a lung than the
is unlikely to do more than provide short term relief entire lung.
from certain symptoms. Most treatment for the disease
is therefore palliative. Survival rates for lung cancer are better than for
mesothelioma: approximately 20% of people
diagnosed with the disease may survive five years.
21
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)
12
Asbestos on ships how to manage it safely
One fibre can kill evaluating the real risk Of course, none of this means that people never
The words one fibre can kill have appeared die from small exposures to asbestos. The case of
numerous times in relation to asbestos but they are Shirley Gibson (see page 12) illustrates this point.
highly misleading. While it is true that any exposure to And there are well documented cases of the wives
asbestos carries risk, loading is highly significant, just of asbestos workers who died from asbestos-related
as it is with smoking: in short, the more asbestos you diseases, whose principle exposure was only from
are exposed to, the more risk you have. washing their husbands overalls. In the same way,
people who smoke heavily all their life may never
A typical acceptable airborne concentration of asbestos get lung cancer while other people who have never
specified by health and safety regulation is smoked may be killed by relatively minor exposure
0.1 fibres per cubic centimetre (cm3) of air averaged to passive smoking.
over a four hour period. Simply put, if every breath
you take fills your lungs with two litres (20,000cm3) of Table 3 summaries the results from various studies
air, it is acceptable for each breath to contain 2,000 of people who worked in crocidolite asbestos mines
particles. The typical number of fibres found in the or in manufacturing using crocidolite asbestos. When
mixing area of a typical asbestos textile factory in the interpreting figures like these, it is important to note
1950s was between 2,000 and 4,000 per cm3, that many factors may have influenced the differences
20,000 to 40,000 times higher than the presently in results, including cases not being reported.
acceptable limit.22
22
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
J.M. Talent et al (1980). A survey of black mineworkers of the Cape crocidolite mines. Biological Effects of Mineral Fibre 2.
26
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/
13
Asbestos on ships how to manage it safely
The subject of testing for asbestos could fill several X-ray diffraction (XRD). In this technique the object
books by itself. There are many different testing is bombarded with X-rays. The rays are reflected by the
techniques which suit different circumstances, such asbestos particles, producing an x-ray spectrum which
as the way an asbestos sample has been extracted is characteristic of the substance. XRD is sometimes
and prepared or the substance it has been extracted used instead of PLM, or to supplement it. However,
from. All techniques have their own advantages and XRD has limitations: it cannot describe size or shape
limitations so it is often necessary to combine methods and so is only really quantitative.
in order to get the most accurate results. This section
describes the principal methods. Transmission electron microscopy (TEM). TEM uses
a very thin section of the sample (unlike SEM, which
The recognised International Standard for laboratory scans the surface). It works on the same principle as
quality is ISO 17025:2005. Many countries run an ordinary light microscope but uses electrons instead
proficiency programmes, sending random samples of light. Electrons are very much smaller than light
to laboratories to see how accurate they are. Most labs and so the resolution is correspondingly higher. It is
perform very well and easily exceed the criteria therefore a more sensitive test than PLM. However, this
for accuracy. sensitivity means that a coarse test sample can cause
problems. Further, because TEM relies on area ratio
Stereoscopic microscopy (20x). This test quantifies estimations to determine asbestos concentration, it can
the number of fibres in a sample but not the type. have limitations at low asbestos levels. This can be a
If you do not need to know what your fibres are problem if your legislation specifies a low asbestos limit
for example you are doing an air sampling filter (say, 1%) and can mean the same sample may pass at
examination and you only expect asbestos fibres one lab and fail at another.
then you can do this count to ensure you are
below the required threshold. It is very quick, simple Gravimetric analysis. This test is used to determine
and cheap. the quantity of asbestos in the sample and works by
removing all other substances. The sample is weighed
Polarized light microscopy, PLM. This is one of the and then ashed in a furnace to remove volatile organic
simplest and most reliable methods, especially for bulk compounds (VOCs). It is then weighed again to
samples, and is probably the commonest. It identifies determine the amount of VOCs that have been lost.
the type and percentage of asbestos using a phase The sample may then be acid washed to remove other
contrast microscope with polarising filters. Its limit likely compounds such as carbonates and weighed
of detection is somewhere between 0.1% and 1% again. At this point a more sensitive analytical method,
which means it may be insufficient by itself if absolute such as PLM or even TEM, is used to identify asbestos
accuracy is needed at these levels. In these cases it fibres so that the quantity of asbestos in the original
will need to be supplemented by other techniques. sample can be estimated. This test is fast and efficient
It is a very fast technique and therefore good for but is only really relevant when you know your sample
statistical analysis. contains asbestos.
14
Asbestos on ships how to manage it safely
Test type What does it do? Good for Speed Level of fibre Ease of use Investment Drawbacks
identification /cost per
sample
Stereo Magnifies the Initial Fast None. Simple to Can cost Not a test for
microscopy sample for initial examination Only gives use. less than asbestos. It only
checking and an indication $500. performs an initial
screening of likely Can be hand check, to indicate
materials carried. Cheap. how the sample
should be further
prepared and what
proper tests are
likely to be best.
Polarised Magnifies the Speed, Fast Medium. Simple to Less than Poor at levels
light sample 100 to 400 simplicity Can be very use. $10,000. of accuracy
microscopy times and uses and cost good with below 1% and
(PLM) other techniques specific types Portable. Cheap. limited for fibre
such as polarisation of asbestos Can be set up analysis
and dyes to do bound up anywhere.
basic fibre and in a simple
quantity analysis matrix
Scanning Uses electrons to Accuracy, Slow Good Complex. Huge Cost. Very slow
electron scan the sample detail and investment. for quantitive
microscopy and produces images Non-portable analysis.
(SEM) massively equipment in High.
magnified 3D a dedicated
images to find and laboratory
identify fibres
X-ray Uses X-rays to Speed of Fast Poor. Cannot Moderately Large Does not give
diffraction examine crystal quantitive identify easy to use investment. fibre morphology
(XRD) properties, but analysis between
does not produce asbestos and Medium
an image non-asbestos (depends
forms of the on set up
same material. and usage).
Gravimetric Through Quick Fast (once None. Does Moderately Low. Preparation time
analysis weighing and quantitive sample not identify easy can be very slow
reduction of estimation has been asbestos Cheap to
the sample, it prepared) and relies medium.
finds the mass on other
percentage of techniques to
asbestos do this first.
A steam plant
containing asbestos
16
Asbestos on ships how to manage it safely
1
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
17
Asbestos on ships how to manage it safely
In the worst cases, you can find asbestos virtually mooring ropes
everywhere on a ship. It can be in: firemens outfits
boiler cladding
the concrete and tiling on the floor furnace firebricks, and
the wall and ceiling panels and the fire insulation welding shop curtains and welders gloves.
behind them
the doors The list goes on.
the glues and sealants in the windows and furniture
heat insulation and lagging The International Maritime Organization (IMO) has
electrical cables published a detailed list of areas where asbestos can
brake linings and gaskets be found3 (see Table 4).
Pipes and cables. These could contain asbestos but if maintained in good condition they will be safe.
3
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 Classification Societies (IACS) in its guidance on the subject.
18
Asbestos on ships how to manage it safely
Diesel engine Packing with piping flange Lagging material for exhaust pipe
Lagging material for fuel pipe Lagging material turbocharger
Exhaust gas economizer Packing for casing door Packing with hand hole
Packing with manhole Gas shield packing for soot blower
Packing with flange 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
Auxiliary machinery (pump, Packing for casing door and valve Brake lining
compressor, oil purifier, crane) Gland packing
Heat exchanger Packing for casing door and valve Lagging material and insulation
Gland packing for valve
Valve Gland packing with valve, sheet packing with piping flange
Gasket with flange of high pressure and/or high temperature
Air-conditioning system Sheet packing, lagging material for piping and flexible joint
19
Asbestos on ships how to manage it safely
Thick insulation. All of this could be asbestos. This image demonstrates the A battery operated sniffer mounted on
potential amount of asbestos that can be present on ships. If it is properly the stairs at the exit of a compartment.
sealed and kept in good condition then the risk is acceptable. For areas of particular concern, air
monitoring can demonstrate they are safe.
4
An A-60 partition is a particular type of fire-resistant partition designed to work for 60 minutes.
20
Asbestos on ships how to manage it safely
3. Regulation
watertight joints and linings used for the The ISM Code
circulation of fluids when, at high temperature All SOLAS Convention ships must comply with the
(in excess of 350 C) or pressure (in excess International Safety Management (ISM) Code. This
of 0.7 x 106 Pa), there is a risk of fire, corrosion requires companies to identify safety risks, including
or toxicity, and asbestos risks.
New installation
SOLAS bans the new installation of asbestos.
This means that asbestos which is already in ship stores The US legal position on banning asbestos6
(in unused spare parts, for example) may remain on On 12 July, 1989, the United States Environmental
board the ship, but may not actually be installed. Protection Agency (EPA) issued a final ruling banning
This presumably avoids the expense of having to remove most asbestos-containing products. This was an
such materials from the stores. It is recommended that early move in comparison to other countries, and
owners ensure asbestos or asbestos-containing materials perhaps because of this it was overturned on appeal
within stores are properly managed and not used. in New Orleans in 1991. The ruling was clarified to
ban specific products (flooring felt, rollboard, and
For newbuilds, this wording also means that items corrugated, commercial, or specialty paper) and new
containing asbestos purchased before 1 January, 2011, uses of asbestos. This meant that products already
may not be installed. For example, a windlass purchased being made that contained asbestos could continue to
and delivered to the yard before 31 December, 2010, be manufactured.
which has asbestos brake linings would have to have the
linings removed if the yard wished to install it today. This is of vital importance to the shipping industry
as EPA does not track the manufacture processing
How the SOLAS asbestos regulations apply to existing and or distribution in commerce of asbestos-containing
new ships is explored in more detail on pages 22 to 25. products. Therefore, many items which shipyards
(or other manufacturers in the shipping supply
The role of flag states and recognised chain) buy from the US might contain asbestos
organisations in ensuring compliance but there is no legal requirement for the item
with SOLAS manufacturer to declare this. The US consumes
Flag states5 are responsible for ensuring that the about 1,100 tonnes of asbestos per year to make
provisions of the SOLAS Convention are properly asbestos-containing products.
represented in national law and for enforcing the
A flag state is the administration of the government where the ship is registered, whose flag a ship is entitled to fly.
5
6
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)
21
Asbestos on ships how to manage it safely
Focus on existing ships Despite the IMO Guidelines, it appears that within
Under the SOLAS asbestos regulations, existing the industry there is little impetus to ensure that
ships are split into two main groups. Those built existing asbestos on these ships is managed effectively.
before 1 July, 2002, are allowed to have asbestos This leads to potentially strange situations such as
on board. Those built after this date are subject to recently built ships being forced to remove small
the ban on most new installations (see page 21) and amounts of asbestos at huge cost while ships
should only have very limited amounts of asbestos containing many tonnes of blue asbestos in a badly
on board. managed condition continue sailing without any
restriction. LR believes the greatest safety benefits
Ships built after 1 July, 2002 are to be gained by making sure that any asbestos is
Ships containing asbestos in contravention of the managed properly, regardless of the ships age.
SOLAS 2002 ban are governed by the IMO Circular
MSC.1/Circ.1374 Information on Prohibiting the Use In this section, we look some of the text relating to
of Asbestos on Board Ships. asbestos management contained in IMO Circular 1045
and provide additional recommendations.
This acknowledges that asbestos is still being found
on board ships despite the regulations. And it states 2.4 Planned repairs or removal of such materials
that the principal means of addressing the problem is should be carried out by specialist personnel and
through the shipyards and suppliers. not normally by crew. In cases where the crew
is involved in urgent repair work at sea, special
Circular 1374s main recommendation is that any measures should be observed as listed in annex 1.
item supplied to the ship has an asbestos free Procedures should be developed for the safe
declaration. It also says that random confirmations retention of any waste asbestos on board the
should be carried out. ship before it can be transferred and disposed
of ashore.
Asbestos found on board ships in contravention
of SOLAS is required to be removed. Shipowners This is vitally important. Ordinary crew must not
need to make sure that this is managed safely and interfere with asbestos in any way. Any owner or
carefully, person involved with the ship who makes such a
request of ordinary crew could possibly be committing
The Circular allows a maximum of three years to an illegal act and exposing the company to
remove the asbestos (subject to the flag states enormous liability.
agreement). An exemption certificate is required to
continue trading during this time. There is no way If asbestos is known, or suspected, to be on board
to extend an exemption. If the ship has not had the a ship, owners should examine the requirements for
asbestos removed after the three years, it must remain its removal (including the experience, training and
where it is until it has been removed. Even small equipment needed) and, if appropriate, allow specialist
amounts of asbestos may take up to 10 weeks or crew members to either undertake urgent repair work
more to remediate, and work must continue until no in the presence of suspected asbestos, or undertake
more asbestos is found. minimum remedial action if suspected asbestos
is damaged, exposed or friable. Such measures would
Ships built before July 1, 2002 normally be limited to simply taping over, or similarly
Ships built before the 2002 ban can contain any sealing. exposed areas, in accordance with a proper
amount and type of asbestos in any location, provided procedure and using specially provided materials.
it is managed properly. The IMO provides guidelines
on this in Circular MSC/Circ.1045 Guidelines for In all cases it is vital to check local legislation first, but
Maintenance and Monitoring of On-Board Materials it should be reasonably simple to train senior crew
Containing Asbestos. members such as chief engineers to carry out this work.
22
Asbestos on ships how to manage it safely
7
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
23
Asbestos on ships how to manage it safely
4.2 In the case of flake coatings, lagging or false 6 Abatement actions, planned repair and
ceilings containing asbestos, their condition removal of asbestos-containing materials
should be assessed by completing the evaluation 6.1 Abatement actions should be selected and
checklist shown in appendix 1 to annex 1, which implemented when necessary. In some
takes into account, in particular, the accessibility instances, due to the condition of asbestos-
of the materials and products, their degree of containing materials or upcoming ship repairs or
degradation, their exposure to shocks and vibration modifications, a Company may decide to take
and the presence of air currents in the area. Air other abatement actions to deal with asbestos-
sampling of dust measurement may be used as one containing materials in the ship. These response
tool to help provide a more complete assessment actions could include: encapsulation (covering
of the ambient conditions on board. The evaluation the asbestos-containing materials with a sealant
form contained in appendix 2 to annex 1 should to prevent fibre release), enclosure (placing an
be used to make the diagnosis on the state of air-tight barrier around the asbestos-containing
conservation of these materials. materials), encasement (covering the asbestos-
containing materials with a hard-setting sealing
This assessment should be carried out by an expert material) or repair or removal of the asbestos-
(and in some countries a government-licensed expert). containing materials. Qualified, trained and
We strongly recommend that a company with marine experienced contractors should be used for any
expertise is used. Experience shows that land-based of these actions. The Company should be aware
companies do not understand the complexities of ship of any national and local regulations that pertain
structures or operations. For example, ceilings on land to abatement actions to deal with asbestos-
are often ignored in asbestos assessments since they are containing materials.
out of reach. But the constant movement and vibration
on ships can cause highly friable asbestos above false This provides further clarification on paragraph 5.2.
ceilings to shed fibres. Encapsulation, enclosure and encasement can be very
effective measures and can be much cheaper than
5 Maintenance and monitoring programme removal, but they do require constant monitoring and
5.1 If asbestos-containing material is located, a procedures must be put in place for potential repairs.
maintenance and monitoring programme should
be developed for that ship, based on the inspection 6.2 In the event of works requiring the removal of
and assessment data. The programme should be asbestos-containing materials, they should be
implemented and managed conscientiously and unloaded from the ship. On completion of the
include the elements contained in annex 1. work, and before any restoration of the spaces,
the Company should carry out dust measurement
Asbestos management is not only about safety, it is about after dismantling the enclosing mechanism. If the
corporate risk management. Unmanaged asbestos is an work does not result in the total removal of the
unknown and potentially enormous long-term liability. materials and products listed in this order, the
Maintenance and monitoring programmes are cost- Company should carry out regular surveillance
effective tools designed to save lives in the long term. of the asbestos-containing materials at intervals
identified by the Company as being appropriate,
5.2 In the case of flake coatings, lagging or false ceilings but not exceeding 3 years.
containing asbestos, depending on the diagnosis
as described in paragraph 4.2, the company should Various studies have been carried out on the results of
establish appropriate thresholds and timescales for asbestos concentration monitoring on board ships. One
undertaking any necessary repairs or abatement, study8 compiled evidence from 52 in-house studies and
taking into account any national regulations. 84 different vessels which included the analysis of over
1,000 air samples under normal conditions (i.e., with no
This paragraph highlights the fact that asbestos in some asbestos work underway). Nearly 99% of the samples
locations may be so friable and subject to such frequent were below the common health and safety limit of 0.1
disturbance that removal may be the only option. Asbestos fibres per cubic centimetre (cm3) and all were below
management must ensure that the relevant national 1 fibre per cm3.
regulations are properly followed and implemented.
8
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
24
Asbestos on ships how to manage it safely
9
IMO Circular MSC.1/Circ 1426 Unified Interpretation of SOLAS Regulation II-1/3-5
25
Asbestos on ships how to manage it safely
The importance of supply chain checks: asbestos in How the Netherlands flag is guarding
baby talcum powder against asbestos on newbuilds
In April 2009, three South Korean manufacturers had to The Netherlands flag had particular concerns about
recall baby powder products after the health authorities the amount of asbestos being found on newbuilds
discovered they contained asbestos. The Korean Food and Drug in countries that did not have proper asbestos
Administration initially confirmed asbestos in 11 talc products regulations or enforcement of asbestos regulations.
but then went on to discover 1,122 drugs and medical products They came up with their own procedure for
containing the contaminated talc. ensuring asbestos was not introduced onto their
newbuilds, as follows:
The asbestos was understood to have come from talc mined
outside Korea and may have become contaminated during 1. The shipyard provides evidence that the
the milling process before import. The talc was imported by a ship is asbestos-free and the RO verifies the
company which specialised in providing chemical raw materials investigation documentation.
to the pharmaceutical industry10.
2. The sub-contractors and shipyard supply
While this didnt occur within the maritime industry, it shows the asbestos free declarations or statements11.
importance of having checks throughout the whole supply chain.
Remember, the manufacturer may have been acting correctly in 3. Random samples are taken by a properly
terms of their contract and national law. authorised and independent asbestos company
of the items listed in IMO Assembly Resolution
A197(62), to a maximum of 20 samples.
If asbestos is found then further tests are
An example of good supply chain carried out.
management steel plates
Steel is manufactured in mills approved by the 4. When the results of the tests are known, a
major classification societies. Ladle analyses are remediation plan is agreed.
done of the melt, and composition checks are
performed on selections of the finished plate. 5. The asbestos company issues a report/
Batches are random tested. Each and every plate statement of its actions and recommendations
has markings which relate to a certificate, and if and the process is verified by the RO.
the plate is cut, such markings are transferred until
the plate is a known part of the ship. During this This is a simple, practical procedure that gives
process, random batches of steel are even tested better assurance to all involved.
by the shipyard normally as a side product of
weld tests (a sub-standard plate will break before
the weld and thus the quality control department
will know the steel is faulty). All of these items are Caroline Essberger12
controlled by the shipyard and witnessed/reviewed The 8,400 dwt tonne chemical Tanker Caroline
by the classification society. All the results are Essberger was built in the Eregli shipyard in
available to the owner and normally he is allowed Istanbul, Turkey in 2009 for German Shipowner
to witness or review any part. John T. Essberger. She was found to be riddled
with asbestos in thousands of gaskets and other
This is a good example of material control that can seals. The asbestos was only found several months
easily be applied to asbestos management. 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
Talc is commonly used as an excipient, the inactive ingredient that actually carries the drug the bulking agent in a pill for example.
11
Note that Lloyds Register and other classification societies already check ships plans for comments regarding asbestos during plan approval.
12
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)
26
Asbestos on ships how to manage it safely
27
Asbestos on ships how to manage it safely
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.)
28
28
Asbestos on ships how to manage it safely
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.
29
Asbestos on ships how to manage it safely
Asbestos Management Plans materials to contain asbestos unless there are good
Figure 1 is a land-based Asbestos Management Plan reasons not to do so.
for dutyholders who manage premises13 that may
contain asbestos, taken from Asbestos: The Survey This management plan is an excellent and internationally
Guide, published by the Health and Safety Executive14. recognised way of managing asbestos and can be simply
The Guide begins with a fundamental concept which is tailored to make it relevant to shipowners, as Figure 2
vitally important in managing asbestos risks: Presume demonstrates. It can also be applied to fleet management.
Appoint person
to manage
asbestos
Yes
RECORD
No further action Prepare asbestos
register
Prepare
management
plan
Train staff
Manage contractors
Checked all work against
plan/register
Control of work itself:
Asbestos essentials
Compliance with CAR
13
Interestingly, under UK law, premises includes ships.
14
Available at http://www.hse.gov.uk/pubns/books/hsg264.htm
30
Asbestos on ships how to manage it safely
Appoint person
to manage
asbestos
Identify ships
in fleet to be
managed
Record. Maintain
Approved service
evidence and
supplier
decision making Find out if ACMs present:
steps check plans and drawings.
Carry out samples and surveys,
check procurement information
Ensure effective
Third party
systems in place to
verification
avoid purchasing Prepare asbestos
and installing ACMs register (Inventory
of Hazardous
Materials preferred)
Monitor and Approved service
review supplier
effectiveness Undertake risk
of system assessment
Approved service
supplier
Prepare
management
plan
Policy
Procedures
Objectives and targets
Safety provision
Maintenance work
Equipment and Training
Improve PPE provision Awareness
procedures Procurement plan
Asbestos action
Monitor ACM
and work
Measure performance
Update records
Document
Review
Figure 2: The land-based Asbestos Management Plan adapted for maritime use.
31
Asbestos on ships how to manage it safely
32
Asbestos on ships how to manage it safely
Between
Before After
1 July, 2002 and
1 July, 2002 1 Jan, 2011
1 Jan, 2011
Yes
Is there a reputable
Is there a reputable
No asbestos free certificate No
asbestos free certificate
(or a list of asbestos available
available
from the time of construction)
Yes Yes
Have any large reputable
No asbestos registers been done?
(has a list of asbestos
been provided?)
Yes
Note: you must follow the arrows directly down from the year of build unless an arrow takes you sideways.
33
Asbestos on ships how to manage it safely
A turbo-alternator with
asbestos-lagged steam pipes
34
Asbestos on ships how to manage it safely
35
Appendix Common asbestos areas on board ships
Appendix
Common asbestos areas on board ships
This appendix contains images of the places where Asbestos fire blankets
asbestos is most likely to be found on board ships. It Asbestos fire blankets are a common nuisance.
is based on an educational powerpoint presentation They are often brought on board ships by uncontrolled
used to train our surveyors, prepared in collaboration sub-contractors carrying out temporary work. They
with M.A.R.C a Netherlands-based, licensed are extremely easy to damage and very friable, so they
specialist asbestos company. We are very grateful will easily shed large numbers of fibres which can be
for their assistance and for the use of many of their difficult to clean up. Their asbestos content will be
photographs in this section. very high well over 50% but the good news is that
they are likely to be new and therefore contain only
Before we get on board the ship chrysotile asbestos.
plan approval
A lot of information relating to asbestos will be
contained in the ships plans. There may be statements
that particular items are non-asbestos or details of
substitute materials like rockwool.
Friable mess and fibres from an asbestos blanket. Note: a piece of cloth has been used to
protect the deck from the scaffolding this will clearly cause large fibre releases.
36
Asbestos on ships how to manage it safely
37
Asbestos on ships how to manage it safely
38
Asbestos on ships how to manage it safely
Floors
Floors present particular problems because they are
often multi-layered and any or all of these layers might
contain asbestos. An A-60 floor, for example, might
contain a bottom levelling layer (so that the fire layer
can be accurately applied); several centimetres of fire
proof cement; a levelling compound; an adhesive;
and a fire-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 floor.
39
Asbestos on ships how to manage it safely
40
Asbestos on ships how to manage it safely
41
Asbestos on ships how to manage it safely
Asbestos canvas. This is also used on cold water pipes Asbestos canvas
to avoid condensation.
Asbestos insulation. This type of loose flock 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 fibres, leading to large releases if it is disturbed.
42
Asbestos on ships how to manage it safely
Engine room stores spare parts It is common to find ships which state they have no
Engine room stores are some of the commonest areas asbestos onboard and yet have cupboards which
for new asbestos to get on board ships. The problem is contain items clearly marked asbestos. On one ship,
underlined by the IMO Circular, MSC.1/circ.1426. This an LR surveyor was given a long lecture by the Chief
recognises that it is almost impossible to guarantee Engineer on the dangers of asbestos, only to then find
that engine room stores do not contain asbestos, and a freshly cut gasket, clearly labelled asbestos, sitting on
therefore states that asbestos is allowed in engine the cutting bench in the machinery area.
room stores but that items containing it cannot actually
be installed on board the ship.
Engine room
The engine room store examples show that you
are likely to find 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.
44
Asbestos on ships how to manage it safely
45
Lloyds Register EMEA Lloyds Register Asia Lloyds Register Americas, Inc.
T +44 (0)20 7709 9166 T +852 2287 9333 T +1 (1)281 675 3100
F +44 (0)20 7423 2057 F +852 2526 2921 F +1 (1)281 675 3139
E emea@lr.org E asia@lr.org E americas@lr.org
www.lr.org
March 2013