asbestos in shipyards - identification, awareness, alternatives & removal

Asbestos on shipsHow to manage it safely

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Asbestos on ships – how to manage it safely

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Contents

Foreword 3

Part 1 – A history of asbestos 41 What is asbestos 42 The rise of asbestos 73 Health and regulation 104 Testing for asbestos 14

Part 2 – Asbestos on board ships 171 The increased risk in shipping 172 Where is asbestos found on ships 183 Regulation 214 How the marine industry’s stakeholders can protect their workers 275 Tools for achieving best practice in management 30

Appendix – Common asbestos areas on board ships 36


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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 material’s 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.

Lloyd’s 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 TownsendRegulatory Affairs Lead Specialist, Lloyd’s Register

1 World Health Organization (2010). Elimination of asbestos-related diseases (Fact sheet N°343). Available at: http://www.who.int/mediacentre/factsheets/fs343/en/index.html2 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)


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1. What is asbestos?

Asbestos is a generic name given to the fibrous 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 fibres or fibrils with a diameter of only a few nanometres.

The two groupsAsbestos is generally categorised in two groups: amphibole and serpentine. There are five amphibole asbestoses and one serpentine. Amphibole asbestos is considered more dangerous than serpentine.

Table 1: Types of asbestos and their relative uses and dangers

Part

1 –

A h

isto

ry o

f as

bes

tos

Asb

esto

s fa

mily

Type Name CAS Number Relative use in A: shipbuildingB: other industriesC: total use today

Relative danger A: mesotheliomaB: lung cancer

Actinolite

Amphibole(five types)

Short, sharp fibres

77536-66-4A: LowB: LowC: 0

Amosite(grunerite) (brown)

12172-73-5A: Medium

B: LowC: 0

A: 100B: 10-50

Anthophyllite 77536-67-5A: LowB: LowC: 0

Crocidolite (blue) 12001-28-4A: Medium

B: LowC: 0

A: 500B: 10-50

Tremolite

Chrysotile

Amphibole(serpentine one type)

Long, curly fibres

77536-68-6A: LowB: LowC: 0

12001-29-5A: highB: highC: 100

A: 1B: 1

The big three: blue, brown and whiteThe most commonly recognised types of asbestos are blue, brown and white, and these are properly called crocidolite, amosite and chrysotile asbestos. Crocidolite and amosite are amphiboles and chrysotile is the only serpentine. Their common names relate to their natural colour and have nothing to do with how they appear in products: it is in fact impossible to tell the type of asbestos from the colour of a product.

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/


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Crocidolite asbestos (blue)Crocidolite asbestos is considered the most dangerous form (see Table 1 for the relative risks it presents). Some medical reports describe it as 100 times more dangerous than chrysotile asbestos. It has smaller, more jagged particles than either amosite or chrysotile asbestos, and has a higher iron content4. It is also highly resistant to acid – a feature that might have favoured its use in some applications.

It is thought that the characteristics of crocidolite asbestos allow it to easily penetrate the outer coating of the lungs (the pleura) where it can cause some of the worst asbestos-related diseases. We also know from studies that crocidolite asbestos is far more persistent in the body than other forms.

Amosite asbestos (brown)Amosite5 asbestos is considered to be a little less dangerous than crocidolite, but still considerably more dangerous than chrysotile.

Amosite asbestos, like other amphibole forms of asbestos, consists of straight fibrils 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).

Chrysotile asbestos (white)Chrysotile asbestos is considered significantly less dangerous than crocidolite or amosite asbestos. Its fibrils consist of double layers which roll up into hollow tubes with a diameter of around 25 nanometres. When these long curly fibres are breathed in they often stop in the upper respiratory tract and are therefore more readily cleared from the lungs. Despite chrysotile asbestos’s reputation as a less dangerous form, it is often contaminated with other more hazardous forms (see “A closer look at chrysotile asbestos contamination“on page 6).

Chrysotile asbestos from Brazil (image taken from Wikimedia Commons).

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.

Asb

esto

s fa

mily

Type Name CAS Number Relative use in A: shipbuildingB: other industriesC: total use today

Relative danger A: mesotheliomaB: lung cancer


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Other asbestos types

ActinoliteActinolite shares the basic characteristics of crocidolite and amosite asbestos. It has been used, and therefore researched, far less than crocidolite, amosite or chrysotile. A significant characteristic of actinolite is that it is a common contaminant of talc (see page 26) and chrysotile asbestos.

TremoliteTremolite has similar characteristics to actinolite and its use has been equally rare. It is also a common contaminant of chrysotile asbestos. Significantly, the amount of tremolite found in the lungs of people who have died from exposure to it far outweighs the amount they were apparently exposed to.

AnthophylliteAnthophyllite shares the characteristics of tremolite and actinolite. It is common to see it mentioned in paint contents as ‘non asbestos’ anthophyllite. This refers to one of the major characteristics of asbestos, which causes understandable confusion – the existence of non-hazardous types in which the fibres do not have the same crystalline characteristics as those in the ‘true’ asbestos forms.

Other substancesThis 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.

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/66/8/5357 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.abstract8 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-4be5a6cc711b9 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/abstract10 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/

A closer look at chrysotile asbestos contaminationChrysotile asbestos may be considered less deadly than crocidolite or amosite but a study published in 2009 on 5,770 workers at chrysotile asbestos plants in North Carolina still showed a significantly increased risk of asbestos-related diseases6. A similar study in China also demonstrated strong evidence for increased mortality risks.7

One of the reasons cited for this risk is that chrysotile asbestos is often contaminated with the more harmful amphibole types of asbestos. A number of studies have found the lungs of victims who were expected to have been exposed to chrysotile asbestos to contain a large proportion of amphiboles such as tremolite.

In China, ten samples from six mines were tested and all were found to be contaminated with tremolite although at very low quantities.8 Another study which tested the lung tissues of seven dead workers who had worked in a pure chrysotile asbestos mine showed the fibres in the lungs were 71% anthophyllite, 9% tremolite and just 10% chrysotile asbestos. And yet another study of chrysotile asbestos workers showed 34 of 35 fibres were amphiboles.

These latter two studies showed that chrysotile asbestos had naturally left the workers’ bodies but that the amphibole contaminants had persisted. These findings are reinforced by another study which found that chrysotile asbestos fibres tend to clear from the lungs, with a half life of less than 10 years, whereas amphiboles do not seem to clear.9

Chrysotile asbestos accounted for over 95% of all asbestos produced and consumed between 1900 and 200310.


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2. The rise of asbestos

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 fire 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 benefits and it is still without equal.

A brief history of asbestos production

Pre-historyEvidence of asbestos mining has been found in Cyprus from as long ago as 3,000 B.C. Analysis of archaeological finds in Finland from a slightly later date shows that asbestos fibres were used to reinforce earthenware pots, and there is evidence that this practice spread within Scandinavia and Russia. Tremolite and chrysotile asbestos were mined by the Romans in the Italian Alps.

Early reported usesIn AD 800, Emperor Charlemagne was reported as having a tablecloth that never needed cleaning. When it became dirty, he simply threw it into the fire, 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 fire, remains incombustible”.

First large commercial minesAsbestos 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 ageModern 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 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.)

A Roman glass crematorium urn, containing bones and traces of asbestos burial shrouds(Image courtesy of the British 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 first 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 usageBy 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 figure 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 declineThe 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 significant 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.

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.pdf13 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.aspx15 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

Table 2: Recent global production of asbestos15

e = estimated

Country 2010 2011 2012e

Brazil

CanadaChinaKazakhstanRussiaOthers

Total

270,000 302,000 300,000

100,000 50,000 –400,000 440,000 440,000214,000 223,000 240,0001,000,000 1,000,000 1,000,000

21,000 19,000 20,000

2,010,000 2,030,000 2,000,000

Canada: asbestos mining stops for first time in 130 years13

Canada’s Lac d’Amiante (literally, ‘asbestos lake’) mine in Quebec shut down in early November, 2011. This followed a shutdown at the only other operational asbestos mine in Canada, Jeffrey Mine about 90 kilometres away. Both shutdowns appeared to be for operational or financial reasons and both mines are pursuing plans to re-open.

The Vancouver Sun, in its edition of 24 November, 2011 reported: “Earlier this year, the Canadian Government had blocked the listing of chrysotile asbestos in Annex III of the Rotterdam Convention. This would have meant that exports and imports would have to have been declared and thus countries could refuse to accept chrysotile asbestos”.

The report of the meeting published on the Rotterdam Convention website14 does not record an intervention from Canada, although Canada is conspicuous by its absence from the list of signatories to a ‘declaration’ against chrysotile asbestos made at the conference in June 2011.

In September 2012, Canadian newspapers were reporting anti-asbestos sentiment in Canada but also that the asbestos mines were hoping to re-open in spring 2013.


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The Black Lake asbestos mines in Quebec, Canada


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3. Health and regulation

A health problem for the Greeks and Romans?There is conjecture over whether the Greeks and Romans recognised the health problems associated with asbestos. Some people assert that Pliny the Elder, the Roman author and naturalist, described protection against asbestos, but others claim he was referring to different problems. His “Natural History” makes no direct mention of asbestos. The first recognised cases of asbestos-related diseaseThe first report of asbestos-related disease in England was in 1906 when Dr. Montague Murray reported an asbestosis fatality to the Parliamentary Departmental Committee on Compensation for Industrial Diseases. It wasn‘t until the mid 1920s that more reports started to appear and asbestosis became recognised as a medical term. Asbestosis became the first fatal disease to be definitively linked to asbestos exposure (see “The case of Nellie Kershaw“).

In March 1928, at the inquest of Walter Leadbetter of Aviary Mount in Armley, Dr. H. De Carle Woodcock, a well-known lung specialist, drew attention to the inhalation of asbestos dust as the cause of the deceased’s fibrosis of the lungs.

In 1930, Merewether and Price, two medical inspectors from the Factory Department17 delivered research on the asbestos textile industry in Britain – it identified that 25% of the 363 workers examined had pulmonary fibrosis. It was in the 1930s that workers with asbestosis first started suing their employers.

The beginning of regulationThese reports and research led to the 1931 Asbestos Industry Regulations. While this legislation only reduced the dust levels in factories, at the time it was believed to have solved the problem of asbestosis.

Asbestos, cigarettes and the link to lung cancerSo far, no direct link had been established between asbestos and lung cancer (although a connection between asbestosis and lung cancer had been made). Key to understanding this is the enormous increase 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 to be the same problem.

The link between lung cancer and smoking was eventually established in the 1950s, and it was only in 1955 that countries started recognising unexpectedly high instances of lung cancer among asbestos workers.

Mesothelioma and a problem that could no longer be ignoredIn the 1960s an alarming rise in the previously extremely rare disease mesothelioma was attributed to asbestos. The rarity of the disease made its link to asbestos exposure all the more dramatic, and it became increasingly impossible to ignore asbestos risks. This led the UK to revise its asbestos regulations over a five year period resulting in new regulations in 1969 which effectively banned crocidolite asbestos.

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 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.

The case of Nellie Kershaw16

Nellie worked with asbestos for nearly 20 years. She died aged 33 in 1924. She suffered from a series of health problems that culminated in her being rendered permanently unfit for work in 1922. The primary cause of her death was established as ‘pulmonary fibrosis of the lungs due to inhalation of mineral particles’. Her GP, Walter Joss had characterised her illness as ‘asbestos poisoning’. Nellie was unable to get health insurance during her life because the condition was not recognised.

However, Nellie’s case led to an inquest which ensured that a pathological examination was carried out, by Dr. William Cooke. He subsequently published an article in the British Medical Journal which attributed her death to asbestos. Three years later, in 1927, he definitively attributed her death to ‘asbestosis’. This was the first time the term had been used in this way in a medical publication. Nellie may be considered the first recognised victim of ‘asbestosis’ and the starting point for all the investigation and research that followed.

16 Source: 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)


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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? There’s got to be some cause”.

The situation today In 1983 Iceland became the first country to place a general ban on all recognised forms of asbestos, although with exceptions.

The European Commission announced its almost complete ban on all asbestos in July 1999. It came into effect on 1 January, 2005. However, Cyprus, Czech Republic, Estonia, Greece, Hungary, Lithuania, Malta, Portugal and Slovakia, are not presently verified as being compliant by the International Ban Asbestos Secretariat (IBAS)18.

Globally, IBAS lists 54 countries18 as having banned asbestos. This means that the following countries still allow it. • US (2011 usage was 1,100 tonnes) • India • China • Russia • Brazil • Mexico

With India, China, Indonesia and the US on the list, it appears around half the global population does not have proper protection from asbestos production.

Brazil, China, Kazakhstan and Russia still mine large quantities of asbestos (see page 8).

Asbestos-related diseasesAsbestos causes a number of health problems of varying severity.

Pleural diseases (non-malignant)Pleural diseases include two non-cancerous conditions – diffuse pleural thickening and pleural plaques. They take their name from the ‘pleura’ – the two-layered membrane (or mesothelium20) which encloses and protects the lungs.

Diffuse pleural thickening is general thickening of the pleura which extends over a large area and restricts expansion of the lungs. It is thought that asbestos fibres cause the disease by irritating the pleura, causing scarring and hardening.

Pleural plaques are generally less serious than pleural thickening and may not display any symptoms. Many asbestos workers with pleural plaques may never realise they have them unless they are X-rayed. The plaques occur as bundles of collagen (a fibrous protein that connects tissues and other items in the body) on the pleura.

AsbestosisThe 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 fibres. In an asbestosis sufferer, the air sacs (alveoli) which control gas transfer in the lungs become scarred and healthy lung tissue is replaced by fibrous 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.

A look at asbestos exposure in IndiaIn India it has been estimated that 100,000 workers have been exposed to asbestos, but only 30 have been compensated. A study of 181 workers at just one asbestos composite mill in Mumbai found that 22% had asbestosis19. This echoes the lack of recognition of the problem experienced decades earlier elsewhere in the world.

• Panama• Liberia • Philippines • Indonesia • Singapore • Taiwan

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)


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Pulmonary fibrosis Pulmonary fibrosis 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.

MesotheliomaMesothelioma is a form of cancer which affects the body’s mesothelial membranes, those surrounding organs in the body cavity such as the heart, lungs and stomach. It is believed that asbestos fibres 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 significant 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 cancerBecause lung cancer is caused by many factors, including smoking, it is difficult to definitively 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 five years.

Other diseasesThere is evidence that asbestos can cause other cancers such as bowel, stomach, oesophagus, pancreas and kidney.

The case of Shirley Gibson21

Shirley Gibson was a teacher in the London Borough of Greenwich. She died of Mesothelioma in 1993 at the age of 37. The inquest concluded that the disease had probably been caused by exposure to asbestos in the classrooms of the school she worked at. She only worked at the school from 1983 to 1993.

Greenwich council conducted a survey of the 120 schools in the area, but initially refused to inform parents of the results. In 2004, Greenwich council paid £135,237 to the family of Shirley Gibson.

Cases like Shirley’s have led to better management of asbestos in the UK’s schools today.

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)


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“One fibre can kill” – evaluating the real riskThe words “one fibre can kill” have appeared numerous times in relation to asbestos but they are highly misleading. While it is true that any exposure to asbestos carries risk, ‘loading’ is highly significant, just as it is with smoking: in short, the more asbestos you are exposed to, the more risk you have.

A typical acceptable airborne concentration of asbestos specified by health and safety regulation is 0.1 fibres per cubic centimetre (cm3) of air averaged over a four hour period. Simply put, if every breath you take fills your lungs with two litres (20,000cm3) of air, it is ‘acceptable’ for each breath to contain 2,000 particles. The typical number of fibres found in the mixing area of a typical asbestos textile factory in the 1950s was between 2,000 and 4,000 per cm3, 20,000 to 40,000 times higher than the presently acceptable limit.22

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 figures like these, it is important to note that many factors may have influenced the differences in results, including cases not being reported.

Location Industry Number of people studied

Timescale Number of cases

Year of study

Canada Gas mask manufacturer

200 1939-1942 9 ‘probably mesothelioma’

197823

Australia Mining 6,916 1943 – 1966 222 cases mesothelioma

200724

South Africa Mining 3,430 Before 1962 5 mesothelioma, circa 20% ‘abnormalities’

1974-197825

UK Gas mask manufacturing

435 1930s to 1969 5 mesothelioma 198226

Table 3: results of studies of crocidolite asbestos mine and manufacturing workers

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.pdf23 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/


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The subject of testing for asbestos could fill 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 ‘proficiency 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 quantifies the number of fibres in a sample but not the type. If you do not need to know what your fibres are – for example you are doing an air sampling filter examination and you only expect asbestos fibres – 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 identifies the type and percentage of asbestos using a phase contrast microscope with polarising filters. Its limit of detection is somewhere between 0.1% and 1% which means it may be insufficient 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 reflection from the scattered electrons to create a ‘picture’. The advantage of SEM is that it magnifies the image up to 300,000 times. It is particularly useful for bulk sampling. SEM is normally the most definitive 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 reflected 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 specifies 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 fibres so that the quantity of asbestos in the original sample can be estimated. This test is fast and efficient but is only really relevant when you know your sample contains asbestos.

4. Testing for asbestos


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Test type What does it do? Good for Speed Level of fibreidentification

Ease of use Investment /cost per sample

Drawbacks

Stereo microscopy

Magnifies the sample for initial checking

Initial examination and screening

Fast None. Only gives an indication of likely materials

Simple to use.

Can be hand carried.

Can cost less than $500.

Cheap.

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.

Polarised light microscopy (PLM)

Magnifies the sample 100 to 400 times and uses other techniques such as polarisation and dyes to do basic fibre and quantity analysis

Speed, simplicity and cost

Fast Medium. Can be very good with specific types of asbestos bound up in a simple matrix

Simple to use.

Portable. Can be set up anywhere.

Less than $10,000.

Cheap.

Poor at levels of accuracy below 1% and limited for fibre analysis

Scanning electron microscopy (SEM)

Uses electrons to scan the sample and produces massively magnified 3D images to find and identify fibres

Accuracy, detail and images

Slow Good Complex.

Non-portable equipment in a dedicated laboratory

Huge investment.

High.

Cost. Very slow for quantitive analysis.

X-ray diffraction (XRD)

Uses X-rays to examine crystal properties, but does not produce an image

Speed of quantitive analysis

Fast Poor. Cannot identify between asbestos and non-asbestos forms of the same material.

Moderately easy to use

Large investment.

Medium (depends on set up and usage).

Does not give fibre morphology

Transmission electron microscopy (TEM)

Fires electrons through a very thin slide of the material and produces massively magnified images (10 to 20 000 x) to identify fibres

Accuracy and detail

Slow Good Complex.

Non-portable equipment in a dedicated laboratory

Large investment.

High.

Cost

Gravimetric analysis

Through weighing and reduction of the sample, it finds the mass percentage of asbestos

Quick quantitive estimation

Fast (once sample has been prepared)

None. Does not identify asbestos and relies on other techniques to do this first.

Moderately easy

Low.

Cheap to medium.

Preparation time can be very slow

Table 4: Comparison of asbestos testing methods


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A steam plant containing asbestos


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1. The increased risk in shipping

For a number of reasons, ships can present an increased risk of asbestos exposure. First, the use of asbestos in shipbuilding over the years has been unusually high, and has included a disproportionately large amount of blue and brown asbestos – the worst types. Second, some of the most dangerous asbestos application methods, such as spraying, have been particularly prevalent in ship construction, and these methods also increase friability (see “Friability – a vital consideration”).

Added to these construction factors is the fact that ships are not stable environments: they roll, pitch, yaw, heave, surge, sway, slam and vibrate, and in the engine room these issues are magnified by vibrating machinery. These conditions make friable asbestos far more likely to emit fibres.

A UK study estimated an increase of 61% over the expected presence of asbestos in shipyard workers1. A similar study in Trieste, Italy, showed that of 153 men who had died of malignant mesothelioma 99 had worked in shipbuilding, 19 had been in the navy/merchant marine and 7 had been dockworkers2.

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Friability – a vital considerationThe level of danger presented by asbestos depends mainly on the substance it is ‘bound up’ in and how easily that substance can be damaged. This is referred to as friability.

For example, asbestos solidly bound in concrete which is well protected and in good condition might be considered safe, but exposed concrete which can easily be damaged or become dusty is highly friable and dangerous. Asbestos contained in a plastic, such as a floor tile, is considered safe and even if the tile is damaged it is unlikely to become friable and release fibres. The subject is explored in more detail in the Appendix.

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


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2. Where is asbestos found on ships

In the worst cases, you can find asbestos virtually everywhere on a ship. It can be in:

• the concrete and tiling on the floor • the wall and ceiling panels and the fire insulation behind them• the doors • the glues and sealants in the windows and furniture • heat insulation and lagging • electrical cables • brake linings and gaskets

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 IMO’s 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 IMO’s 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.

• mooring ropes • firemen’s outfits • boiler cladding • furnace firebricks, 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).


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Table 4: IMO list of areas where asbestos may be found on ships

Structure and/or equipment Component

Propeller shafting • Packing with low pressure hydraulic piping flange• Packing with casing • Brake lining• Clutch • Synthetic stern tubes

Diesel engine • Packing with piping flange • Lagging material for exhaust pipe• Lagging material for fuel pipe • Lagging material turbocharger

Turbine engine • Lagging material for casing• Packing with flange 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

Boiler • 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 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

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

Incinerator • Packing for casing door • Packing with hand hole• Packing with manhole • Lagging material for exhaust pipe

Auxiliary machinery (pump, compressor, oil purifier, crane)

• Packing for casing door and valve • Brake lining• 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

Pipe, duct • Lagging material and insulation

Tank (fuel, hot water, tank, condenser), other equipments (fuel strainer, lubricant oil strainer)

• Lagging material and insulation

Electric equipment • Insulation material

Airborne asbestos • Wall, ceiling

Ceiling, floor and wall in accommodation area

• Ceiling, floor, wall

Fire door • Packing, construction and insulation of the fire door

Inert gas system • Packing for casing, etc.

Air-conditioning system • Sheet packing, lagging material for piping and flexible joint

Miscellaneous • Ropes • Moulded plastic products• Thermal insulating materials • Sealing putty• Fire shields/fire proofing • Shaft/valve packing• Space/duct insulation • Electrical bulkhead penetration packing• Electrical cable materials • Circuit breaker arc chutes• Brake linings • Pipe hanger inserts• Floor tiles/deck underlay • Weld shop protectors/burn covers• Steam/water/vent flange gaskets • Fire-fighting blankets/clothing equipment• Adhesives/mastics/fillers • Concrete ballast• Sound damping


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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 floor of a bridge showing damaged, friable asbestos-containing cement. Asbestos is often used to boost the fire-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 asbestos-containing concrete layer may have been put down next, followed by a final finishing and levelling layer before the vinyl floor was put down. The vinyl floor may contain asbestos too.

4 An A-60 partition is a particular type of fire-resistant partition designed to work for 60 minutes.

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.


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3. Regulation

The SOLAS ConventionThe use of asbestos on board ships is governed by Chapter II, Regulation 3-5 of the International Maritime Organization’s Safety of Life at Sea (SOLAS) Convention. This introduced the first major asbestos ban on 1 July, 2002, prohibiting the new installation of asbestos-containing materials on all ships, except for:

• vanes used in rotary vane compressors and rotary vane vacuum pumps

• watertight joints and linings used for the circulation of fluids when, at high temperature (in excess of 350º C) or pressure (in excess of 0.7 x 106 Pa), there is a risk of fire, corrosion or toxicity, and

• supple and flexible thermal insulation assemblies used for temperatures above 1,000º C.

An amendment which came into force on 1 January, 2011, banned all new installations.

“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 flag states and recognised organisations in ensuring compliance with SOLASFlag states5 are responsible for ensuring that the provisions of the SOLAS Convention are properly represented in national law and for enforcing the

5 A flag state is the administration of the government where the ship is registered, whose flag a ship is entitled to fly.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)

Convention’s requirements within their national limits and on board ships which fly their flag. Recognised organisations (ROs) are authorised by the flag state to carry out on their behalf the statutory surveys and certification required to demonstrate compliance. Classification societies commonly act as ROs. Lloyd’s Register is an RO for over 140 countries’ administrations. Flag states can also apply local laws and requirements to ships which fly their flag (see page 26 for an example from the Netherlands).

The ISM CodeAll SOLAS Convention ships must comply with the International Safety Management (ISM) Code. This requires companies to identify safety risks, including asbestos risks.

ISO standardsThe International Organisation for Standardization (ISO) publishes a number of standards on asbestos. These are not legal requirements unless directly referenced by law.

The US legal position on banning asbestos6

On 12 July, 1989, the United States Environmental Protection Agency (EPA) issued a final ruling banning most asbestos-containing products. This was an early move in comparison to other countries, and perhaps because of this it was overturned on appeal in New Orleans in 1991. The ruling was clarified to ban specific products (flooring felt, rollboard, and corrugated, commercial, or specialty paper) and ‘new uses’ of asbestos. This meant that products already being made that contained asbestos could continue to be manufactured.

This is of vital importance to the shipping industry as ”EPA does not track the manufacture processing or distribution in commerce of asbestos-containing products”. Therefore, many items which shipyards (or other manufacturers in the shipping supply chain) buy from the US might contain asbestos but there is no legal requirement for the item manufacturer to declare this. The US consumes about 1,100 tonnes of asbestos per year to make asbestos-containing products.


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Focus on existing shipsUnder the SOLAS asbestos regulations, existing ships are split into two main groups. Those built before 1 July, 2002, are allowed to have asbestos on board. Those built after this date are subject to the ban on most new installations (see page 21) and should only have very limited amounts of asbestos on board.

Ships built after 1 July, 2002Ships containing asbestos in contravention of the SOLAS 2002 ban are governed by the IMO Circular MSC.1/Circ.1374 – Information on Prohibiting the Use of Asbestos on Board Ships.

This acknowledges that asbestos is still being found on board ships despite the regulations. And it states that the principal means of addressing the problem is through the shipyards and suppliers.

Circular 1374’s main recommendation is that any item supplied to the ship has an ‘asbestos free declaration’. It also says that random confirmations should be carried out.

Asbestos found on board ships in contravention of SOLAS is required to be removed. Shipowners need to make sure that this is managed safely and carefully,

The Circular allows a maximum of three years to remove the asbestos (subject to the flag state’s agreement). An exemption certificate is required to continue trading during this time. There is no way to extend an exemption. If the ship has not had the asbestos removed after the three years, it must remain where it is until it has been removed. Even small amounts of asbestos may take up to 10 weeks or more to remediate, and work must continue until no more asbestos is found.

Ships built before July 1, 2002Ships built before the 2002 ban can contain any amount and type of asbestos in any location, provided it is managed properly. The IMO provides guidelines on this in Circular MSC/Circ.1045 – Guidelines for Maintenance and Monitoring of On-Board Materials Containing Asbestos.

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 benefits are to be gained by making sure that any asbestos is managed properly, regardless of the ship’s 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 first, but it should be reasonably simple to train senior crew members such as chief engineers to carry out this work.


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An example of a good repair to an asbestos-containing item

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 qualified professional to investigate the possible presence of asbestos-containing materials on board the ship and, if any are identified, 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 confidence 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.

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


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4.2 In the case of flake 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 fibres.

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 cost-effective tools designed to save lives in the long term.

5.2 In the case of flake 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 asbestos-containing materials or upcoming ship repairs or modifications, a Company may decide to take other abatement actions to deal with asbestos-containing materials in the ship. These response actions could include: encapsulation (covering the asbestos-containing materials with a sealant to prevent fibre release), enclosure (placing an air-tight barrier around the asbestos-containing materials), encasement (covering the asbestos-containing materials with a hard-setting sealing material) or repair or removal of the asbestos-containing materials. Qualified, 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 asbestos-containing materials.

This provides further clarification 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 identified 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 fibres per cubic centimetre (cm3) and all were below 1 fibre per cm3.

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


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Specialist asbestos expertiseWhen specialist asbestos expertise is required (for work such as sampling, testing or removal) make sure that the company and its employees have the appropriate qualifications and certification. Many countries have rigid requirements for asbestos experts, including strict licensing requirements. It is vitally important to check these requirements. Failure to do so may mean that you are breaking the law.

Items removed from existing ships for servicingRecently, we were asked: If you remove an asbestos-containing item from an existing ship for servicing (for example, a fire fighting appliance which needs recharging) is this classed as a new installation when it is put back?

We believe not, and Australian legislation clarifies this in Customs Notice No.2009/30, which states that “new installation of asbestos is banned… where asbestos…due to repairs, refits or renovations…is re-fixed, re-installed, or replaced with other asbestos”.

In other words, if you are keeping the old asbestos, and not replacing it with new asbestos, then you can put the item back on the ship, but any asbestos being replaced must be replaced by an asbestos-free material. If your CO2 system goes ashore for servicing and recharging, for example, any worn asbestos gaskets should be replaced with non-asbestos gaskets, but the servicing agency is not mandated to open the entire object and ensure that existing, good asbestos gaskets are replaced.

We would, however, always recommend replacing any asbestos in these cases, in agreement with the servicing company.

Focus on newbuildsFor 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.

The importance of the supply chain for newbuildsIn countries that allow the use of asbestos, manufacturers are perfectly entitled to use it in their products. Therefore it is vitally important for the owner and the yard to stipulate compliance with SOLAS and any other asbestos regulations throughout the entire ship supply chain.

We recommend the supply chain is set up as follows:

1. The prospective owner or operator agrees the intended use of the ship and the specifications it must comply with, including SOLAS, in the contract with the shipyard.

2. The owner or operator also agrees with the yard how checks will be carried out, including design specification, sub-supplier specification, spot checks, documentation checks, label checks, witness and hold points, and samples and testing.

3. The owner or operator requests asbestos-free declarations from the shipyard, encompassing the entire supply chain.

4. The shipyard specifies, in each of its contracts with sub-suppliers and sub-contractors, that the contracted item or work is intended for a ship and must comply with a list of specifications, including SOLAS. All stakeholders in the supply chain issue a manufacturer’s declaration, stating that items are asbestos free.

5. The shipyard (or any sub-supplier who assembles items sent to him) checks that sub-suppliers and sub-contractors have delivered to specification, identifying high-risk items, manufacturers or other ‘indicators’, and carrying out spot checks accordingly.

6. The shipyard supplies asbestos-free declarations to the owner, including its own overall statement that the ship is free of asbestos.

This set up should ensure the yard is doing spot checks on its sub-suppliers and that the owner is performing similar spot checks before accepting delivery of the vessel.

9 IMO Circular MSC.1/Circ 1426 – Unified Interpretation of SOLAS Regulation II-1/3-5


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The importance of supply chain checks: asbestos in baby talcum powderIn 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 confirmed 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 didn’t 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.

An example of good supply chain management – steel platesSteel is manufactured in mills approved’ by the major classification societies. Ladle analyses are done of the melt, and composition checks are performed on selections of the finished plate. Batches are random tested. Each and every plate has markings which relate to a certificate, and if the plate is cut, such markings are transferred until the plate is a known part of the ship. During this process, random batches of steel are even tested 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 controlled by the shipyard and witnessed/reviewed by the classification society. All the results are available to the owner and normally he is allowed to witness or review any part.

This is a good example of material control that can easily be applied to asbestos management.

How the Netherlands flag is guarding against asbestos on newbuilds The Netherlands flag had particular concerns about the amount of asbestos being found on newbuilds in countries that did not have proper asbestos regulations or enforcement of asbestos regulations. They came up with their own procedure for ensuring asbestos was not introduced onto their newbuilds, as follows:

1. The shipyard provides evidence that the ship is asbestos-free and the RO verifies the ‘investigation documentation’.

2. The sub-contractors and shipyard supply ‘asbestos free’ declarations or statements11.

3. Random samples are taken by a properly 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 carried out.

4. When the results of the tests are known, a remediation plan is agreed.

5. The asbestos company issues a report/statement of its actions and recommendations and the process is verified by the RO.

This is a simple, practical procedure that gives better assurance to all involved.

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 Essberger’s 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 Lloyd’s Register and other classification societies already check ships’ plans for comments regarding asbestos during plan approval.

12 Source: Lloyd’s 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)

Supply chain case studies


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The ultimate aim of managing asbestos is to protect workers from exposure. It is vital that this is achieved through a simultaneous top-down and bottom-up management approach.

Top-down management ensures that the top-level stakeholders are aware of asbestos problems. They should implement an effective asbestos risk management system that provides training, awareness and protection to the workers so that they can recognise potentially dangerous situations and act accordingly. Without top-down knowledge and control, bottom-up management is impossible.

Bottom-up management provides education, training and awareness for workers so that they are properly protected. It empowers them to look after their own safety and to report any issues up to senior management.

The outcome is that both senior management and workers recognise the dangers. Workers are empowered and supported by senior management to work safely and with confidence that their actions are correct.

4. How the marine industry’s stakeholders can protect their workers

This section focuses on the key shipping stakeholders who need effective asbestos risk management systems, looks at their potential responsibilities for safeguarding workers, and outlines our recommendations for managing the risks of asbestos exposure.

ShipownersThe 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 Officers, 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).

ShipyardsShipbuilders 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 specific terms of the contract with the shipowner.

Clearly labelled asbestos-containing materials – an example of good asbestos management


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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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Ship repair and conversion facilitiesShips coming into repair yards may well contain asbestos. The yard must perform some sort of risk assessment for each ship coming into the facility and have management procedures in place for cases when asbestos is suspected. We would recommend that yards assume every ship contains asbestos. Workers should know what items might contain asbestos and be able to respond accordingly. Certain workers carrying out high-risk tasks may benefit from special training. These might include boiler and steam pipe fitters, people installing insulation in the accommodation, or people renewing linings.

Ship recycling facilitiesA recycling facility is where ships are dismantled when they have reached the end of their life. Because recycling facilities commonly deal with older ships, they are certain to encounter asbestos. The IMO’s 2009 Hong Kong International Convention on the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention) contains guidelines for recycling facilities covering how to deal with asbestos and other hazards.

Owner membership bodiesOwner membership bodies such as ICS, BIMCO and Intertanko work hard to bring dangers and problems to their members’ attention in order to help them identify and solve them. In the case of asbestos, we believe that the SOLAS asbestos regulations and the asbestos-related elements of the Hong Kong Convention (such as the Inventory of Hazardous Materials) provide good opportunities for membership bodies to check whether everything possible is being done to protect against asbestos exposure.

Port authoritiesThe 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 flag states in the port authority’s 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 certificates, port authorities should have good reason to perform extended surveys: normally there is an accepted framework for establishing this.

Crew operators/crewing agentsCrew operators and crewing agents have a duty of care for the crew they provide to ships. We recommend that these organisations examine their responsibilities and liabilities, and the training, expertise and experience of their crews, to ensure that they are compatible with the types and ages of the ships they will be working on and the duties they will be expected to perform.

Ship managersAs 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 Convention’s 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.

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.


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materials to contain asbestos unless there are good reasons not to do so”.

This management plan is an excellent and internationally recognised way of managing asbestos and can be simply tailored to make it relevant to shipowners, as Figure 2 demonstrates. It can also be applied to fleet management.

5. Tools for achieving best practice in asbestos management

Record

No further action

Appoint personto ’manage’

asbestos

Record asbestosplan/drawing

Preparemanagement

plan

Carry outrisk assessment

Are ACMs liable to be disturbed?Who can be exposed?Prioritise

Find out if ACMspresent: checkplan/drawings

carry out survey

RECORDPrepare asbestos

register

Repair/removeMonitor Manage

• Train staff• Manage contractors• Checked all work against

plan/register• Control of work itself: – Asbestos essentials – Compliance with CAR

No

Yes

ACMs in good condition

Damaged ACMs

Maintenancework

Asbestos Management PlansFigure 1 is a land-based Asbestos Management Plan for ‘dutyholders’ who manage premises13 that may contain asbestos, taken from Asbestos: The Survey Guide, published by the Health and Safety Executive14. The Guide begins with a fundamental concept which is vitally important in managing asbestos risks: “Presume

13 Interestingly, under UK law, premises’ includes ships.

14 Available at http://www.hse.gov.uk/pubns/books/hsg264.htm

Figure 1: A typical land-based Asbestos Management Plan.


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Figure 2: The land-based Asbestos Management Plan adapted for maritime use.

Record. Maintainevidence and

decision makingsteps

Ensure effectivesystems in place toavoid purchasing

and installing ACMs

Monitor andreview

effectivenessof system

Appoint personto manageasbestos

Preparemanagement

plan

Find out if ACMs present:check plans and drawings.

Carry out samples and surveys,check procurement information

Identify ships in fleet to be

managed

Prepare asbestosregister (Inventory

of HazardousMaterials preferred)

Undertake riskassessment

Monitor ACMMeasure performance

Update recordsDocument

Review

PolicyProcedures

Objectives and targetsSafety provision

Maintenance workEquipment and PPE provisionImprove

procedures

TrainingAwareness

Procurement planAsbestos action

and work

Approved servicesupplier



Third partyverification

Implement effective management system


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A typical plan showing where asbestos is present on board a ship.


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How old is my ship: when was it built?

Have all the owners of the ship since newbuild maintained accurate, documented information to prove that an asbestos free

procurement programme has been followed?

Is there a reputable ’asbestos free’ certificate

(or a list of asbestos availablefrom the time of construction)

Is there a reputable ’asbestos free’ certificate

available

Did the country of buildlegally outlaw asbestos at the

time of build, or did thecontract specify ’asbestos free’

Have any large reputableasbestos registers been done?

(has a list of asbestosbeen provided?)

Note: you must follow the arrows directly down from the year of build unless an arrow takes you sideways.

Between 1 July, 2002 and

1 Jan, 2011

After 1 Jan, 2011

Before 1 July, 2002

High confidencethat ship is free ofasbestos (or thata known list of

asbestos is available)

Low confidencethat ship is

free ofasbestos

Noconfidencethat ship is

free ofasbestos

No

No

No

No

No

Yes

Yes

Yes

Yes Yes

Yes

Yes

Figure 3: Asbestos assessment

Carrying out an asbestos assessment for your shipFigure 3 is an asbestos assessment which allows you to determine the likelihood of asbestos being on board your ship. By performing additional checks and implementing management measures you can move to the right of the diagram and increase confidence in your ship’s asbestos status.


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A turbo-alternator with asbestos-lagged steam pipes


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Appendix – Common asbestos areas on board ships

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.

Before we get on board the ship – plan approvalA lot of information relating to asbestos will be contained in the ship’s plans. There may be statements that particular items are non-asbestos or details of substitute materials like rockwool.

Plan approval surveyors, designers, and owners of newbuild ships or repair yard superintendents should carefully check the plans of any item that might contain asbestos and ensure that a non-asbestos-containing material is specified. Plans are accompanied by, or include, material lists and material specifications. These should be checked in a similar way.

If asbestos substitutes are specified in the plans, it is vital that the site surveyor checks these materials have actually been used, both by inspecting the material and by checking packages and invoices. Rockwool packaging is commonly found strewn around the ship or shipyard, often in bins. Every good surveyor should spend time hunting around bins in yards, repair yards and on board ships.

Ap

pen

dix

– C

om

mo

n a

sbes

tos

area

s o

n b

oar

d s

hip

s

Close up of an asbestos blanket

Asbestos fire blanketsAsbestos fire 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 fibres which can be difficult 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 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.


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A newbuild (or repair) asbestos blanket protecting the area around a proposed weld

Asbestos blankets being used to protect oil tanks from flame and sparks

Deckheads and ceiling and wall panelsAsbestos was regularly specified for use in ships’ deckheads and panels because of its fire-resistant properties. Because of this, original A-60 or similar panels of a certain age will be almost guaranteed to contain asbestos. But the asbestos content of other ordinary panels is harder to predict. Because of the material’s great performance and low price, it was often used by panel manufacturers even when fire protection wasn’t specified. The only way to tell if ordinary panels contain asbestos is destructive examination.

All panels sourced from countries that still allow asbestos should be suspected of containing it. A quick internet search will show how easy it is to find asbestos boards for sale even today.

It is not only the panels that might contain asbestos – the glues, cements, putties, backing strips and shims used in their construction are also likely to contain it. The putties and adhesives are not likely to be friable. Cement may well be highly friable but should be underneath items which will protect it.

In general the danger from panels is low. It is very easy to see if a panel is damaged and light damage can be rectified very easily. Such work should normally be undertaken by specialist sub contractors. However, it can be carried out by suitably trained crew using emergency repair kits if the ships has a good asbestos management plan in place and legislation allows it. Training needs and repair methods should be included in the ship’s ISM manual and crew training and procedures documentation. This work should also be monitored by specialists at the arranged intervals.

Panels in good condition can be safely managed in situ or easily removed in one piece by specialist companies if the objective is to reduce the amount of asbestos on the ship.

An asbestos blanket used as pipe lagging


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Fire doors and surroundsFire doors have historically been made with asbestos because of its fire-retardant properties. The asbestos is commonly hidden in the core of the door. Modern doors would be expected to contain mineral wool, but if doors are sourced from countries that allow asbestos they should be suspected as containing it.

As you can see from the photograph below it is almost impossible to tell what a fire door is made of just by looking at its exterior. The photograph also shows that asbestos is normally well encapsulated within fire doors and can be managed safely in situ.

A typical bulkhead panel with the interior exposedThis is a typical sandwich board bulkhead panel found in accommodation blocks. The exterior is formica which is asbestos free. This encapsulates the asbestos-containing material in the middle. If the formica was undamaged the panel would not present a problem. But exposed like this, the friable asbestos will be easily disturbed.

Unrepaired damage like this is an example of poor asbestos management. It could be resealed with tape, adhesive or more formica.

Modern sandwich board panels are likely to contain rockwool. Once you are familiar with it, rockwool looks distinctly different from asbestos-containing material. However, in Lloyd’s Register, in common with other class societies, we do not train our surveyors to recognise unmarked rockwool as the risks of misidentification are very high.

Asbestos within a fire door

A damaged and friable asbestos millboard ceiling

A Portland cement ceiling which is not damaged or friable

It is very difficult to tell the difference between these two ceilings and both should be suspected as containing asbestos. But the key difference is that the first 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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Asbestos rope in a fire 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 fire door frame. Compare this to the asbestos-containing rope in the image above. It is impossible to tell by looking which one contains asbestos.

FloorsFloors 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.

To find out how much asbestos a floor 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 vinyl floor tiles and asbestos glueAsbestos floor tiles are very common, but even when damaged they are very unlikely to emit a dangerous level of fibres 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 modification 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 asbestos-free, 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 fire hazards or are toxic when burnt.

Asbestos-containing material in a cable penetration

Putties and sealants used in penetrationsMany putties and sealants were manufactured with asbestos, and they still are in some countries. Asbestos can also be added as a ‘bulking’ agent to an ‘asbestos free’ putty, glue or sealant, to alter its properties or make it go further. Older putties and sealants and those manufactured in countries still using asbestos must therefore be suspected of containing it. The good news is that provided they are not disturbed, and are not brittle or aged, they are likely to last for the life of the ship without becoming friable or causing a health hazard. In these cases we would encourage proper management in situ rather than removal, unless relevant legislation required it.

The substitute for asbestos in new putties and sealants is often silicon. Silicon actually outperforms asbestos in many areas, but can be a nuisance to work with.

Asbestos-containing putty in the ‘watertight’ penetrations of cables

A common use of asbestos putty on small fitments


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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 influence of the ship’s movements.

Asbestos rope being used as a sealant for exhaust uptakes

Asbestos lagging on the exhaust pipe of an emergency generator


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Asbestos insulation rope. This rope is highly friable and will contaminate the whole area, including the rockwool below it. Rockwool can easily ‘absorb’ asbestos waste fibres and so presents a danger even if it is manufactured without asbestos. In some ship recycling legislation, rockwool is mandatorily treated as asbestos-containing waste.

Pipe insulation, covers, ropes and insulated boardPipe insulation or lagging is one of the most common uses of asbestos, especially lagging used for high-temperature steam or heating pipes. These materials can be naturally quite friable and can be damaged easily, especially in a busy engine room, but they can be reasonably easily sealed in place with the right paints or adhesives. This needs to be managed carefully. In some cases, asbestos lagging is so friable that it must be totally encapsulated or removed.

Asbestos canvas

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.

Asbestos canvas. This is also used on cold water pipes to avoid condensation.


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Engine room stores – spare partsEngine room stores are some of the commonest areas for new asbestos to get on board ships. The problem is underlined by the IMO Circular, MSC.1/circ.1426. This recognises that it is almost impossible to guarantee that engine room stores do not contain asbestos, and therefore states that asbestos is allowed in engine room stores but that items containing it cannot actually be installed on board the ship.

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.

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 ship’s 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 flange 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.

It is common to find 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 find a freshly cut gasket, clearly labelled asbestos, sitting on the cutting bench in the machinery area.

Engine roomThe 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.

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 difficult. In these cases, properly stabilising the surface is highly recommended, Physical encapsulation is preferable to removal in cases where removal will cause unacceptable disturbance.


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Asbestos lagging


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Asbestos lagging

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March 2013

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asbestos in shipyards - identification, awareness, alternatives & removal

Engineering