Appendix 5 - Example of the Development Process for Part I of the Inventory for Existing Ships
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Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee - Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials - Appendix 5 - Example of the Development Process for Part I of the Inventory for Existing Ships

Appendix 5 - Example of the Development Process for Part I of the Inventory for Existing Ships

 1 Introduction

1.1 In order to develop part I of the Inventory of Hazardous Materials for existing ships, documents of the individual ship as well as the knowledge and experience of specialist personnel (experts) is required. An example of the development process for Part I of the Inventory of Hazardous Materials for existing ships is useful to understand the basic steps as laid out in the guidelines and to ensure a unified application. However, attention should be paid to variations in different types of shipsfootnote.

1.2 Compilation of part I of the Inventory of Hazardous Material for existing ships involves the following five steps which are described in paragraph 4.2 and appendix 4 of these guidelines.
  • Step 1: Collection of necessary information;
  • Step 2: Assesment of collected information;
  • Step 3: Preparation of visual/sampling check plan;
  • Step 4: Onboard visual/sampling check; and
  • Step 5: Preparation of part 1 of the Inventory and related documentation

 2 Step 1 – Collection of Necessary Information

2.1 Sighting of available documents

A practical first step is to collect detailed documents for the ship. The shipowner should try to collate documents normally retained on board the ship or by the shipping company as well as relevant documents that the shipyard, manufacturers, or classification society may have. The following documents should be used when available:
  • .1 Ship's specification
  • .2 General Arrangement
  • .3 Machinery Arrangement
  • .4 Spare Parts and Tools List
  • .5 Piping Arrangement
  • .6 Accommodation Plan
  • .7 Fire Control Plan
  • .8 Fire Protection Plan
  • .9 Insulation Plan (Hull and Machinery)
  • .10 International Anti-Fouling System Certificate
  • .11 Related manuals and drawings
  • .12 Information from other inventories and/or sister or similar ships, machinery, equipment, materials and coatings
  • .13 Results of previous visual/sampling checks and other analysis

2.1.2 If the ship has undergone conversions or major repair work, it is necessary to identify as far as possible the modifications from the initial design and specification of the ship.

2.2 Indicative list

2.2.1 It is impossible to check all equipment, systems, and/or areas on board the ship to determine the presence or absence of hazardous materials. The total number of parts on board may exceed several thousand. In order to take a practical approach, an indicative list should be prepared that identifies the equipment, system, and/or area on board that is presumed to contain hazardous materials. Field interviews with the shipyard and suppliers may be necessary to prepare such lists. A typical example of an indicative list is shown below.

2.2.2 Materials to be checked and documented

Hazardous Materials, as identified in appendix 1 of these guidelines, should be listed in part I of the Inventory for existing ships. Appendix 1 of the guidelines contains all the materials concerned. Table A shows those which are required to be listed and table B shows those which should be listed as far as practicable

2.2.3 Materials listed in table A

2.2.3.1 Table A lists the following four materials:
  • .1 Asbestos
  • .2 Polychlorinated biphenyls (PCBs)
  • .3 Ozone depleting substances
  • .4 Anti-fouling systems containing organotin compounds as a biocide

2.2.3.2 Asbestos

Field interviews were conducted with over 200 Japanese shipyards and suppliers regarding the use of asbestos in production. Indicative lists for asbestos developed on the basis of this research are shown below:

Structure and/or equipment Component
Propeller shafting Packing with low pressure hydraulic piping flange
Packing with casing
Clutch
Brake lining
Synthetic stern tubes
Diesel engine Packing with piping flange
Lagging material for fuel pipe
Lagging material for exhaust 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 of steam line, exhaust line and drain line
Boiler Insulation in combustion chamber
Packing for casing door
Lagging material for exhaust pipe
Gasket for manhole
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 of steam line, exhaust line, fuel line and drain line
Exhaust gas economizer Packing for casing door
Packing with manhole
Packing with hand hole
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 of steam line, exhaust line, fuel line and drain line
Incinerator Packing for casing door
Packing with manhole
Packing with hand hole
Lagging material for exhaust pipe
Auxiliary machinery (pump, compressor, oil purifier, crane) Packing for casing door and valve
Gland packing
Brake lining
Heat exchanger Packing with casing
Gland packing for valve
Lagging material and insulation
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 tank, hot water, tank, condenser), other equipment (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
Thermal insulating materials
Fire shields/fire proofing
Space/duct insulation
Electrical cable materials
Brake linings
Floor tiles/deck underlay
Steam/water/vent flange gaskets
Adhesives/mastics/fillers
Sound damping
Moulded plastic products
Sealing putty
Shaft/valve packing
Electrical bulkhead penetration packing
Circuit breaker arc chutes
Pipe hanger inserts
Weld shop protectors/burn covers
Fire-fighting blankets/clothing/equipment
Concrete ballast

2.2.3.3Polychlorinated biphenyl (PCBs)

Worldwide restriction of PCBs began on 17 May 2004 as a result of the implementation of the Stockholm Convention, which aims to eliminate or restrict the production and use of persistent organic pollutants. In Japan, domestic control began in 1973, with the prohibition of all activities relating to the production, use and import of PCBs. Japanese suppliers can provide accurate information concerning their products. The indicative list of PCBs has been developed as shown below:

Equipment Component of equipment
Transformer Insulating oil
Condenser Insulating oil
Fuel heater Heating medium
Electric cable Covering, insulating tape
Lubricating oil  
Heat oil Thermometers, sensors, indicators
Rubber/felt gaskets  
Rubber hose  
Plastic foam insulation  
Thermal insulating materials  
Voltage regulators  
Switches/reclosers/bushings  
Electromagnets  
Adhesives/tapes  
Surface contamination of machinery  
Oil-based paint  
Caulking  
Rubber isolation mounts  
Pipe hangers  
Light ballasts (component within fluorescent light fixtures)  
Plasticizers  
Felt under septum plates on top of hull bottom  

2.2.3.4 Ozone depleting substances

The indicative list for ozone depleting substances is shown below. Ozone depleting substances have been controlled according to the Montreal Protocol and MARPOL Convention. Although almost all substances have been banned since 1996, HCFC can still be used until 2020.

Materials Component of equipment Period for use of ODS in Japan
CFCs (R11, R12) Refrigerant for refrigerators Until 1996
CFCs Urethane formed material Until 1996
Blowing agent for insulation of LNG carriers Until 1996
Halons Extinguishing agent Until 1996
Other fully halogenated CFCs The possibility of usage in ships is low Until 1996
Carbon tetrachloride The possibility of usage in ships is low Until 1996
1,1,1-Trichloroethane (methyl chloroform) The possibility of usage in ships is low Until 1996
HCFC (R22, R141b) Refrigerant for refrigerating machine It is possible to use it until 2020
HBFC The possibility of usage in ships is low Until 1996
Methyl bromide The possibility of usage in ships is low Until 1996

2.2.3.5 Organotin compounds

Organotin compounds include tributyl tins (TBT), triphenyl tins (TPT) and tributyl tin oxide (TBTO). Organotin compounds have been used as anti-fouling paint on ships' bottoms and the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention) stipulates that all ships shall not apply or re-apply organotin compounds after 1 January 2003, and that, after 1 January 2008, all ships shall either not bear such compounds on their hulls or shall bear a coating that forms a barrier preventing such compounds from leaching into the sea. The above-mentioned dates may have been extended by permission of the Administration bearing in mind that the AFS Convention entered into force on 17 September 2008.

2.2.4 Materials listed in table B

For existing ships it is not obligatory for materials listed in table B to be listed in part I of the Inventory. However, if they can be identified in a practical way, they should be listed in the Inventory, because the information will be used to support ship recycling processes. The Indicative list of materials listed in table B is shown below:

Materials Component of equipment
Cadmium and cadmium compounds Plating film, bearing
Hexavalent chromium compounds Plating film
Mercury and mercury compounds Fluorescent light, mercury lamp, mercury cell, liquid-level switch, gyro compass, thermometer, measuring tool, manganese cell, pressure sensors, light fittings, electrical switches, fire detectors
Lead and lead compounds Corrosion resistant primer, solder (almost all electric appliances contain solder), paints, preservative coatings, cable insulation, lead ballast, generators
Polybrominated biphenyls (PBBs) Non-flammable plastics
Polybrominated diphenyl ethers (PBDE) Non-flammable plastics
Polychlorinated naphthalenes Paint, lubricating oil
Radioactive substances Refer to appendix 10
Certain shortchain chlorinated paraffins Non-flammable plastics

 3 Step 2 – Assessment of Collected Information

Preparation of a checklist is an efficient method for developing the Inventory for existing ships in order to clarify the results of each step. Based on collected information including the indicative list mentioned in step 1, all equipment, systems, and/or areas on board assumed to contain hazardous materials listed in tables A and B should be included in the checklist. Each listed equipment, system, and/or area on board should be analysed and assessed for its hazardous materials content.

The existence and volume of hazardous materials may be judged and calculated from the Spare parts and tools list and the maker's drawings. The existence of asbestos contained in floors, ceilings and walls may be identified from Fire Protection Plans, while the existence of TBT in coatings can be identified from the International Anti-Fouling System Certificate, Coating scheme and the History of Paint.

Example of weight calculation

No. Hazardous Materials Location/equipment/ component Reference Calculation
1.1-2 TBT Flat bottom/paint History of coatings  
1.2-1 Asbestos Main engine/ exh. pipe packing Spare parts and tools list 250 g x 14 sheet = 3.50 kg
1.2-3 HCFC Ref. provision plant Maker's drawings 20 kg x 1 cylinder = 20 kg
1.2-4 Lead Batteries Maker's drawings 6kg x 16 unit = 96 kg
1.3-1 Asbestos Engine-room ceiling Accommodation plan  

When a component or coating is determined to contain hazardous materials, a "Y" should be entered in the column for "Result of document analysis" in the checklist, to denote "Contained". Likewise, when an item is determined not to contain Hazardous Materials, the entry "N" should be made in the column to denote "Not contained". When a determination cannot be made as to the hazardous materials content, the column should be completed with the entry "Unknown".

Checklist (step 2)

Analysis and defintion of the scope of assessment for "Sample Ship"

 4 Step 3 – Preparation of Visual/Sampling Check Plan

4.1 Each item classified as "Contained" or "Not contained" in step 2 should be subjected to a visual check on board, and the entry "V" should be made in the "Check procedure" column to denote "Visual check".

4.2 For each item categorized as "unknown", a decision should be made as to whether to apply a sampling check. However, any item categorized as "unknown" may be classed as "potentially containing hazardous material" provided comprehensive justification is given, or if it can be assumed that there will be little or no effect on disassembly as a unit and later ship recycling and disposal operations. For example, in the following checklist, in order to carry out a sampling check for "Packing with aux. boiler" the shipowner needs to disassemble the auxiliary boiler in a repair yard. The costs of this check are significantly higher than the later disposal costs at a ship recycling facility. In this case, therefore, the classification as "potentially containing hazardous material" is justifiable.

Checklist (step 3)

Analysis and definition of scope of assessment for "Sample Ship"

4.3 Before any visual/sampling check on board is conducted, a "visual/sampling check plan" should be prepared. An example of such a plan is shown below.

4.4 To prevent any incidents during the visual/sampling check, a schedule should be established to eliminate interference with other ongoing work on board. To prevent potential exposure to Hazardous Materials during the visual/sampling check, safety precautions should be in place on board. For example, sampling of potential asbestos containing materials could release fibres into the atmosphere. Therefore, appropriate personnel safety and containment procedures should be implemented prior to sampling.

4.5 Items listed in the visual/sampling check should be arranged in sequence so that the onboard check is conducted in a structured manner (e.g. from a lower level to an upper level and from a fore part to an aft part).

Example of visual/sampling check plan
Nmae of ship XXXXXXXXXX
IMO Number XXXXXXXXXX
Gross Tonnage 28,000 GT
L x B x D xxx.xx × xx.xx × xx.xx m
Date of delivery dd.mm.1987
Shipowner XXXXXXXXXX
  • Contact point
  • (Address, Telephone, Fax, Email )
  • XXXXXXXXXX
  • Tel: XXXX-XXXX
  • Fax: XXXX-XXXX
  • Email: abcdefg@hijk.co.net
Check schedule
  • Visual check: dd, mm, 20XX
  • Sampling check: dd, mm, 20XX
Site of check XX shipyard, No. Dock
In charge of check XXXX XXXX
Check engineer XXXX XXXX, YYYY YYYY, ZZZZ ZZZZ
Sampling engineer Person with specialized knowledge of sampling
Sampling method and anti-scattering measure for asbestos Wet the sampling location prior to cutting and allow it to harden after cutting to prevent scatter. Notes: Workers performing sampling activities shall wear protective equipment.
Sampling of fragments of paints Paints suspected to contain TBT should be collected and analysed from load line, directly under bilge keel and flat bottom near amidships.
Laboratory QQQQ QQQQ
Chemical analysis method Method by ISO/DIS 22262-1 Bulk materials – Part 1: Sampling and qualitative determination of asbestos in commercial bulk materials and ISO/CD 22262-2 Bulk materials – Part 2: Quantitative determination of asbestos by gravimetric and microscopic methods. ICP Luminous analysis (TBT)
Location of visual/sampling check Refer to lists for visual/sampling check
Listing for equipment, system and/or area for visual check
See attached "Analysis and definition of scope of investigation for sample ship"
List of equipment, system and/or area for sampling check
Location Equipment, machinery and/or zone Name of parts Materials Result of doc. checking
Upper Deck Back deck ceilings Engine-room ceiling Asbestos Unknown
Engine-room Exhaust gas pipe Insulation Asbestos Unknown
Engine-room Pipe/flange Gasket Asbestos Unknown
         
Refer to attached "Analysis and definition of scope of investigation for sample ship" and "Location plan of hazardous materials for sample ship"
List of equipment, system and/or area classed as PCHM
Location Equipment, machinery and/or zone Name of part Material Result of doc. checking
Floor Propeller cap Gasket Asbestos PCHM
Engine-room Air operated shut-off valve Gland packing Asbestos PCHM
         
Refer to attached "Analysis and definition of scope of investigation for sample ship" and "Location plan of hazardous materials for sample ship"

This plan is established in accordance with the guidelines for the development of the Inventory of Hazardous Materials

Prepared by: XXXX XXXX
Tel.: YYYY-YYYY
Email: XXXX@ZZZZ.co.net

・Document check・date/place:

dd, mm, 20XX at XX Lines Co. Ltd.

・Preparation date of plan:dd. mm, 20XX

 5 Step 4 – Onboard Visual/Sampling Check

5.1 The visual/sampling check should be conducted according to the plan. Check points should be marked in the ship's plan or recorded with photographs.

5.2 A person taking samples should be protected by the appropriate safety equipment relevant to the suspected type of hazardous materials encountered. Appropriate safety precautions should also be in place for passengers, crewmembers and other persons on board, to minimize the potential exposure to hazardous materials. Safety precautions could include the posting of signs or other verbal or written notification for personnel to avoid such areas during sampling. The personnel taking samples should ensure compliance with relevant national regulations.

5.3 The results of visual/sampling checks should be recorded in the checklist. Any equipment, systems and/or areas of the ship that cannot be accessed for checks should be classified as "potentially containing hazardous material". In this case, the entry in the "Result of check" column should be "PCHM".

 6 Step 5 – Preparation of Part I of the Inventory and Related Documentation

6.1 Development of part I of the Inventory

The results of the check and the estimated quantity of hazardous materials should be recorded on the checklist. Part I of the Inventory should be developed with reference to the checklist

6.2 Development of location diagram of hazardous materials

With respect to part I of the Inventory, the development of a location diagram of hazardous materials is recommended in order to help the ship recycling facility gain a visual understanding of the Inventory.

Checklist (step 4 and step 5)

Analysis and definition of scope of assessment for "Sample Ship"

Example of the Inventory for existing ships

Inventory of Hazardous Materials for "Sample Ship"

Particulars of the "Sample Ship"

Distinctive number or letters XXXXNNN
Port of registry Port of World
Type of vessel Bulk carrier
Gross Tonnage 28,000 GT
IMO number NNNNNNN
Name of shipbuilder xx Shipbuilding Co. Ltd
Name of shipowner yy Maritime SA
Date of delivery MM/DD/1988

This inventory was developed in accordance with the guidelines for the development of the Inventory of Hazardous Materials.

Attachment:
  • 1: Inventory of Hazardous Materials
  • 2: Assessment of collected information
  • 3: Location diagram of Hazardous Materials

Prepared by XYZ (Name & address) (dd/mm/20XX)

Inventory of Hazardous Materials: "Sample Ship"

Part I – hazardous materials contained in the ship's structure and equipment

I-1 Paints and coating systems containing materials listed in Table A and Table B of appendix 1 of the guidelines

No. Application of paint Name of paint Location* Materials (classification in appendix 1) Approximate quantity Remarks
1 AF paint Unknown paints Flat bottom TBT 60.00 kg Confirmed by sampling
2              
3              

I-2 Equipment and machinery containing materials listed in Table A and Table B of appendix 1 of the guidelines

No. Name of equipment and machinery Location *1 Materials (classification in appendix 1) Parts where used Approximate quantity Remarks
1 Main engine Lower floor Asbestos Exh. pipe packing 3.50 kg  
2 Aux. boiler 3rd deck Asbestos Unknown packing 10.00 kg PCHM (potentially containing Hazardous Material)
3 Piping/flange Engine-room Asbestos Packing 50.00 kg PCHM
4 Ref. provision plant 2nd deck HCFC Refrigerant (R22) 20.00 kg  
5 Batteries Navig. Bridge deck Lead   96.00 kg  
               

I-3 Structure and hull containing materials listed in Table A and Table B of appendix 1 of the guidelines

No. Name of structural element Location *1 Materials (classification in appendix 1) Parts where used Approximate quantity Remarks
1 Back deck ceiling Upper deck Asbestos Engine-room ceiling (A class) 3.80 kg Confirmed by sampling
2              
3              

* Each item should be entered in order based on its location, from a lower level to an upper level and from a fore part to an aft part.

Example of location diagram of hazardous materials


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