The presence of asbestos on ships remains a significant concern in the maritime industry, despite regulations banning its use since 2002. Lucion's Marine & Offshore Principal Consultant, Kevan O'Neill, explores the critical role of Inventory of Hazardous Materials (IHM) surveys in detecting asbestos on ships and provides essential guidance for ship owners, in light of the Hong Kong Convention (HKC) entering into force in June 2025.
The Importance of IHM Surveys in Detecting Asbestos on Ships
An Inventory of Hazardous Materials (IHM) survey is a crucial first step in identifying asbestos on ships. However, it’s important to note that an IHM survey provides only a representative sample. A typical IHM survey might involve 40 to 100 asbestos test samples, compared to 100-400 samples in a comprehensive ship asbestos survey.
What should you do if you discover asbestos
- Conduct a detailed asbestos survey to determine the full extent of asbestos presence.
- Investigate similar systems and materials where asbestos was initially found.
- Consult with class and flag state authorities to determine the best course of action (management or removal).
Persistent Asbestos Issues in Modern Shipbuilding
Despite the 2002 ban, asbestos is still found in over 60% of ships, including new builds. This persistence is often due to:
- Varying international standards for “asbestos-free” materials
- Lack of testing and certification by manufacturers
- Global supply chain complexities, particularly with materials originating from countries where asbestos use is still legal
Regulatory Enforcement and Compliance
While many flag states accept shipyard declarations of “asbestos-free” status, some authorities, like Australia and the Netherlands, require verification surveys by accredited companies. Ship owners should be aware of these stricter requirements and consider proactive measures to ensure compliance.
June 2025 IHM HKC Entry Into Force
A significant development in maritime regulations is the upcoming Hong Kong Convention coming into force in June 2025. This significant date marks the start of 5 years whereby ship owners must comply with the HCK by June 2030.
Key points about the IHM compliance requirements:
- Scope: Applies to all ships of 500 GT and above calling at ports or anchorages
- Requirements: Ships must carry on board a valid IHM certificate or statement of compliance
- Implementation: Gradual approach, with the final deadline set for June 2030 providing 5 years in which ship owners must comply
- Consequences: Non-compliant ships may face penalties, detentions, or be denied entry to ports
Ship owners and operators should start preparing well in advance of this deadline to ensure compliance and avoid potential operational disruptions.
Where can you find Asbestos on Ships
Common areas where asbestos is found include ship whistles, gasket materials, pipe hangers, incinerators, boilers, deck compositions, and ship stores.
Some ship owners are reluctant to conduct IHM surveys due to potential complications if asbestos is found. However, there’s a duty of care to crew and workers, making specialist surveys crucial for safety and compliance. The upcoming entry into force in June this year adds urgency to this matter.
Asbestos On Ships – A Global Problem
Asbestos on ships is not limited to vessels built in specific regions. Even European-built ships have been found to contain asbestos in certain components.
The EU Inventory of Hazardous Materials (IHM) directive, implemented in December 2020, requires all EU ships to have an IHM. This regulation aims to protect workers involved in ship recycling and improve overall maritime safety. The June 2025 entry into force and the deadline of 2030 for compliance, further reinforces these requirements.
Ensuring Asbestos-Free Ships
To mitigate the risks of asbestos on ships and prepare for the deadline, owners should:
- Commission surveys by approved companies
- Remove any identified asbestos
- Implement quality management systems for periodic material testing
- Conduct updated surveys after refits
- Develop a timeline for IHM compliance well before the June 2030 deadline
Benefits of Proactive Asbestos Management:
- Reduced litigation risk from crew exposure claims
- Unrestricted global operations, including access to ports
- Enhanced ship value
- Improved safety for crew and workers
- Compliance with current and upcoming regulations
As the maritime industry continues to grapple with the challenges of asbestos on ships, comprehensive Inventory of Hazardous Materials (IHM) surveys and proactive management strategies are essential. The approaching June entry into force and 2030 deadline for IHM compliance adds urgency to these efforts. By prioritising these measures now, ship owners can ensure regulatory compliance, protect their crew, maintain the value and operational efficiency of their vessels, and avoid potential penalties or operational disruptions in EU waters.
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