EMSA issued a study on the two hazardous substances, PFOS
and HBCDD, included in the annexes of regulation (EU) 1257/2013 on ship
recycling, aiming to close knowledge gaps regarding requirements in EU Ship
Recycling regulation.
The EU Ship Recycling Regulation, that entered into force
on 30 December 2013, aims at facilitating early ratification of the Hong Kong
Convention 2009, both within the EU and in other countries, by applying
controls to ships and ship recycling facilities. It aims to ensure that vessels
are recycled in EU-approved facilities worldwide.
EU legislation sets additional requirements compared to
the Hong Kong Convention for the Inventory of Hazardous Materials (IHM), by
including the substances Perfluorooctane sulfonic acid (PFOS) and
Hexabromocyclododecane (HBCDD) in the list of hazardous substances.
PFOS
As explained, firefighting foam is expected to have the
highest concentration of PFOS and the most relevant material to analyse and
check for inclusion in the IHM Part I.
Protective coatings for fabrics such as carpets,
textiles, upholstery and electronics such as semiconductors not integral to
ship in operation, is also relevant, however falling out of scope with regards
to IHM Part I in general. Paint and coatings may be relevant but it is not
expected to find PFOS in paint and coatings because other surfactants are
probably used and it is not detected in paint in any samples looked at
(inventories in 21 ships).
For PFOS in firefighting foam, global, regional and
national legislation as well as shelf life need to be taken into consideration.
After 2010, PFOS containing firefighting foams is less
likely on board vessels at all, unless vessels built in China, where it at that
time and still is legal to produce and sell. Having in mind that the reporting
limit is set to 0,001%, incomplete emptying of tanks and hoses, previously
holding PFOS containing foam concentrate, may contaminate new non-PFOS
containing foam above the threshold level, hence sampling and analysis is
recommended.
Sampling should in general follow the EMSAS’s Best
practice guidance on the inventory of hazardous material (2016) and the IMO
resolution MEPC.269(68) Guidelines for inventory of hazardous material. Health,
safety and environmental (HSE) aspects during sampling should be focused on
proper ventilation, especially if working in confined spaces, use eye
protection and gloves and have available safety data sheets and eye wash
bottles.
The Basel Convention technical guidelines for the
environmentally sound management of wastes consisting of, containing or
contaminated with PFOS, its salts and PFOSF, list two methods for destruction
and irreversible transformation:
- Cement kiln co-incineration and
- Hazardous waste incineration.
Destruction and irreversible
transformation methods applicable for the environmentally sound disposal of
wastes with a content of PFOS, its salts or PFOSF at or above 50 mg/kg.
HBCDD
HBCDD in polystyrene foam (EPS and XPS) is the most
relevant area of use. HBCDD is found in textiles (carpets) in IHM’s and can be
found on board all vessels types and should in particular be considered in the
IHM Part I for insulation used in the walls and ceiling of cold provision
rooms.
Special attention is recommended to insulation on board
reefers, insulation in refrigerated containers and tank insulation of LPG, LEG
and LNG cargo tanks.
As for PFOS, sampling should in general follow the
EMSAS’s Best practice guidance on the inventory of hazardous material (2016)
and the IMO resolution MEPC.269(68) Guidelines for inventory of hazardous
material. Particular HSE aspects have not been identified for sampling, as the
most relevant is polystyrene foam.
No standards exist for analysis of HBCDD. Existing
standards used in IHMs is for brominated flame retardants in general and it is
uncertain to what extent these standards are quantitative for HBCDD, and they
cannot discriminate between the most common “types” of HBCDD.
As described for PFOS, the
same methods listed by Basel Convention are applicable to HBCDD as well.
Link of the study repot:
https://www.green4sea.com/wp-content/uploads/2017/11/EMSA-Study-on-the-two-hazardous-substances-PFOS-and-HBCDD-included-in-the-annexes-of-regulation-EU-1257.2013-on-ship-recycling-2017_11.pdf
Source: 22 November 2017
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