Asbestos in Shipyards - Identification, Awareness, Alternatives & Removal

Asbestos on ships
How to manage it safely

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Asbestos on ships – how to manage it safely
1
Contents

Foreword 3
Part 1 – A history of asbestos 4
1 What is asbestos 4
2 The rise of asbestos 7
3 Health and regulation 10
4 Testing for asbestos 14
Part 2 – Asbestos on board ships 17
1 The increased risk in shipping 17
2 Where is asbestos found on ships 18
3 Regulation 21
4 How the marine industry’s stakeholders
can protect their workers 27
5 Tools for achieving best practice
in management 30
Appendix – Common asbestos areas
on board ships 36

2

3
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 Townsend
Regulatory 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.html
2
U.S. Geological Survey (USGS) (2013). Asbestos Statistics and Information.
Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/#pubs (Accessed: March 11, 2013)

4
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 groups
Asbestos 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
Part1–Ahistoryofasbestos
Asbestosfamily
Type Name CAS Number Relative use in
A: shipbuilding
B: other industries
C: total use today
Relative danger
A: mesothelioma
B: lung cancer
Actinolite
Amphibole
(five types)
Short, sharp fibres
77536-66-4
A: Low
B: Low
C: 0
Amosite
(grunerite) (brown)
12172-73-5
A: Medium
B: Low
C: 0
A: 100
B: 10-50
Anthophyllite 77536-67-5
A: Low
B: Low
C: 0
Crocidolite (blue) 12001-28-4
A: Medium
B: Low
C: 0
A: 500
B: 10-50
Tremolite
Chrysotile
Amphibole
(serpentine
one type)
Long, curly fibres
77536-68-6
A: Low
B: Low
C: 0
12001-29-5
A: high
B: high
C: 100
A: 1
B: 1
The big three: blue, brown and white
The 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/

5
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.

6
Other asbestos types
Actinolite
Actinolite 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.
Tremolite
Tremolite 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.
Anthophyllite
Anthophyllite 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 substances
This 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/66/8/535
7
Xiaorong Wang et al (2011). A 37-year observation of mortality in Chinese white asbestos workers. Thorax, Volume 67, Issue 2.
Available at http://thorax.bmj.com/content/67/2/106.abstract
8
Antti Tossavainen et al (2001). Amphibole fibres in chinese chrysotile asbestos. The Annals Of Occupational Hygiene, Volume 45, Issue 2.
Available at http://annhyg.oxfordjournals.org/content/45/2/145.abstract?sid=26e21abb-5ce8-4c60-a9fd-4be5a6cc711b
9
Murray M. Finkelstein and Andre Dufresne (1999). Inferences on the kinetics of asbestos deposition and clearance among chrysotile miners and
millers. American Journal of Industrial Medicine, Volume 35, Issue 4.
Available at http://onlinelibrary.wiley.com/doi/10.1002/(SICI)1097-0274(199904)35:4%3C401::AID-AJIM12%3E3.0.CO;2-4/abstract
10
R.L. Virta (2006). Worldwide asbestos supply and consumption trends from 1900 through 2003: USGS Circular 1298.
A closer look at chrysotile asbestos contamination
Chrysotile 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
.

7
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-history
Evidence 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 uses
In 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 mines
Asbestos 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 age
Modern asbestos mining in industrialised nations
began expending rapidly from the late 1800s, probably
due to steam technology. Vast chrysotile asbestos
reserves were discovered in 1877 at Danville in Quebec,
Canada, and have been mined until very recently
(see case study overleaf).
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.)

8
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 usage
By 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 decline
The 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.
12
R.L.. Virta (2011). USGS 2011 Minerals Yearbook – Asbestos.
Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/myb1-2011-asbes.pdf
13
CBC (2011). Asbestos mining stops for first time in 130 years.
Available at http://www.cbc.ca/news/canada/story/2011/11/24/asbestos-shutdown.html (Accessed 13 March, 2012)
14
Report of the Conference of the Parties to the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous
Chemicals and Pesticides in International Trade on the Work of its Fifth Meeting (2011).
Available at http://www.pic.int/TheConvention/ConferenceoftheParties/Meetingsanddocuments/COP5/tabid/1400/language/en-US/Default.aspx
15
Source: USGS Asbestos Mineral Commodity Summaries 2012 and 2013.
Available at http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/mcs-2012-asbes.pdf and
http://minerals.usgs.gov/minerals/pubs/commodity/asbestos/mcs-2013-asbes.pdf
Table 2: Recent global production of asbestos15
e = estimated
Country 2010 2011 2012e
Brazil
Canada
China
Kazakhstan
Russia
Others
Total
270,000 302,000 300,000
100,000 50,000 –
400,000 440,000 440,000
214,000 223,000 240,000
1,000,000 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.

9
The Black Lake asbestos
mines in Quebec, Canada

10
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 disease
The 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 regulation
These 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 cancer
So 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 ignored
In 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)

11
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 diseases
Asbestos 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.
Asbestosis
The 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 India
In 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)

12
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.
Mesothelioma
Mesothelioma 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 cancer
Because 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 diseases
There 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)

13
“One fibre can kill” – evaluating the real risk
The 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.pdf
23
Alison D. Mc.Donald and J. Corbett McDonald (1978). Mesothelioma after crocidolite exposure during gas mask manufacture.
Environmental Research, Volume 17, Issue 3. Available at http://www.sciencedirect.com/science/article/pii/0013935178900385
24
A.W. Musk et al (2007). Mortality of former crocidolite (blue asbestos) miners and millers at Wittenoom. Occupational Environmental
Medicine Volume 65, Issue 8. Available at http://oem.bmj.com/content/65/8/541
25
J.M. Talent et al (1980). A survey of black mineworkers of the Cape crocidolite mines. Biological Effects of Mineral Fibre 2.
26
E.D. Acheson et al (1982). Mortality of two groups of women who manufactured gas masks from chrysotile and crocidolite asbestos – a 40
year follow up. British Journal of Industrial Medicine, Volume 39. Available at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1009064/

14
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

15
Test type What does it do? Good for Speed Level of fibre
identification
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

16
A steam plant
containing asbestos

17
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
.
Part2–Asbestosonboardships
Friability – a vital consideration
The 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

18
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).

19
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

20
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.

21
3. Regulation
The SOLAS Convention
The 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 SOLAS
Flag 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 Code
All SOLAS Convention ships must comply with the
International Safety Management (ISM) Code. This
requires companies to identify safety risks, including
asbestos risks.
ISO standards
The 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.

22
Focus on existing ships
Under 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, 2002
Ships 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, 2002
Ships 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.

23
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

24
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

25
Specialist asbestos expertise
When 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 servicing
Recently, 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 newbuilds
For 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 newbuilds
In 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

26
The importance of supply chain checks: asbestos in
baby talcum powder
In 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 plates
Steel 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

27
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.
Shipowners
The 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 PI).
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).
Shipyards
Shipbuilders 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

28
Asbestos protection during ship recycling. The blue pipes contain asbestos and have therefore been wrapped
in protective blue plastic. The white uptake (on the left) was presumed to contain asbestos and marked ‘a’. Testing
revealed it was clear of asbestos and so the ‘a’ has been crossed out. (Photo courtesy of Leyal Ship Recycling.)
28

29
Ship repair and conversion facilities
Ships 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 facilities
A 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 bodies
Owner 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 authorities
The 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 agents
Crew 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 managers
As 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.

30
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 person
to ’manage’
asbestos
Record asbestos
plan/drawing
Prepare
management
plan
Carry out
risk assessment
Are ACMs liable to be disturbed?
Who can be exposed?
Prioritise
Find out if ACMs
present: check
plan/drawings
carry out survey
RECORD
Prepare 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
Maintenance
work
Asbestos Management Plans
Figure 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.

31
Figure 2: The land-based Asbestos Management Plan adapted for maritime use.
Record. Maintain
evidence and
decision making
steps
Ensure effective
systems in place to
avoid purchasing
and installing ACMs
Monitor and
review
effectiveness
of system
Appoint person
to manage
asbestos
Prepare
management
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 asbestos
register (Inventory
of Hazardous
Materials preferred)
Undertake risk
assessment
Monitor ACM
Measure performance
Update records
Document
Review
Policy
Procedures
Objectives and targets
Safety provision
Maintenance work
Equipment and
PPE provisionImprove
procedures
Training
Awareness
Procurement plan
Asbestos action
and work
Approved service
supplier
Approved service
supplier
Approved service
supplier
Third party
verification
Implement effective management system

32
A typical plan showing where asbestos is present on board a ship.

33
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 available
from the time of construction)
Is there a reputable
’asbestos free’ certificate
available
Did the country of build
legally outlaw asbestos at the
time of build, or did the
contract specify ’asbestos free’
Have any large reputable
asbestos registers been done?
(has a list of asbestos
been 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 confidence
that ship is free of
asbestos (or that
a known list of
asbestos is available)
Low
confidence
that ship is
free of
asbestos
No
confidence
that ship is
free of
asbestos
No
No
No
No
No
Yes
Yes
Yes
Yes Yes
Yes
Yes
Figure 3: Asbestos assessment
Carrying out an asbestos assessment for
your ship
Figure 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.

34
A turbo-alternator with
asbestos-lagged steam pipes

35

36
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 approval
A 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.
Appendix–Commonasbestosareasonboardships
Close up of an asbestos blanket
Asbestos fire blankets
Asbestos 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.

37
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 panels
Asbestos 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

38
Fire doors and surrounds
Fire 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 exposed
This 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.

39
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.
Floors
Floors present particular problems because they are
often multi-layered and any or all of these layers might
contain asbestos. An A-60 floor, for example, might
contain a bottom levelling layer (so that the fire layer
can be accurately applied); several centimetres of ‘fire
proof cement’; a levelling compound; an adhesive;
and a fire-proof tile or carpet. Even within one layer,
asbestos content may vary widely. This is particularly
true of cement, where several different mixes may have
been used to complete the same floor.
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 glue
Asbestos 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.

40
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 penetrations
Many 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

41
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

42
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 board
Pipe 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.

43
Engine room stores – spare parts
Engine 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 room
The engine room store examples show that you
are likely to find asbestos in the engine room itself.
Any asbestos there is prone to damage due to the
operations taking place and the heat, humidity
and vibration.
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.

44
Asbestos lagging

45

Lloyd’s Register EMEA
T +44 (0)20 7709 9166
F +44 (0)20 7423 2057
E emea@lr.org
71 Fenchurch Street
London EC3M 4BS
UK
Lloyd’s Register Asia
T +852 2287 9333
F +852 2526 2921
E asia@lr.org
Suite 3501
China Merchants Tower
Shun Tak Centre
168–200 Connaught Road Central
Hong Kong
SAR of PRC
Lloyd’s Register Americas, Inc.
T +1 (1)281 675 3100
F +1 (1)281 675 3139
E americas@lr.org
1401 Enclave Parkway
Suite 200
Houston
Texas 77077
USA
www.lr.org
March 2013
Lloyd’s Register is a trading name of Lloyd’s Register Group Limited
and its subsidiaries. For further details please see www.lr.org/entities

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