SQEMS OPERATING PROCEDURE OP-TEC-08 1 of 6 References: Manual Chap. 1; 6 1. SCOPE The present Operating procedures scope is to provide guidelines to Company office personnel and company ship s crew, on the implementation of the SOLAS II-1, regulation 3-5 and MSC.1/Circ. 1379 aimed at preventing the use of materials containing asbestos in new ships construction and supply to existing ships. 2. RESPONSIBILITY Fleet Director To arrange for the Company SQEMS coverage of the required evidence and documentation relevant to the implementation of the regulations in caption by Company offices and ships; To provide timely updates of the SQEMS and information relevant to changes of the same as well as new national and flag state regulations dealing with asbestos on board of ships; To arrange for newbuilding and conversion shipyards where Premuda Group s newbuildings keel laying occurred after 1 st July 2012 and/or conversion contracts were placed after 1 st July 2013, that the proper declaration and evidences of materials supply used for the construction/conversion of the vessels are asbestos free are issued by the Shipyards and delivered to the Company together with the vessel documents; To provide the necessary guidelines and Working Instructions to the Company Technical and Purchasing Office on the evidence that all materials (Spares, stores etc.) purchased for new and existing Company ships in service are asbestos free. Technical Dept. Mgr. To make sure the current operating procedure is implemented by the technical office personnel and Company ships commands; To instruct and verify that Ship Superintendents report to him and FD on any non compliance with the currents operating procedure found on board of Company ships and at office; To instruct and make sure that shiprepair/conversion shipyards provide the proper evidence and documentation to confirm all materials used on board of Company ships during repair/conversion works by themselves and by their subcontractors are asbestos free. The same are to be provided as per required declarations forms and issued to the Company before vessel departure for the Shipyard. To report to the Fleet Director about any misinterpretation or non compliance with the present operating procedure; To provide all required Company and shipyards declarations confirming supply of asbestos free materials, spares and stores on board of Company vessels, are issued as required for class check at every annual Safety Equipment and annual Safety Construction surveys. Purchasing manager To instruct Purchasing Dept personnel regarding the implementation of the present Operating procedure and other Company documents related to, for the relevant part applicable to the Purchasing Office; To contact all supplliers of materials, stores and spares that might contain asbestos, in order to get their confirmation their supplied goods are all asbestos free. To get their confirmation all materials, spares and stores supplied to Company vessesl since June 2013 can be provided with a makers declaration the same are asbestos free; To provide all suppliers of materials spares and stores materials that might contain asbestos with a Asbestos free declaration form facsimile; To keep evidence as dedicated electronic files of all orders of materials, spares and stores that require the asbestos free makers declaration together with a copy of the declarations themselves. Prepared by: Reviewed by: Approved by: TECH Dept. Fleet Director General Manager Distribution: to all managed vessels
2 of 6 To delete from the Company s suppliers lists with immediate effect all suppliers not complying with the present procedure and/or supplying materials containing asbestos. SQE Dept. To provide Company vessels command with a dedicated SQEMS file for keeping records of all orders of materials that have been provided with the asbestos free declaration and a copy of the same; Appointed Internal Auditors are responsible to control and monitor the documentation relative to the presence of asbestos on board, as applicable from Company ships as well as control the procedures for the management of asbestos free materials, spares and store to be supplied on board of Company vessels. Ships master To verify that for all materials, spares and stores that mighth contain asbestos that have been received on board, thre relevant makers asbestos free declaration has been received as well. To immediately inform the purchasing office in case the asbestos free makers declarations have not been received; To verify that copies of all packing lists for supplies of materials, spares and stores received on board together with their asbestos free declarations are properly filed in the relevant SQEMS Asbestos free materials declarations file; 3. PROCEDURE 3.1 General Solas II-1, Regulation 3-5 requires that from 1 January 2011 for all ships either newbuilding and existing at the same date, any new installation of materials containing asbestos is forbidden. In order to clarify the precise meaning of of the Solas regulation application referred to new and existing ships, both IMO and IACS (International Association of Classfication Societies) have edited circulars and Unified Interpretations respectitvely, providing as well a list of the required documentation to be issued by each Shipping company/managers for each ship, to be revised and checked by the attending class and/or RO surveyor attending the vessels on account of the annual Safety Construction and Safety Equipment surveys. The present Operating Instruction is therefore based on and consistently complies with the following IMO and IACS circulars and Unified Interpretations: MSC.1/Circ. 1379 dated 8 th December 2010 IACS UI SC 249 Rev 1 dated 1 st April 2012 MSC.1 Circ. 1426 dated 13 th June 2012 MEPC.197(62) dated 15 th July 2011 3.1 Action In order to comply with the SOLAS II-1, Regulation 3-5 and MSC.1/Circ 1379, the Company is required to provide evidence that materials containing asbestos have not been installed on board of her ships according to the following scheme: A) New buildings for which the keel has been laid on or after 1 st July 2012; B) Converted ships the contract of which has been placed on or after 1 st July 2012; C) All existing ships during dry dock and repair work; maintenance and overhaul works as of 1 st July 2012; D) For all existing ships as well all materials, stores and spares supplied by the company to her ships as of 1 st July 2012 must be asbestos free. Detailed action plan is as follows: Cases A) and B): the Fleet Director and/or technical manager in charge of the Company Newbuilding and/or conversion project management will make sure provisions of contract or separate agreement with the new-building and/or conversion shipyard will include obligations for the shipyard to issue to the Company, upon works completion/vessel delivery, the following documents:
3 of 6 1) A declaration by the Shipyard stating only and exclusively asbestos free materials have been installed on the ship during her construction and/or conversion. 2) Declarations from Shipyard s subcontractors, suppliers and any other third party having been involved in the construction of the ship, as necessary, stating their supplied materials are all asbestos free. Dedicated annexes for the above declarations, as reference, are available (Annex 1 and 3 of IACS REC.130). The Class or Vessel Flag Administration Recognised Organization (RO) will not issue any statement or certificate for compliance with SOLAS II-1; regulation 3-5, anyway their representatives will have to check the above documentation on issuing of all other class certificates. The above declarations (Annex 1 & 3) will have to be collected an filed together into dedicated SQEMS File and kept ready for class and/or PSC or vessel flag authority whenever required. A copy of the documents will have to be filed at Company office in dedicated sections of the SQEMS file containing all asbestos free declarations documents as well. Case C): the Company Technical manager and/or Ship superintendent in charge of the dry dock/repair works management will make sure that dry dock/repair contract signed with the shipyard will include the obligation for the shipyard to issue the following documents upon completion of the works: 1) A declaration by the shipyard stating only and exclusively asbestos free materials have been installed on the ship during her dry dock and repair works. 2) Declarations from Shipyard s subcontractors, suppliers and any other third party having been involved in the dry dock, repair, overhaul and renewal works carried out on any part or equipment of the ship, as necessary, stating their supplied materials are all asbestos free. The class or Recognised Organization will not issue any statement or certificate for compliance with SOLAS II-1, regulation 3-5 for existing ship, anyway they will have to check above documentation on issuing/endorsing the Safety Construction and Safety Equipment certificates. The above documents will have to be collected and filed on board of Company vessels in a dedicated Company file named: Asbestos free materials declarations in specific section relevant to Dry Dock, repair and overhaul works declarations by shipyards and subcontractors. The file is to be kept ready for class and/or PSC or vessel flag authority whenever required. A copy of the documents will have to be filed at Company into dedicated sections of the SQEMS file containing all asbestos free declarations documents as well. Case D): the Company is required to keep record and evidence that all materials, spares and stores directly supplied to the vessels or purchased through subcontractors that fall into specific categories and types of materials that might contain asbestos, are free from asbestos and are provided with a makers or suppliers declaration confirming the same are asbestos free. The purchasing department will follow a dedicated working instruction as set forth in the Company dedicated WIN, for the purchase and supply of such materials to the Company ships. The following table, taken from MSC.1/Circ.1426 provides a quick reference of all ships machinery, system and installations components the materials they are made of or can contain asbestos; it is to be taken as a quick reference when ordering/supplying materials, spares and stores to Company ships: Structure and/or equipment Propeller shafting Component Packing with low pressure hydraulic piping flange Packing with casing Clutch Brake lining Synthetic stern tubes
4 of 6 Diesel engine Packing with piping flange Lagging material for fuel pipe Lagging material for exhaust pipe Lagging material turbocharger Turbine engine Boiler Exhaust gas economizer Incinerator Auxiliary machinery (pump, compressor, oil purifier, crane) Heat exchanger Lagging material for casing Packing with flange of piping and valve for steam line, exhaust line and drain line Lagging material for piping and valve of steam line, exhaust line and drain line Insulation in combustion chamber Packing for casing door Lagging material for exhaust pipe Gasket for manhole Gasket for hand hole Gas shield packing for soot blower and other hole Packing with flange of piping and valve for steam line, exhaust line, fuel line and drain line Lagging material for piping and valve of steam line, exhaust line, fuel line and drain line Packing for casing door Packing with manhole Packing with hand hole Gas shield packing for soot blower Packing with flange of piping and valve for steam line, exhaust line, fuel line and drain line Lagging material for piping and valve of steam line, exhaust line, fuel line and drain line Packing for casing door Packing with manhole Packing with hand hole Lagging material for exhaust pipe Packing for casing door and valve Gland packing Brake lining Packing with casing Gland packing for valve Lagging material and insulation Structure and/or equipment Valve Component Gland packing with valve, sheet packing with piping flange Gasket with flange of high pressure and/or high temperature
5 of 6 Pipe, duct Lagging material and insulation Tank (fuel tank, hot water, tank, condenser), other equipments (fuel strainer, lubricant oil strainer) Electric equipment Ceiling, floor and wall in accommodation area Fire door Inert gas system Air-conditioning system Lagging material and insulation Insulation material Ceiling, floor, wall Packing, construction and insulation of the fire door Packing for casing, etc. Sheet packing, lagging material for piping and flexible joint Miscellaneous Ropes Thermal insulating materials Fire shields/fire proofing Space/duct insulation Electrical cable materials Brake linings Floor tiles/deck underlay Steam/water/vent flange gaskets Adhesives/mastics/fillers Sound damping Moulded plastic products Sealing putty Shaft/valve packing Electrical bulkhead penetration packing Circuit breaker arc chutes Pipe hanger inserts Weld shop protectors/burn covers Fire-fighting blankets/clothing/equipment Concrete ballast Note: The above list is taken from resolution MEPC.197(62), appendix 5, paragraph 2.2.2.1. All asbestos free declarations received from the suppliers will have to be collected on board by the Company vessels command and filed in the dedicated section of the dedicated SQEMS file together with a copy of the relevant order/packing list received from the Company office. The vessel Master will immediately advise the purchasing office in case of declarations missing and/or incomplete and/or missing the proper identification and reference to the relevant materials. In this case the received materials will be kept packaged and segregated from other ships stores until the issue of un proper declaration will have been solved or the materials will have to be returned to the supplier. The Company Purchasing Office will keep a proper electronic file of all above orders issued for materials that might contain asbestos, together with the relevant Asbestos free declarations. A facsimile of the suppliers declaration form is available as reference of present document for easier reference (Annex 1 and 3 of IACS REC.130). The file in caption on board of the Company vessels, will be kept ready for inspection by the RO, class and/or flag administration representative controls. The same have to be carried out mandatorily by RO/class at every Safety Equipment and Safety Construction annual survey. Furthermore on account of every Safety Equipment and Safety Construction annual survey, the Company is required to issue a dedicated declaration stating that the vessel has all materials, spares and stores supplied to the vessel since the previous Safety Equipment and Safety Construction annual surveys are all asbestos
6 of 6 free. The technical manager is in charge of issuing the declarations and verify all related evidence of asbestos free materials is available on the file on board and at office, for the year of reference. Copies of the above declarations issued yearly by the Company for each ship will have to be kept in a dedicated section of the file Materials asbestos free declarations as well as in the company office. References WIN-PUR-07 IACS REC.130 Procurement and Supply of Asbestos Free Materials and Spares for Company Ships Procedures for Verifying that Materials Are Asbestos Free