The question of how to break ships in a safer and more environmentally sound manner is one of the biggest challenges facing the marine industry today. By encouraging simple, achievable measures, the Lloyd's Register Green Passport could be highly effective in helping the industry improve its image and safety record.
The International Maritime Organization’s (IMO) Guidelines on Ship Recycling were introduced, in 2003, to improve standards of safety and reduce environmental pollution resulting from the scrapping of ships. Subsequently, IMO’s Marine Environment Protection Committee (MEPC) has agreed that parts of the Guidelines will be given legal force in a ship recycling convention. Central to both the guidelines and the convention is the concept of the Green Passport, which is an inventory of materials present in a ship’s structure, systems and equipment that may be hazardous to health or the environment.
In November 2004, as the result of an extensive collaborative study, Lloyd’s Register became the first classification society to issue an independently verified Green Passport. We now provide a Green Passport approval and verification service for both newbuilds and existing ships.

Newbuild inventories

The Green Passport for newbuilds is compiled by the shipyard using a specially developed template and verified during the normal construction survey process, using procedures that were developed in conjunction with one of the largest yards in Korea. An important aspect of the Guidelines is the exclusion of certain materials from the build and we expect each ship owner to discuss this possibility with the yard.

Following this discussion, the yard and all sub-suppliers must take steps to ensure that agreed materials are excluded, and they must declare materials that have been included according to various categories required by IMO. Materials commonly earmarked for exclusion are asbestos, chlorofluorocarbons (CFCs), polychlorinated biphenyls (PCBs) and tri-butyl tin-based paint (TBT). The inventory is designed to give reasonable estimates as to the presence of these materials, but the owner and the yard are free to include any additional detail they think is relevant.

On completion of the newbuild, the surveyor issues a certificate of compliance and attaches the inventory of hazardous materials and any declarations that the ship is free of a particular material; together, these documents make up the Green Passport.

Inventories for existing ships

Where a ship is already in service, the owner completes the inventory template and submits it for approval three months before the ship’s next major survey. When the survey takes place, the surveyor verifies that the inventory is a reasonable representation of the hazardous materials onboard.

The primary source of information for the inventory is ship documentation, but details can often be gleaned from the item itself: refrigeration units, for example, commonly state the refrigerant used and more recent lighting ballasts often indicate that they are free of PCBs.

Another excellent source is manufacturers’ records, whether maintained by the manufacturers themselves (such as with paints) or by third parties (such as the Canadian government’s records of common PCB-filled capacitors).

Sampling or presumption?

The next step is to double-check that there have been no alterations since the ship’s documentation was produced. In many cases, this will be a relatively simple process, since alterations tend to be fairly apparent – they may look newer, have different paint or be in an unusual position with strange pipework or wiring. There may, however, be some unknowns and, in such cases, it may be advisable to take samples of the material in question. The drawback is that sampling will never do more than provide an assessment of what was actually sampled: its accuracy will depend very much on the homogeneity of the material, how recognisable it is and the number of samples taken.

The best example of the dangers inherent in sampling can be seen with floor coverings – especially fire coatings. It appears to have been common practice to use asbestos-containing cement for the bottom layer of an A60 boundary, but not the top layer. Clearly, a sample that scratches the top layer, but not the full thickness will be misleading, as will a sample of the full thickness in an area that was wrongly assumed to be an A60 zone.

Ultimately, there may be a need for yards to be properly approved or licensed to carry out this type of sampling work. In the meantime, the simplest – and possibly safest – method will often be presumption. When compiling an inventory, any unknown material considered likely to contain a hazard should be presumed to contain that hazard. Once this is declared it is the owner’s responsibility to treat the material accordingly throughout the ship’s life, and for the recycling facility to dispose of it as though the hazard were known to be present – unless, of course, it carries out tests that prove otherwise.

The benefits of the Green Passport

Many companies are now demonstrating a commitment to continuous improvement in terms of safety and the environment. The Green Passport enables easy benchmarking and helps to make such improvements measurable and achievable. “The Green Passport enables through-life hazard management in terms of both safety and the environment,” says Robin Townsend, Lead Specialist – External Affairs, Lloyd’s Register. “It can also be of substantial assistance in achieving fleet compliance with new legislation, helping the operator to identify all the affected ships and enabling plans and repair schedules to be drawn up in a timely fashion.”

Potentially the most far-reaching benefit of the Green Passport, however, comes at the ship scrapping stage. “At the end of the ship’s life, the Green Passport forms the basis for a transparent agreement with the recycling yard, displaying up front the hazards that the yard will need to be able to handle and hopefully enabling it to formulate a safer and more environmentally sound plan for decommissioning the ship,” Townsend continues.

Simple but effective

Despite – or perhaps because of – the success of Green Passports so far, proposals currently under consideration by MEPC suggest that they should be extended to cover as many as 56 different categories of hazardous materials, checking for and recording in detail the presence of these materials in all components of a ship. Townsend suggests, however, that such measures could be counterproductive in practice. “Ultimately,” he says, “the greatest improvements in ship recycling will be achieved by introducing small, but essential measures that all parties will have the means to implement. “The Lloyd’s Register Green Passport has not been developed to ensure that the presence of every possible hazard is discovered and catalogued: it encourages shipbuilders and operators – as well as the recycling facilities themselves – to focus their attention on eradicating the major known hazards. It is to be hoped that, by taking such an approach, the ship recycling industry will realise far sooner the improvements in safety and environmental performance it so desperately needs.