MAN Diesel pre-empts IMO ship recycling regulations

27 Jan 2010

Ships and their components (such as engines shown here) will be subject to the ‘IMO Convention on Safe and Environmentally Sound Recycling of Ships’ regulations

MAN Diesel is to introduce a ‘materials declaration’ for all its products containing materials identified by IMO as hazardous in order to comply with the proposed ‘IMO Convention on Safe and Environmentally Sound Recycling of Ships’ regulations.

For reasons of cost, the final scrapping of ships and the recycling of materials has gravitated to developing countries and attracts considerable criticism regarding the working conditions of the personnel involved and the disposal of possible harmful residues in the ships. In particular, given the lifespan of merchant ships in the region of 30 years, the scrapped hulls can contain substances which have long been identified as hazardous and outlawed in many parts of the works. Examples are asbestos and lead which were widely used as insulation for pipes and in paints respectively, before their risks were recognised.

To counter this situation, the International Maritime Organisation has developed the ‘IMO Convention on Safe and Environmentally Sound Recycling of Ships’,a set of regulations controlling the use of hazardous substances in new buildings. The legislation started ratification in 2009 and affects newbuildings with keels laid in about 2013. Sensibly, the legislation applies to all the components of the ship and places the onus on the manufacturer to minimise or, where possible, completely eliminate harmful substances from their products. Any unavoidable residual substances must be entered in an Inventory of Hazardous Materials (IHM) issued by the shipyard and based on declarations from its suppliers.

As an engine, turbocharger, gear and propeller supplier, MAN Diesel’s products are categorised as ‘Structure and Equipment’ under the IMO convention. MAN Diesel is obliged to issue declarations under Table A Materials, which is mandatory for new and existing ships, and Table B Materials, which is mandatory for new ships and voluntary for existing ships. “These involve a ‘materials declaration’ for all our products containing materials identified by IMO as hazardous, as well as a ‘declaration of conformity’ which confirms that we have the quality processes and procedures we need to ensure the correctness of our ‘materials declarations’,” note Dr. Holger Gehring and Harald Krekel, who implemented the process for compliance with this convention in MAN Diesel.

Having accompanied the development of the new IMO legislation closely through all its stages, MAN Diesel has prepared its response to the changes well in advance and already has its solution in place. “Materials declarations are already available for all MAN Diesel Products”, Gehring confirms. “In this way, as with our early availability of engines complying with emissions legislation, we aim to give our customers clear future perspectives,” Gehring states. “In fact, due to strict safety at work regulations in Europe, our engines contain only minor proportions of the hazardous substances listed by the IMO convention,” Gehring states. “And in any case, similar declarations are already requested in the ‘green passport’ schemes run by the classification societies,” he adds.

Essentially, MAN Diesel has adopted a delegated approach which obliges its suppliers to make parallel declarations. The obligation to declare potentially hazardous substances is now firmly enshrined in MAN’s contracts with suppliers and its ‘conditions of purchase’. To ensure compliance, MAN has contacted their suppliers and ascertained what substances they use. The materials identified, are for example - as stated, in very small amounts - lead in bearings, lead oxide in gaskets and mercury in thermometers. Under MAN’s revised conditions and quality guidelines, suppliers issue MAN with their own ‘material declarations’, and are obliged to inform the company immediately of proposed changes in their manufacturing practices.

Parallel to identification and documentation of hazardous substances MAN has investigated how to reduce or even eliminate these substances from its products. As a first consequence lead oxide free gaskets have been intensively tested. Most of the gaskets so far containing lead oxides have been substituted with lead-free components with the same or even better performance. The remaining ones will follow soon, when the performance testing is finished.

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