The impact of IMO recycling regulations on ship engines
MAN Diesel says that it is pre-empting the IMO ship recycling regulations by making materials documentation available now for its products.
According to the company, reasons of cost are behind the final scrapping of ships and the recycling of materials gravitating to developing countries. This has attracted considerable criticism regarding the working conditions of the personnel involved and the disposal of possible harmful residues in the ships. In particular, given lifespans 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 IMO developed its 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, says MAN Diesel, 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 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 therefore 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 reports that it has prepared a 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,” he 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, and in any case, similar declarations are already requested in the ‘Green Passport’ schemes run by the classification societies,” Gehring 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 our contracts with our suppliers and our conditions of purchase. To ensure compliance, we have contacted our 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 our revised conditions and our quality guidelines, suppliers issue MAN Diesel with their own material declarations, and are obliged to inform us immediately of proposed changes in their manufacturing practices.
Parallel to identification and documentation of hazardous substances we have investigated how to reduce of even eliminate these substances from our 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 of even better performance. The remaining gaskets will follow soon, when the performance testing is finished.
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