Guidance

Annex 1 (regulation 8) maintenance work or emergency repairs

Published 14 October 2024

Annex 1 - (regulation 8) further precautions to be taken when maintenance work or emergency repairs are being undertaken which might create asbestos dust

1. Work on materials containing asbestos, and any operation which could give rise to asbestos dust, should be left until the ship is in a port or dry dock where the proper facilities, trained contractors and equipment are available. Where it is essential for such work to be carried out at sea, maximum precautions must be taken as indicated in this MGN. In particular it should be noted that material associated with structural fire protection should not be disturbed except in circumstances where it may be necessary to sacrifice some measure of structural fire protection in order to ensure the safety of the ship itself, e.g. to preserve watertight integrity or adequate stability. In such cases, proper precautions must be observed and the materials and structure concerned restored to their original condition as soon as possible.

2. When working with materials containing asbestos (eg when stripping thermal insulation, etc.) dust levels should be reduced by careful handling, by using hand tools rather than power tools, and by thorough pre-wetting of the item to be worked. Thoroughly wet or oil-soaked items, such as gaskets and seals, might be capable of being replaced without special precautions (NOTE: a thick layer of asbestos such as lagging, may not however be thoroughly wet all the way through, even if it has been deliberately wetted: so treat it as if it were dry); the replaced item should be carefully disposed of. Care should be taken if asbestos is on or close to electrical wires or parts. Movement of dust should also be controlled by effectively enclosing the relevant areas and by using portable filtering dust extraction equipment. Air vented from such areas should, as far as possible, be vented and filtered so that no one on deck or elsewhere can inhale it.

3. Access to areas where asbestos is being worked should be limited to those persons essential to the operation. The working area should be enclosed (for example, by plastic sheeting and adhesive tape), and warning signs should be posted. Persons not wearing protective clothing and respiratory equipment should be excluded from this area.

4. If possible a large plastic sheet, etc should be used to collect all waste material as it is generated during the work. The sheet should be used to wrap up asbestos dust and small fragments of asbestos.

5. When work in the enclosed area is completed, dust sheets should be carefully folded and placed, along with large pieces of asbestos, in air tight containers (eg strong plastic bags, sealed with adhesive tape). Then the walls, ceiling and items in the area should be cleaned with damp cloths, and dust on the deck should be dampened and then cleaned carefully. Where possible the enclosure sheets should be sprayed with PVA and allowed to dry in order to fix any residual asbestos dust on the sheets. The sheets should then be carefully taken down, and put into air tight containers. Then the area should be cleaned again as above. See paragraph 6.5(c) as to the use of special vacuum cleaners and the disposal of contaminated clothing.

6. All cloths, filters, brushes, clothing, etc should be placed in the air tight containers: they should NOT be cleaned on board ship. The sealed containers should be clearly labelled “Warning: Contains asbestos. Breathing asbestos dust is dangerous. Follow safety instructions” or “asbestos contaminated clothing—do not inhale the dust”. (The port authority can give a translation of the asbestos warning.) The containers should be stowed safely until they can be disposed of ashore in accordance with the advice of the port authority, or sent by the ship to a place where the clothing can be specially laundered.

7. Whilst crew members should as far as possible avoid removing any asbestos-containing materials which are in a sound condition, any replacement of a defective asbestos item should be with an equivalent item made from a safer substance.

8. Before return to port any friable materials, eg sprayed asbestos insulation, panels, cladding, etc. which have become, or could become, damaged should be protected by a suitable coating or covering applied by a suitably protected person. Likewise any bare asbestos should be sealed with paint, etc. and properly covered. If there is a danger of unsealed edges of asbestos panels rubbing together with the movement of the ship, they should be plugged with a suitable sealing compound. Compounds used for sealing edges of panels used for structural fire protection should be of a material considered in conjunction with the testing and approval of the fire bulkhead materials.