Emissions from metal cutting are more likely to contain air pollutants that have toxic effects on the workers, exposing their health to risk rather than having a major air quality impact. Our Company identifies measures of protection for these cutting operations, both to avoid the spreading of the contaminants as well as protecting the workers.

　　Metal exposure through consumption of contaminated seafood may cause health problems. This is particularly a problem in areas where workers live nearby ship-dismantling facilities and where seafood is an important source of nutrition.

1.2 Precautions
　　Prior to any “hot work” activities, surface coatings should be assessed and removed (in the cutting line), if found to be toxic or highly flammable. All spaces where torch-cutting is to be conducted, should be clarified as “safe for hot work” prior to start-up. This includes areas within, on or adjacent to spaces that contain or have contained combustible or flammable liquids or gases, as well as accessories connected to spaces that contain or have previously contained fuel.

　　An area or space is “safe for hot work” after concentrations of flammable vapors or gases in the atmosphere are declared to be less than 10 percent of the lower explosive limit. Further, hollow metal containers must be filled with water or be thoroughly cleaned of flammable substances, vented and tested prior to cutting. Sufficient ventilation (through-flow) is required for each hollow structure for the release of any pressure build-up that might occur during heating.

　　Workers performing any type of metal cutting may be exposed to damaging bright light, ricochets, noise and heat. This requires the use of personal protective equipment (PPE) including suitable eye protection as well as appropriate hand and body protection. Clothing must not contain flammable material, and all fire hazards must be moved away from the object to be cut. Workers subjected to noise levels of a certain magnitude must use appropriate equipment reducing the exposure to an acceptable level.

　　The workforce may conduct general metal cutting without mechanical ventilation or respiratory equipment, provided that it is not done in a confined or enclosed space and that metals containing or coated with toxic materials are not being cut. If sufficient ventilation is not feasible (to arrange) when metal cutting is performed in confined spaces, the workers must then use air-line respirators. Furthermore, someone outside the confined space must maintain communication with the workers inside in order to provide assistance and/ or alert in case of an emergency. Workers cutting metals that contain or are coated with toxic materials, must use local exhaust ventilation or air-line respirators.

1.3 Waste handling
　　The dismantling facility may recycle scrap metal by selling it to a resmelting / re-rolling company or a scrap metal broker. It is important to note that coated scrap metal that is not recycled should be managed and disposed of as hazardous waste. Recyclable metal that is intermixed with non-metallic material can be recovered by the use of shredders and separators. The remaining non-recoverable non-metallic materials from the shredding process must be disposed of as hazardous waste as they may contain environmentally hazardous substances, such as asbestos or PCBs. Scrap metal for recycling exported from the dismantling facility may be contaminated by considerable amounts of coating products containing toxic or hazardous substances. Receivers of scrap metal for re-processing should be encouraged to take action in order to safeguard against pollution.

　　Cable-burning for the recovery of copper wire is highly hazardous and must be prevented. Operators are strongly encouraged to separate copper from cable insulation by other means. Cable insulation should be considered to contain hazardous substances or substances capable of producing hazardous substances upon disposal and treated accordingly if not confirmed otherwise.

　　Anodes are fitted to both the vessel’s hull and inside tanks in order to protect against corrosion and fouling. Anodes consist mainly of aluminum (Al) and zinc (Zn), but may also include small amounts of other metals, such as copper (Cu), iron (Fe), and mercury (Hg). Anodes are sacrificed over a space of time and the amount of metals left when the ship arrives for dismantling will reflect its history of maintenance. It is likely that most (intact) anodes will be extracted and sorted for reuse/ resale. Heavily corroded anodes will be disposed of as hazardous waste. The removal of the anodes will in itself not generate any adverse effects on humans or the environment as alloys are non-toxic in their solid states.

　　Lead (Pb) is toxic, and can be found in batteries, paints and in components in motors, generators, piping, cables and others. The detrimental effects of lead upon human health have been widely known for a long time. Young children are most susceptible to the toxic effects of lead. Long-term exposure to even low levels can cause irreversible learning difficulties, mental retardation and delayed neurological and physical development. In adults, exposure to lead primarily affects the peripheral nervous system and can cause impairment of hearing, vision, and muscle co-ordination. Lead can also damage the blood vessels, kidneys, heart and reproductive system.

　　Lead chromate (present in paint pigments) is documented as a carcinogen both to humans and other organisms. It may also damage embryo development and cause infertility. Improper disposal of batteries and paints containing lead can cause a threat to health as well as to the environment.

　　Mercury is a toxic heavy metal and a persistent, bio-accumulative pollutant that affects the nervous system. On board ships, mercury can be found in thermometers, electrical switches, light fittings and luminescent lamps. Accidental spills of mercury can lead to dangerous mercury exposure. Consumption of contaminated fish is also an important source of mercury exposure. Mercury must be handled as hazardous waste.

2. Oil and fuel

2.1 Onboard location
　　The vessel’s piping and tank arrangements will generally contain some quantities of oil, fuel, sludge and associated residues. Fuel oil may be found in both integrated and free-standing tanks throughout the ship. Lubricating oils may be found in a variety of tanks depending on their individual use. System oils are typically located in engine room sump tanks, whilst cylinder oils may be stored in separate purpose tanks. Lubrication/ system oils may also be stored in drums. Tankers can arrive at the ship-dismantling facility with a significant quantity of cargo residues. Further, all tanks may contain a certain level of sludge.

2.2 Hazards
　　Both petroleum products and non-petroleum oils can have adverse and well-documented effects on the environment. Oils and fuels may poison marine organisms and physically soil the environment (birds, fish, plants, etc.). Oil spills also threaten natural resources.
　　The primary danger to workers handling oil and fuel on ships is that of fire and explosions. It should also be noted that oil and fuel represent certain toxic hazards and may impose serious health threats to workers if handled incorrectly. The main exposure routes for the hazardous components in oils and fuels are inhalation and consumption of contaminated fish and water. Highly refined petroleum products are toxic and also represent a fire hazard.

2.3 Waste handling

　　Oil and fuel removed from ship must be stored in a safe tank arrangement, ensuring leakage detection, overfill monitoring and corrosion protection, in addition to a leakage-collection arrangement. The monitoring should include record-keeping. Local/ national regulations require notification to authorities concerning installation and usage for the storage of flammable or combustible liquids. Regulations address the issues of fire-protection and financial responsibilities.

　　Used oil may be defined as oil that has been refined from crude oil or made from synthetic materials and which contains physical or chemical contaminants as a result of being used. Used oil should not be mixed with other wastes as this may require the entire amount being managed as hazardous waste. Used oil should be stored in dedicated tanks or containers and should be labelled “Used Oil”. The most environmentally friendly and often most economical way of managing used oil is recycling. Oil and oily wastes that are defined as hazardous waste, either by appearing on a relevant hazardous waste list or by having hazardous waste characteristics (ignitable, corrosive, reactive or toxic), must be managed according to governing national hazardous waste regulations.

　　We have an oil spill preparedness contingency plan that includes instructions on notification, recovery and normalization. The plan should be integrated in the general Contingency and Preparedness Plan (CPP) for the shipbreaking yard.

3 Bilge and ballast water

3.1 Onboard location
　　Bilge water is stagnant water mixed with potentially polluting liquids, which has drained to the lowest inner part of a ship’s hull (i.e. the ship’s bilge). Bilge water may be found anywhere in the ship, and its quantity increases during dismantling activities due to the accumulation of rainwater as well as cooling and containment water used during dismantling operations.

　　Ballast water is fresh, brackish or marine water that has intentionally been brought on board a ship in order to adjust the ship’s stability and trim characteristics in accordance with various operating conditions. It is critical to safe operations and can involve vast quantities as cargo holds are often used for ballast water on older ships (those typically being sent to the recycling yards). More modern ships have segregated ballast tanks, but even those may need cargo hold ballast to withstand rough weather. Further, an empty ship would need larger amounts of ballast water for safe transport to the recycling yard whether being towed or steaming under its own power. Ballast water can be found in various tanks throughout the ship.

3.2 Hazards
　　Bilge water is often referred to as oily waste as it is usually heavily contaminated with oil and cargo residues, in addition to other pollutants (inorganic salts, and metals, such as arsenic; copper; chromium; lead; and mercury). Given this, bilge water presents an oil pollution hazard during cutting operations.

　　Ballast water may contain pollutants, such as residual fuel, cargo hold residues, biocides, oil and grease, petroleum hydrocarbons, and metals (e.g. iron, copper, chromium, nickel, and zinc). Ballast water in cargo tanks (oil) is referred to as dirty ballast water.

　　The transport of large volumes of water containing organisms from shallow, coastal waters across natural oceanic barriers can cause massive invasions of neritic marine organisms. Because ballast water is usually taken from bays and estuaries with water rich in animal and plant life, most ships carry a diverse assemblage of aquatic organisms. Aggregate sediments typically found in ballast tanks will contain living species which reflect the trade history of the vessel.

　　The arrival condition of the dismantling candidate is most likely that of “in ballast”. The discharge of ballast water/ sediment species into the coastal sea-area may be a potential source for introducing unwanted organisms which threaten the ecological balance in the surrounding seas and thereby represent a direct threat to biodiversity. Ballast water can be the carrier of viruses and bacteria transferred to humans causing epidemics.

　　In order to limit the biological threat represented by the introduction of invasive species via ballast water, the vessel should undergo recommended de-ballasting

3.3 Waste handling
　　Bilge and ballast water is transferred to onshore storage tanks, evaporation pits (ballast water only) or discharged directly overboard. Regulations apply that specifies permitted levels of contaminants. The Company will reduce the pollutant content in wastewater prior to discharge.

4. Paints and coatings

4.1 Onboard location
　　A comprehensive selection of different paints and coating products are present on board a vessel. These products are used both on the exterior and the interior and may have characteristics requiring certain precautions with respect to the demolition process. The hull is coated several times during its lifetime in order to prevent fouling. Fresh paint for maintenance purposes may also be found on board.

4.2 Hazards
　　Paints can be flammable and may contain toxic compounds (PCBs, heavy metals (e.g. lead, barium, cadmium, chromium, and zinc), and pesticides). Paints with metallic compounds are used to protect ship surfaces from corrosion. Pesticides, such as tributyl tin (TBT) and organotin are still commonly in use on wetted hull surfaces in order to prevent fouling.

　　The removal of paints prior to cutting during ship dismantling may not be necessary unless the process leads to the release of toxic compounds or if the paint is highly flammable. Prior to cutting painted surfaces, the dismantling facility should conduct an evaluation to determine flammability and toxicity of the paint or coating.

　　Toxic or flammable painted/ coated steel should be labelled following cutting. Flammable paints or coatings may be burned away in a controlled manner. This process requires that provisions for fire-fighting have been made.

　　Toxic paints or coatings should be removed at a distance of some 10 cm from the area to be cut. If removal is not possible or feasible, cutting can proceed provided that the operator(s) are equipped with respiratory protective equipment such as air-line respirators. Three methods are commonly used to remove paints and coatings:
　　Chemical stripping. The application of solvents. Note that solvents are in their own right, usually hazardous and will present a use and disposal challenge.

　　Abrasive blasting. A surface is blasted with abrasives (slag, grits or steel shots). Blasting involves the use of high-pressure equipment and may potentially be dangerous if the condition of the equipment applied is not satisfactory. Periodic checking of pressure equipment/ tools should be mandatory. Workers’ skin, eyes and hearing are particularly exposed. Abrasive blast material is a hazardous waste if the material includes hazardous coating residues or is made from slag contaminated with arsenic, lead or cadmium.

　　Mechanical removal. Power tools or thermal tools may be applied. Thermal removal must not be used on paintwork containing PCB.

　　The methods above may generate emissions containing compounds of concern, which are also associated with the potential for causing cancer. The main exposure route from paint removal is inhalation. Paint removal activities also generate large amounts of hazardous waste.

　　Most paints and coatings will be exported from the dismantling facility to steel reprocessing plants via steel plates. Consequently, the challenges associated with emissions of polluting substances in the paints and coatings are transferred to the reprocessing facilities where air emissions may be easier controlled. The labelling of steel plates will enable the reprocessing plant to undertake certain measures in order to control the air emissions.

　　Tributyl tin (TBT) is an organometallic substance used in anti-fouling paints. It can cause an effect at low to sub-nanogram quantities per litre, and is therefore considered to be one of the most toxic compounds in the aquatic environment. Its use is now strictly controlled in most parts of the world. When a vessel is beached, there will be direct contact between the ship’s hull and the beach, and some anti-fouling will be ground up. High concentrations in beach sediments would be expected from this process. The antifouling residue is deposited in the sediment or carried away with the current thereby causing pollution in the marine environment.

　　Isocyanates are often used in spray-painting and polyurethane coating processes and may be released when hot work is applied. Occupational exposure can cause respiratory diseases and asthma. The exposure levels likely to be generated by ship-dismantling activities are unknown.

4.3 Waste handling
　　Waste from these processes can also have negative impacts on the environment. Remains generated from the paint and coating removal processes should be considered hazardous and should be managed and disposed of accordingly. Procedures must be identified in the waste management plan for our Company. This should also identify best-management practices to prevent or minimize pollution from surface runoff water.
　　The waste management plan will be facility-specific as different facilities vary in size and location, hydrogeology, climate, environmental setting, and so on. Paint removal wastes (including contaminated or residues of solvents and sludge, solvent-contaminated rags, abrasive residues and paint chips) that are defined as hazardous waste, either by appearing on a defined hazardous waste list or by having hazardous waste characteristics (ignitable, corrosive, reactive or toxic) are managed according to the national hazardous waste regulations.

5 Asbestos

5.1 Onboard location
　　Asbestos-containing material (ACM) may be found in thermal system insulation and on surfacing materials. Engine rooms usually contain the most asbestos. Some other applications may also be found. ACM is often visible, but can also be found underneath other materials that do not contain asbestos.

5.2 Hazards
　　Asbestos is a natural mineral which is not harmful to the environment but represents a major health threat. When ACM is deteriorated or disturbed, asbestos breaks up into very fine fibers which can be suspended in the air for long periods and possibly inhaled by workers and operators at the facility or by people living nearby. The most dangerous asbestos fibers are too small to be visible. Once they are inhaled, the fibers can remain and accumulate in the lungs. Breathing high levels of asbestos fibers can lead to an increased risk of lung cancer, mesothelioma (a cancer of the chest and abdominal linings), and asbestosis (irreversible lung scarring that can be fatal). The risk of lung cancer and mesothelioma increases with the number of fibers inhaled. Symptoms of these diseases do not show up until many years after exposure. Most people with asbestos-related diseases have been exposed to elevated concentrations in connection with their work.

5.3 Waste handling
　　Asbestos is a hazardous waste and should not be re-used or re-cycled. Maximum precautions include both the protection of workers when extracting asbestos from the vessel, the securing of the disposal of asbestos and measures preventing asbestos from re-entering the market.

　　Our Company has an asbestos disposal plan in the waste management plan including requirements associated with the ship’s inventory plans so that asbestos can be localized, quantified and identified prior to removal. The plan identifies personnel removing the material and procedures for both the removal as well as the disposal.

　　Handling of asbestos is monitored by record keeping as well as by sampling. It is essential to keep the asbestos wet before and during the removal operations in order to avoid dispersion of the fine fibers in the air. Asbestos removal should always be carried out with two people: one who makes sure the asbestos is wet during the removal operation and one performing the actual asbestos removal work.

　　Monitoring includes air-surveillance activities to be performed in work areas where asbestos is being removed. The record-keeping includes all measurements taken to monitor worker-exposure to asbestos.

　　Asbestos removal is carried out only by workers who have been specially trained to do this type of work. Workers involved in asbestos removal and disposal must use appropriate respirators, as well as protective clothing such as overalls, head coverings, gloves, face shield or vented goggles, and foot covering. The facility must provide hygiene facilities for workers, such as decontamination areas (equipment room, shower area and clean room) and dining areas.

　　If a shipboard inventory containing the details on asbestos is not available, a survey of asbestos -containing materials on the ship must be carried out. The inspection should include determination of location, type and amount of ACM (localize, identify and quantify). Instead of collecting samples for asbestos analysis, it might be feasible to assume that all suspect material is ACM.

　　All ACM must be removed from a ship being scrapped before any activity that would disturb the materials is carried out.

　　Once removed from vessel, the asbestos containing waste (ACM) is disposed of. Asbestos containing waste material (ACWM) is any waste that contains or is contaminated with RACM (including equipment and clothing).

　　After wetting, we seal all ACWM in leak-tight containers while still wet. The containers are plastic bags (6-mils thick). For bulk wastes that will not fit into containers without additional breaking, we must put these wastes into leak-tight wrapping. The wrapping should be sealed (e.g., with duct tape) while adequately wet.

　　In all cases, the ACWM should be wet when contained to prevent the release of asbestos fibers in case the container or wrapping is broken. An inspector may check bags or other containers to determine if the ACWM was kept adequately wet when packaging. One way to quickly check if this requirement has been met is to lift the bag. A bag filled with well-wetted material is substantially heavier and denser. An inspector may also open any bags to inspect them, most likely using a glove bag or other emissions control method. The inspector will then properly reseal the bag, or request that workers do so. An inspector may also observe trucks picking up asbestos wastes to see if the bags are handled without bursting or dispersing asbestos to the atmosphere.

　　Warning labels are placed on all bags, containers, or wrapping materials containing ACWM. These labels must be printed in letters of sufficient size and contrast so that they are easily visible and readable. The labels must have the wording specified by OSHA:

　　Additionally, we label those bags of ACWM destined to be transported offsite with the name and location of our company.

　　We control no visible emissions to the outside air during the collection, packaging, or transporting of any ACWM by adequately wetting the ACWM to ensure there are no visible emissions.

　　We inspect if there is any material on the ground that appears to be ACM (such as white fluff). We will sample and photograph suspected ACM, as well as the sources (such as a nearby cable) that it may have come from.

　　All shipments of ACWM transported off the facility site are accompanied by a waste shipment record (WSR). The WSR is a record of the movement and ultimate disposition of the asbestos waste. Our company, as a waste generator, keep copies of all WSRs for at least 2 years.

　　We receive a copy of the WSR signed by the disposal site operator within 35 days to determine the status of the waste shipment. An inspector will examine the WSRs to ensure that the records are complete, including all required signatures for each shipment.

　　Asbestos mixed with cement and confined in sealed cement box are disposed for landfills in approved disposal site. ACWM logs and the disposal site records. Additionally, the inspector checks to see that the asbestos waste is placed in the disposal site without dispersing asbestos to the atmosphere, and that the site covers the asbestos waste daily. If asbestos is removed from a ship and exhibits any hazardous waste characteristics (e.g., toxicity), it is considered a hazardous waste.

6 PCBs

6.1 Onboard location
　　PCBs may be found in both solid and liquid forms in equipment and materials throughout the ship. Since the sampling and determination of the presence of PCB's is a difficult process, a so-called Grey List has been set up listing suspect materials and equipment.
Grey List of suspected PCB-containing materials
• Cable insulation
• Rubber and felt gaskets
• Thermal insulation material including fiberglass, felt, foam and cork.
• Transformers, capacitors (also contained in electronic equipment)
• Voltage regulators, switches, reclosers, bushings and electromagnets
• Adhesives and tapes
• Oil, including that contained in electrical equipment and motors, anchor windlasses, hydraulic systems.
• Surface contamination of machinery and other solid surfaces
• Oil-based paint
• Caulking
• Rubber isolation mounts
• Foundations mounts
• Pipe hangers
• Light ballasts
• Plasticizers

6.2 Hazards
　　PCBs are toxic and persistent in the environment and have been shown to cause a number of adverse health effects. The most carcinogenic PCBs tend to bioaccumulate. Exposure to PCBs may occur through inhalation, ingestion, or absorption through the skin. The toxicity of chemicals produced when PCBs are heated (polychlorinated dibenzofurans and polychlorinated dibenzo-p-dioxins) is of special concern, as they are believed to be even more toxic than PCBs themselves.

6.3 Waste handling
　　Workers removing and disposing of PCBs or PCB-containing materials must use appropriate personal protective clothing or equipment that protects against dermal contact with or inhalation of PCBs. Removal and disposal of PCB-containing materials should be carried out only by workers who have been specially trained to do this type of work. In cases where there are several ship -dismantling yards in one area these specialized workers could be shared by the dismantling companies.

　　The production of PCBs in the USA ceased in 1979 following new regulations. In Europe, most countries banned the manufacturing of PCB in the early 1980s (1978-1982) and phase-out regulations on use of PCB are in place. A global campaign aiming at prohibiting all use of PCB is ongoing. International trade of PCB is regulated in the Rotterdam Convention and under the Stockholm Convention.

　　Wastes containing PCBs at a concentration level of 50 mg/kg or more are considered hazardous waste by the Basel Convention. As a precaution, it may be feasible to remove all known and suspected PCBs and PCB-containing material, or conduct sampling and chemical analysis of these items, and if regulated PCB levels are present, dispose of them according to the criteria set forth in Article 6 of the Stockholm Convention.

　　PCBs or PCB items to be stored must be placed in proper containers, covered and labelled. Temporary storage facilities for PCB-containing waste must have a floor-covering that prevents penetration of PCBs and a curbing that provides sufficient containment volume in the case of a spill, roof and walls that prevent rainwater from reaching the wastes, and no floor drains or other openings that would allow liquids to flow from the area. Disposal requireme nts may be dependent upon the nature of the source and its concentration.

7. Other waste streams

7.1 Radiation sources.

　　Radioactive material may be present on board a ship in liquid level indicators, smoke detectors or emergency signs. These sources generate low -level radioactive waste, but handling and disposal of such waste is usually strictly regulated. Ionizing radiation is hazardous to human health and the environment and can cause severe forms of cancer and/ or damage to genetic material endangering future generations. Any release of radioactive material could increase the radiation exposure to the population and must therefore be avoided.

　　We request ship owners to discharge all radioactive materials before we decide to purchase such old ship.

7.2 Timber
　　Timber can be found in furniture or walls, and timber may for example contain preservation or paint that could have an adverse effect on the environment. The timber should be treated according to national regulations and should be taken care of by approved waste companies.

7.3 Polyvinyl chloride (PVC)
　　PVC is used in a wide variety of products for different applications and is commonly found in cables, floor coverings and plastic devices of different types. PVC products may contain more than 50% chlorine, and may contain environmentally hazardous additives. A complex mixture of fumes and gases is generated when PVC is burned, depending on the oxygen availability and other fire conditions. This includes carbon monoxide and dioxins. Indeed all open burning may generate toxic gases and should therefore be prohibited, but PVC is of particular concern because of the chlorine content. Also, large quantities of hydrogen chloride gas are generated when PVC is burned. The hydrogen chloride gas combines with water to form hydrochloric acid in the lungs.

7.4 Batteries
　　Batteries can contain heavy metals such as Pb, Cd and Ni. Lead-acid batteries also contain sulphuric acid, which is corrosive and can cause severe burns. Batteries can be in flashlights, mobile radios and electrical equipment, but the largest volume of batteries (lead-acid batteries) is found in radio applications, intercoms, fire alarms, emergency start equipment and lifeboats. Batteries in working order will most often be sorted and sold for reuse. Lead alone represents a considerable value, and there is therefore reason to believe that batteries are recycled regardless of their condition. If batteries are undamaged, they will not have an environmental effect. However, the improper storage or disposal of batteries can cause a threat to human health and the environment.

7.5 Freon
　　Freon is a Du Pont trade name for chlorofluorocarbons (CFC), which are compounds consisting of chlorine, fluorine and carbon. CFCs are non-toxic, non-flammable compounds that are stable in the troposphere, but in the stratosphere, can be broken down by UV light and deplete the ozone layer. CFCs are used as refrigerants, solvents and foam-blowing agents. Shipborne CFCs have been believed to contribute to up to 10% of global emissions.

7.6 Other chemicals
　　Other chemicals/ substances/ components that may require special handling are for example:
• Antifreeze fluids
• Solvents/ thinners
• Battery electrolyte
• Evaporator dosing and de-scaling acids
• Corrosion inhibitor
• Compressed gases (acetylene, propane and butane)
• Plastics, as covered by MARPOL
• Boiler/ water treatment chemicals
• Kerosene/ White Spirit
• Anti-freeze compounds
• Engine additives
• Flame retardants
• Miscellaneous chemicals, such as alcohols, methylated spirits, epoxy resins, etc.

　　The chemicals/ substances/ components above may have negative effects on the environment. They may represent a market value and some are therefore sold on for further use. Their characteristics are not addressed any further in these guidelines.