This notice outlines regulations and guidance for the management of hazardous materials on board ships, specifically focusing on Asbestos Containing Materials (ACMs) and fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS). These rules apply to all ships, including Mobile Offshore Units (MOUs) and High-Speed Craft (HSC).
Management of Asbestos Containing Materials (ACMs)
The regulations for dealing with asbestos on ships vary depending on the vessel’s construction date:
- Ships built before July 1, 2002: ACMs are permitted but only if they don’t pose a health risk to the crew. These ships are required to have a hazardous material inventory (IHM) that identifies the location and quantity of all ACMs. Based on this inventory, a conscientious maintenance and monitoring program must be developed and implemented, including regular surveillance not exceeding a three-year interval. If any ACMs need to be removed, it must be done by qualified contractors, and the area must be tested for dust afterward.
- Ships built between July 1, 2002, and January 1, 2011: New installations of ACMs were generally prohibited, with a few very specific exceptions. If ACMs are found that violate the regulations, they must be removed by professional companies within three years of discovery. During this period, the vessel’s administration must issue an Exemption Certificate, and a risk-based maintenance and monitoring program must be in place.
- Ships built on or after January 1, 2011: New installations of ACMs are completely prohibited without exception. Despite this clear rule, asbestos is still being found on ships, often as a result of later repairs or the purchase of spare parts. When ACMs are discovered, the same process applies as for the 2002-2011 ships: removal by professionals within three years, an Exemption Certificate, and a strict risk-based maintenance and monitoring program.
For smaller ships (under 500 GT), the provisions for ACM management should be followed “as far as practicable.”
Management of PFOS
The notice also sets strict rules for the use of PFOS, a chemical historically used in firefighting foams.
- Prohibition: The use or storage of fire-extinguishing media containing PFOS is prohibited on all ships and mobile offshore units constructed on or after January 1, 2026.
- Removal on Existing Vessels: For ships built before January 1, 2026, all fire-extinguishing media containing PFOS must be removed by the date of the vessel’s first survey on or after January 1, 2026. This “first survey” can be the first annual, periodical, or renewal survey.
- Verification and Disposal: To verify if a firefighting foam contains PFOS, the maker’s declaration or lab test reports should be used. If these are not available, the foam must be sampled and tested according to a recognized standard. Once removed, PFOS-containing materials must be delivered to an approved shore-based reception facility, with the action recorded in the ship’s official logbook.
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Source: Liberia Maritime Authority
