asbestos-free, says the paperwork

Problem statement

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force on 26 June 2025, and under it, according to DNV, "all internationally trading vessels of 500 GT and above" must have an International Certificate on Inventory of Hazardous Materials "at the latest by 26 June 2030" (or before recycling, if sooner) — a one-time, treaty-driven inventory of essentially the entire world merchant fleet. The inventory's Part I is built, for new ships, on Material Declarations and Supplier's Declarations of Conformity "furnished by the suppliers in the shipbuilding supply chain (e.g. equipment suppliers, parts suppliers, material suppliers)," and for existing ships on document analysis, an onboard "visual/sampling check," and — where sampling is impractical — a category of items "potentially containing hazardous material." The weak link is the declaration. IMO's own circular records that "despite the clear and unambiguous prohibition of asbestos containing materials (ACMs), asbestos is still found on various locations on board ships ... fire blankets, joints and insulation materials, types of sealants, friction material for brakes, wall and ceiling coverings, cords, remnants, electric fuses, etc.," that "ships that initially were free of asbestos appear to have asbestos on board as a result of repairs at shipyards and/or of purchasing spare parts at a later stage," that "most asbestos is used on board in materials where it cannot easily be identified visually," and that "asbestos in most ACMs can only be ascertained by experts in specialized laboratories." The unsolved problem is verifying, cheaply and at fleet scale, whether a component's paper declaration is true — for tens of thousands of ships that must be inventoried by 2030 and for every spare part they will buy afterwards.

Why this matters

Asbestos on ships kills twice: crews and repair workers are exposed during service, and the workers in recycling yards — the population the Hong Kong Convention was written to protect — are exposed at end of life, when an inventory that says "asbestos-free" determines how a hull is cut up. SOLAS regulation II-1/3-5 has prohibited new installation of asbestos on all ships since 1 January 2011 (with only limited exceptions since 1 July 2002), yet the IMO circular exists precisely because the ban did not hold at the supply-chain level; the circular's stated remedy is that "the principal means of addressing the issue ... rests with shipyards and ship suppliers purchasing and installing asbestos free material," backed by "due diligence" on declarations and "random confirmations." A global spare-parts trade of gaskets, packings, brake linings and insulation, much of it sourced from markets where asbestos is still legally used, cannot be policed by declarations alone. The 2030 deadline turns a chronic quality problem into an acute one: the world fleet must be inventoried under time pressure, by shipowners who "may draw upon expert assistance," with sampling limited to what can be done without "compromising the safety of the ship and its operational efficiency."

What’s been tried and why it hasn’t worked

The regulatory scaffolding is complete: the SOLAS ban (2002/2011), the IMO circular's awareness campaign and 3-year removal rule (removal by professional companies "within a time frame of 3 years from the date when the contravention is found"), the MEPC.269(68) inventory guidelines with their Material Declaration and Supplier's Declaration of Conformity templates, the EU Ship Recycling Regulation (which DNV notes has already given many vessels an approved IHM), and now the Hong Kong Convention. What has not worked is the assurance model underneath: a Supplier's Declaration of Conformity "remains valid as long as the products are present on board" and depends on the supplier having "a company policy" for chemical management — self-declaration by thousands of vendors across shipbuilding and repair supply chains — with confirmation only where a surveyor chooses to sample and a laboratory analyses the sample. The guidelines themselves acknowledge the residual gap by allowing items to be classed "potentially containing hazardous material" without sampling when sampling is impractical, deferring the question to "a later survey (e.g. during repair, refit or conversion)." Industry survey providers report that large shares of both in-service ships and newbuilds surveyed after 2011 contained asbestos despite asbestos-free declarations (a service-provider claim not independently verified here), which is consistent with the circular's language but not a substitute for it. The failure is that the control was designed as a document trail through a supply chain that does not reliably know, or disclose, what is in its own gaskets — a context the regulation assumed away.

What would unlock progress

Two kinds of advance would change the economics: (1) field-deployable screening — a low-cost, surveyor-usable test (portable spectroscopic or chemical) that triages gaskets, sealants and friction materials so that laboratory analysis is reserved for positives — and (2) supply-chain traceability that attaches verified, product-specific asbestos test evidence to marine spare parts (a marine-equipment analogue of the conformity databases used for restricted substances in electronics), so that a Material Declaration is backed by data rather than by a signature. Risk-based sampling plans built on where asbestos has actually been found (component type, supplier region, ship age and repair history) would make the 2030 inventory wave both cheaper and more accurate. The adjacent precedents are RoHS/REACH substance-declaration systems in electronics and the asbestos-survey practice developed for buildings, neither of which has been ported to the shipping spares trade.

Entry points for student teams

A data/OR team could prototype a risk-based visual/sampling-check planner for existing-ship IHMs: a scoring model over component classes, ship age, build yard region and repair history that recommends where to sample under a fixed sampling budget, taking component-class priors from the location list in MSC.1/Circ.1374 and ship-level covariates from the Paris MoU's public inspection search (https://parismou.org/inspection-search/inspection-search), since real IHM survey results are commercially confidential and no student team will obtain them. An instrumentation team could take the screening half of the problem without touching suspect material: measure portable NIR/Raman spectra of the modern asbestos-free gasket, packing and friction products a marine chandler sells off the shelf, score them against the published reference spectra for chrysotile, crocidolite and amosite in the free RRUFF mineral database (https://www.rruff.net/), and report how reliably a handheld instrument can rule a component out — the triage decision that actually saves laboratory cost. Confirmatory work on real asbestos-containing marine material is not a student door: handling it is regulated under OSHA 29 CFR 1910.1001 (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1001) and analysis belongs in an accredited PLM/TEM laboratory, so a team wanting true positive controls should buy certified reference material and partner with such a lab rather than salvage its own samples. A design/traceability team could specify a verified-declaration data schema for marine spare parts that plugs into the Material Declaration/SDoC format of MEPC.269(68); writing the schema and validating it against the published templates needs no partner, and piloting it inside a ship manager's purchasing system is an optional extension where one is available. Relevant skills: analytical chemistry/materials characterisation, operations research, supply-chain data systems, maritime regulation.