Maritime Services
Ship Purchasing/Transfer of Ownership
The US Maritime Administration (MARAD) which is part of the Department of Transportation has the authority to halt the transfer of ownership of US Flag vessels to another registry and/or to a non-US citizen owner based on environmental conditions in the vessel. In particular, MARAD/EPA approval must be obtained confirming that the vessel does not contain products containing PCBs greater than 50 ppm. This restriction is enacted since the transfer would violate TSCA's prohibition on the exportation of PCBs. This approval process applies even if the vessel is not being sold for scrap/decomissioning, regardless of when the vessel was built, or if it is being sold to foreign buyers for continuous use.
Per MARAD/EPA guidelines, AET develops sampling plans to evaluate non-liquid PCBs in vessels based on the gross weight of the vessel as sold in long tons. A minimum of 15 representative samples of non-liquid PCB containing products is required in this evaluation. PCB samples are analyzed utilizing EPA Extraction (Soxhlet) Method 3540C and PCB Analysis Method 8082. In addition, standard liquid PCB evaluations are required.
AET's statistically valid sampling plan includes all three stratum detailed in the MARAD/EPA guidelines and is prepared by CIH/CHMM staff.
- Stratum 1: Electrical cables
- Stratum 2: Gaskets in air handling systems
- Stratum 3: Rubber and felt gaskets, thermal insulation material (fiberglass, felt, foam and cork), sound deadening felt, paints/coatings, grouting/caulking, rubber insulation mounts, foundation mounts, pipe hangers, adhesives/tapes, etc.
AET's vessel surveys also involve comprehensive investigation and documentation of other related environmental contaminants.
- Asbestos: Routinely found in the engine room
- Lead-Based Paint: Ongoing preventative maintenance or painting during repairs or retrofits rarely involve paint removal to the bare metal.
- Freon: In refrigeration systems including water coolers and small freezers.
- Halon and Carbon Dioxide in fire suppression systems.
- Mercury in gauges, tank-level indicators, electrical switches or fluorescent light tubes.
- Hazardous materials and chemicals
- PCB oils and hydraulic fluids in transformers, capacitors and fluorescent light ballasts.
Ship Breaking (Dismantling, Recycling, Disposal)
Ship breaking is the process of dismantling an obsolete ship, commercial barge or mobile off-shore drilling unit. Whether dismantling is conducted at a pier, dry dock, or dismantling slip, AET's experts can assist you in health and safety compliance for your employees or environmental impact issues.
Our OSHA compliance services include:
- Asbestos removal and disposal
- Noise monitoring and controls
- Lead and other toxic fumes during cutting, burning or removal
- Safety (including electrical shock) and confined space
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