Preparing for Marine Industry HCFC Restrictions

Ship builders and owners are preparing for January 1, 2020: the day when installation of equipment containing hydrochlorofluorocarbons (HCFCs) will no longer be acceptable in any port around the world. Because HCFCs are highly ozone depleting substances, the globally agreed Montreal Protocol (PDF, 7.7 MB) has set a phaseout timetable across all sectors of the economy, with a particular impact expected in the marine industry.

HCFCs are highly versatile compounds that have been used in a range of marine applications, including:
 

• Solvents for cleaning, coating and lubricating equipment and parts that might accumulate oils, salts or other contaminants.
• Fire suppression, in traditional portable fire extinguishers and 150 lb. wheeled units.

Developed countries like the U.S. have largely completed phasing out HCFCs and developing countries have until 2030 – except in the marine industry.

Unlike equipment installed in buildings or other stationary applications, ships can dock in many countries’ ports, creating challenges in discerning Montreal Protocol compliance obligations.

As a result, the marine industry has taken a more aggressive approach to compliance. MARPOL Annex VI, regulation 12 – the International Convention for the Prevention of Pollution by Ships – requires that all countries enforce a prohibition on the installation of equipment using HCFCs on any new ships. This enables consistent enforcement and protects shipbuilders and shipowners from potential future compliance issues as well as challenges sourcing and maintaining equipment that uses a compound subject to a global phase-out.

For example,  a May 2019 Technical Circular from the Indian Registry of Shipping stated that “Ships having onboard installations of existing systems and equipment containing HCFCs are likely to have detailed inspections by the port state control (PSC) authorities.” and recommended that “In order to avoid future troubles arising out of such situations, owners and operators of the ships are advised to take stock of existing systems and equipment containing HCFCs installed on their respective ships. A suitable evaluation of existing systems and equipment with possible alternative arrangements may be carried out.”

As January 1, 2020 is approaching quickly, shipbuilders and shipowners, particularly in top shipbuilding countries such as China, South Korea, Japan, Italy and the United States, are likely to turn to their experts in solvents, coatings and fire suppression to identify sustainable solutions that will reduce the risk of interrupting shipping operations without compromising other human health, safety or environmental stewardship goals. Fortunately, tried and tested alternative solutions are available today from a range of companies, including 3M™ Novec™ fluids for solvent cleaning, coatings, lubrication and fire suppression.