Concise Guide to the Green Passport

Lloyds Register

March, 2008

This document is intended to provide a quick guide on compiling a hazardous materials inventory (Green Passport) for submission to Lloyds Register Design Support Services. It is principally aimed at existing ships. For newbuilds, the process will be managed by the Lloyds Register site team; however, the principles are the same. This guidance will be updated and extended as knowledge develops and as further information is received from bodies such as the IMO. Please check for updated versions prior to use. Lloyds Register March 2008

Lloyd's Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as the Lloyd's Register Group. The Lloyd's Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register Group entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract. Lloyds Register 2008

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Contents 1. 2.
2.1. 2.2. 2.3. 2.4.

Background The Lloyds Register Green Passport

Purpose Responsibility Initial Approval Maintaining the inventory

4 5
5 5 5 6

3.

Compiling the Inventory of Hazardous Materials Onboard

6
6 8

3.1. Starting the process 3.2. Completing the inventory

4. 5.

In-service use Some common hazards and definitions

14 15 23 24 27 30 33

Appendix I - Lists of PCB Ballasts Appendix II - Compounds Used as Refrigerants or Refrigerant Blends Appendix III - Recognition of Green Passport Sampling and Assessment Service Suppliers Appendix IV Manufacturers and Suppliers Inventory Lists for Newbuilds Appendix V Green Passport EXAMPLE 1

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1.

Background
From the mid 1980s the centre of the ship scrapping industry shifted towards Asia, in particular to India, Bangladesh and Pakistan. This industry was, and still is, virtually unregulated and has one of the worst safety records of any industry. It also causes massive environmental pollution. Initially, there was little awareness or acknowledgement of the appalling working conditions and environmental pollution. However, a concerted campaign by environmental groups has brought about widespread awareness of ship scrapping practices. Owners sending ships for scrap have also been targeted and cases are increasingly being reported in media (including the Danish Passenger ferry, Riki; the French aircraft carrier, Clemenceau, and the cruise ship, Blue Lady ex Norway). In order to address these issues, industry working groups developed the Industry Code of Practice on Ship Recycling. This guidance subsequently fed into discussions at the International Maritime Organization (IMO), which resulted in the IMO Guidelines on Ship Recycling, adopted by Member States in December 2003. In parallel to this activity, the International Labour Organisation (ILO) developed Guidelines on Safety and Health in Ship Breaking in Asia and Turkey and the Basel Convention published guidance on Environmentally Sound Management of Dismantling of Ships. The pre-existing Basel Convention on the Transboundary Movement of Hazardous Wastes also began to be applied to ships, although not originally intended for this purpose. The IMO Guidelines cover the entire ship lifecycle from design through construction and operation to preparation for scrapping at the end of the ships useful life. New concepts such as design for recycling and licensed recycling facilities are included, which will require much development before they can be implemented. However, central to the Guidelines is the Green Passport. In its simplest form, it is a summary of the ships details, accompanied by an inventory of hazardous materials onboard. This allows the owner, the recycling facility and the relevant authorities to assess the hazards involved, and the facilities required to deal with them. It has benefits not only at scrapping, but, since it is an inventory of hazardous materials, it has major safety benefits for all onboard or those visiting the ship by allowing proper identification and management of hazards. It also allows an owner to assess his financial liability with regard to the hazardous materials onboard the ship. The IMO is presently developing a new convention that is intended for adoption in April 2009. This continues to rely on the Green Passport as a fundamental element although it more properly now calls it the Inventory of Hazardous Materials The concept of the Green Passport is one that is considered by owners to be both useful and achievable at the present time. This guidance document aims to help owners compile Green Passports for their ships using the electronic template developed by Lloyds Register and the guidance contained herein.

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2.
2.1.

The Lloyds Register Green Passport

Purpose
The Green Passport is intended to comply with IMO Resolution A.962 (23), paragraph 5. It is intended to be a reasonable listing of expected or known hazards, at the time of drawing up the inventory, given in suitable detail for the Owners purposes. It is not a detailed and accurate account of each and every elemental hazard onboard the ship. As knowledge, experience and legislation develops, doubtless the inventory will develop also. This guidance is based on currently available knowledge and practices. It is published in good faith to ensure that the guidance on which Lloyds Registers Green Passport is based is fully in the public domain for scrutiny and discussion, in the spirit of enhancing safety and the environment in a new and uncertain field of knowledge. Different users will have different requirements. Ship owners will primarily be interested in safety and liability in relation to items in normal operational use. A dismantling, recycling or disposal facility is likely to require far more onerous testing of potentially hazardous material. Thus future end users, (licensed) recycling facilities, will need to identify the hazards which need to be included in the Green Passport and those items for which further information is required. Similarly, as safety and environmental legislation develops, areas within the Green Passport will be subject to greater scrutiny, and at that future point additional detail may be required. This is why the concept of maintenance and annual survey is essential to developing a Green Passport which will retain its usefulness through-life.

2.2.

Responsibility
Lloyds Register will verify that the resulting Green Passport complies with the minimum documentation requirements as set out in IMO Resolution A.962 (23), paragraph 5. In addition Lloyds Register will verify that it considers the inventory to be a reasonable listing of expected or known hazards, based on current knowledge and procedures as set out in this guidance, and on information provided by the owner.

2.3.
2.3.1.

Initial Approval Surveys

New Construction The Lloyd's Register new construction site team will review and periodically audit the processes that the ship builder has implemented to capture the hazardous materials that are used to build the ship. An example of a letter to send to manufacturers and suppliers along with a possible checklist of materials is provided in Appendix IV of this guide. In addition, the site team will undertake spot checks to ensure that the contents of the Green Passport prepared by the ship builder are an acceptable representation of the items onboard the ship. The site team will subsequently issue the Green Passport Statement of Compliance.

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2.3.2.

Existing Ships The ship operator prepares the Green Passport and submits it along with the required supporting documentation to the specified approval office (Houston, Singapore, Southampton or Yokohama Port). The approval office reviews the Green Passport and associated documentation for completeness and checks that all hazards that would be expected for ships of a similar age and type have been addressed. Initial Survey: The approval office liaises with the ship operator to arrange an onboard survey. This is to consist of a survey sufficient to have reasonable confidence that the contents of the Green Passport are an acceptable representation of the items onboard the ship, as laid down in this guidance. On completion of the onboard survey the surveyor will issue the ship with the Green Passport Statement of Compliance.

2.4.

Maintaining the inventory

For the Green Passport Statement of Compliance to remain valid the inventory must be reviewed annually, with a full verification survey completed every five years. The annual review can either be as part of the Annual Survey (Lloyd's Register class ships only) or by submitting the updated Green Passport to one of the Lloyd's Register approval offices (Houston, Singapore, Southampton or Yokohama Port). Annual Survey: This is to be sufficient to have confidence that the ships crew are updating and maintaining the Green Passport in accordance with their internal procedures and sufficient for the Green Passport to continue to be an acceptable representation of hazards onboard the ship.

3.

Compiling the Inventory of Hazardous Materials Onboard

This procedure is for existing ships. Newbuilds are different as the process is undertaken by the shipyard and the inventory verified by the Lloyds Register site team. Many of the items referred to or requested can be found in the ships onboard documentation, plans and so on. Machinery specifications should show details of gaskets, synthetic bearings, heat insulation, oils, plastics, asbestos, transformer cooling media etc. Insulation and accommodation plans should show many of the common materials in the ship. Electrical drawings and specifications should show details of wiring and wiring coverings and so on. Additional information may be found in Part 5 of this guidance.

3.1.

Starting the process

The best place to start is the ships office, or wherever the main plans/records/ documents for the ship are kept, with a computer and printer to hand. Installing, saving and testing the Green Passport template Insert the Green Passport CD-ROM into your computers CD-ROM drive and follow the installation instructions found in the Green Passport Installation and User Guide, which should have been provided with the Green Passport CD-ROM. If additional

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copies of the installation guide are required, or if there are any issues installing or opening the template, please contact the Lloyds Register representative who supplied the CD-ROM Summary instructions for data entry

Double click on one of the Click here to add fields

A pop-up window will be displayed where data can be entered, either using the drop-down menus or by entering free text

Please refer to Appendix V of this guide for an example of a completed inventory, which should be used as a guide when completing your Green Passport To start entering data, double click on one of the Click here to add fields, as marked on the previous page; a pop-up window should display, as shown on the previous page

Please note: Completion of the fields Type, Approximate Quantity and Location is
mandatory, for compliance with the IMO Guidelines on Ship Recycling. You will not be allowed to save your data unless all three of these fields have been completed, for each line of data

Please note: Free text can be added into any of the fields found in the pop-up window;
therefore, if an option does not exist it can be entered manually

Please note: Information can be copied and pasted into the Green Passport pop-up
windows from another source, if desired

The Type field has a drop-down list to select from; if you cannot find the desired Type in the drop-down list then free text can be entered

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The Location field has a pick list to select from: o click on the desired Location in the pick list and click the > button to add it to the Selected Location/s field on the right-hand side of the pop-up window click on the < button to remove a selected Location from the Selected Location/s field if you cannot find the desired Location in the pick list then free text can be entered

Click the Save button to save your data and keep the pop-up window open Click the Ok button to save the data and close the window Click the Close button to close the pop-up window without saving data After entering a line of data, click the Add New Line button to enter more data Click the Delete Line button to remove a selected row of data Further information regarding the pop-up windows can be found in the Green Passport Installation and User Guide, which should have been provided with the Green Passport CD-ROM

If you experience any problems, please contact the Lloyds Register representative who supplied the CD-ROM, providing details of any error messages.

3.2.

Completing the inventory

This guidance covers Part 1, Potentially Hazardous Materials in the Ships Structure and Equipment. Parts 2 and 3 covering operationally generated wastes and stores do not need to be completed until the ship is being prepared for recycling. In cases where testing would be required in order to establish whether a hazard exists, owners have the option not to test, but to declare the material a probable or presumed hazard. However, proper safety and environmental hazard management systems (as per the ISM code) must exist for all noted probable, possible, presumed or actual hazards. These hazard management systems are not part of the Green Passport since they are covered by the ISM code; however, the Green Passport will be available to ISM auditors, and may be used as a source of reference during the audit. Recognised Service Suppliers IMO is currently developing a convention providing globally applicable ship recycling regulations for international shipping and for recycling activities. The proposed convention, due to be adopted in 2009, defines four classes of hazardous materials; asbestos, PCBs, TBT anti fouling and CFCs / Halons and these materials should receive special attention. Owners are encouraged to employ third party subcontractors who are specialists in these fields to develop sampling

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plans to test for these materials, build better confidence in whether they are present or not and in what locations and quantity. To assist in identifying such firms, a procedure to help properly identify if the third party has the expertise and experience required is set out in Appendix III of this guide. Executive Summary Enter the ships name in the grey data entry area on the top left of the Executive Summary above the Lloyds Register logo. Enter the ships LR or IMO number on the top right hand side in the data entry area alongside Inventory number. On the basis of the detailed inventory the surveyor will briefly summarise the hazards.

1A Asbestos Does your ship contain asbestos? If Yes, enter details in the table. Alternatively, include a summary of the asbestos status of the vessel in the grey area alongside Summary of asbestos status, appending supporting documentation such as your asbestos register in Appendix A. An acceptable summary entry may include: Several types of asbestos. Distributed throughout ship. See asbestos register Appendix A If No; can you prove it? Enter details of evidence and include copies in Appendix A. An acceptable entry could be: No asbestos. See certificate Appendix A. For example, the vessel may have a certificate stating that it is Asbestos free, issued by a recognised international company. In this case, confirmation that this certificate is acceptable to Lloyds Register needs to be made at the approval stage. The vessel will also be required to demonstrate a continuous system of procurement procedures such that asbestos could not have been introduced onboard the ship. If this cannot be demonstrated, then any replacement parts or equipment must be declared presumed asbestos containing material (PACM). Third party asbestos certificates may be included in the appendix at the specific request of the Owner and under his ongoing responsibility for their validity. If the asbestos status is unknown, declare it. An acceptable summary entry may include: Asbestos status unknown. All relevant materials PACM. Alternatively, the inventory can list all known, unknown and PACM items. It is strongly recommended that a recognised service supplier be used to aid in assessing the asbestos situation.

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1B Paints TBT Anti fouling Almost all vessels will now comply with the Anti Fouling System Convention. If this is the case, the certificate will give details of whether the ship uses, or has sealed, TBT anti fouling. If the certificate records that the TBT paint was fully removed, then state this. If the TBT paint was sealed, then this should be stated and TBT paint declared as present. The AFS convention certificate should be copied into Appendix B. If the ship does not have an AFS certificate then TBT paint must be presumed and declared. Other paints Find all the records you can of paints on the ship. This should be fairly easy. Enter them on the form as demonstrated. The entry in this section could be in the form of a simple summary, with more detailed specification sheets appended in Appendix B, which is reserved for this purpose. Any relevant certificates, such as those associated with compliance with the International Convention on the Control of Harmful Anti-Fouling Systems on Ships should also be appended in Appendix B. A summary of the paint situation and any paints of known elevated hazard will be recorded in the executive summary. Older ships should be aware of the potential for high levels of lead and cadmium as well as other hazardous materials in paints.

1C Plastics and rubber materials. Plastics and rubber materials are not presently considered hazardous under normal situations or handling, unless contaminated by other hazards such as asbestos, and do not cause a hazard unless grossly mistreated (eg burnt). On account of this, detailed listing and analysis is not required, and simple summaries may be given. A general estimation as shown in the example Green Passport (Appendix V) is fine. Care should be taken regarding plastics likely to contain asbestos such as synthetic bearings, especially those used in situations of elevated heat and these should be checked carefully and findings listed as far as possible. Stern tube and pintle bearing materials need to be checked. Find any details you can from plans and include them in the inventory as per the example Green Passport provided. If you cannot find plans, your Lloyds Register memo items should state any synthetic bearings. Enter the details on the form. Similar considerations exist for insulative material, brake or windlass linings, gaskets, packing and any plastics for high temperature situations. It is generally recommended that care is taken to identify any flame retardant chemicals used in plastics or rubber materials, since brominated flame retardants or similar may have been used.

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This is especially applicable if the vessel has any enhanced fire fighting characteristics (either active or passive) such as may be found on passenger ships. However since the release of such hazards would be dependant on gross misuse, or would occur as part of the recycling process, the level of detail and analysis included is left to the owner. It is generally recommended that good records of PVC use are kept since this material is presently under international scrutiny. However, as there is no globally ratified legislation relating to PVC use at present, this is not essential. Attention should be paid to any plastic materials that may have been expanded using blowing agents which may have ODP and/or GWP (see information relating to blowing agents). A summary of the plastics and rubber containing material should be included in the Executive Summary. Since hazards specific to these materials (as opposed to known additives like asbestos or PCBs which are covered elsewhere) are not presently of major concern, the entry may be limited to a general statement.

1D Materials containing PCBs These families of materials were generally legislated out globally around 1976; however they may still have been used for the next decade. Essentially, if your ship was built after 1992 then it is extremely unlikely that it contains these substances. In older vessels, these hazards are likely to exist in transformers, fluorescent lighting ballasts, electric motor start up capacitors, paints and wire insulation. There are some simple checks you should carry out: Ask the Chief Engineer to confirm that all power transformers are air cooled. Only liquid cooled transformers carry significant quantities of PCBs and these are very rare onboard ships. If the Chief reports any liquid cooled transformers, you will need to investigate further. If not just list the transformers and their locations, and state air cooled, no PCBs. Where liquid cooled transformers are found on a ship, the liquid should be confirmed either from the manufacturers nameplate or by testing. If the transformer was built before 1992 and no details are known, it should be listed as Presumed containing PCBs Fluorescent lighting ballasts should be marked, and their markings can be traced. Ask the electrician to check all the different light fittings on the ship and list the different makes and serial numbers of the starting ballasts. There should not be too many, and this should be relatively quick to do. You can check whether the details are on the list provided in Appendix I of this guide. These items were legislated against early, but any built before 1992 should be presumed PCB containing, unless clearly marked otherwise. Check any paint specification. For ships built before 1992, the paint manufacturer may be able to advise, otherwise state unknown. For ships built after this date, state none suspected.

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Check cable list. It may be possible to trace the materials, but is probably very difficult; so for ships built before 1992, state unknown, for ships built after this date, state: none suspected.

This is quite a complicated area, but Lloyds Register will examine it in some detail. The plan approval surveyor will advise you of any further data requirements. PCBs have a threshold value of 50ppm, therefore values below this do not have to be shown, but may be useful in case legislation is tightened in the future. It is strongly recommended that a recognised service supplier be used to help assess the PCB situation.

1E Refrigerants, fire-fighting media, blowing agents and other gases installed onboard Ozone Depleting Substances (CFCs and Halons) Most ships will now list the refrigerants used in the Marpol Certification for Annex VI Record of Construction and Equipment. This can be used to identify the ozone depleting substances and to list them in the inventory. However, it does not cover CFCs etc used as blowing agents in insulative foam and other plastics, and these should be identified separately. It is strongly recommended that a recognised service supplier be used to help assess the situation onboard regarding ozone depleting substances.

Refrigerants: There will be several areas where these are located: AC units, fridges, freezers,
cold stores, inert gas cooling and so on. Each unit will have a plaque with the coolant type (eg. R-22). They should all be checked and listed. This includes cabin fridges, stand alone AC units in cabins, ECRs, workshops, galley units.

Fire-fighting: This section should list any fixed systems containing compressed gases, including
bottles in dedicated store rooms or areas. For portable systems it is unnecessary to go into great detail since it is all contained in other statutory documents such as the record of safety equipment. The fire control plan will summarise all the items required to complete the inventory. Fill in the forms with the details as per the example Green Passport. Summarise the portable systems; provide detail for the fixed systems. Note the fire control plan will also provide details of ionising smoke detectors, a radiation hazard to be included in Part 1J.

Blowing agents: Your ship will contain various foams and expanded plastics, for thermal and cold insulation, furniture and other items. This is normally very difficult to identify and can contain substances such as CFC or HCFC, which may have been used as blowing agents.

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If no information is available it should be stated unknown potentially contains ODS & GWS. In general CFCs were phased out in the mid nineties on account of their ozone depleting and global warming properties, but these gases should be suspected as being used as the blowing agent unless it can be proved otherwise. In many instances CFCs were replaced by gases such as HCFCs and HFC. HCFC have ODS and GWP characteristics and are legislated against. HFC have global warming characteristics and are likely to be restricted in the future. Any relevant information is useful and should be recorded. (Environmental data for many CFC, HCFC, HFC and other refrigerant gases is given in Appendix II).

Other gases: Compressed air for starting or control purposes should be listed with amount and
location. Other common gases are oxygen and acetylene, propane and nitrogen. Any accumulators for hydraulic systems or special gases for cargo control or inerting, such as nitrogen, should also be listed.

1F Chemical in ships equipment or machinery This area can be used for miscellaneous items such as anti freeze, engine additives, battery acids, cathodic protection (anodes), and other information you can find on the files. An important concept in this section and others is of the attached inventory. Ships maintain inventories of many items especially stores (paint stores, chemical stores, engine treatment stores). Rather than list these, it is best to simply state lube oil - see attached inventory and place the latest inventory in the appendices. Provided no major change happens to these inventories (e.g. new supplier replaces all old paints with new ones, or all old lube oils with new stock), these inventories do not need to be updated regularly.

1G Electrical and electronic equipment This section is in addition to the requirements set out in the IMO Guidelines on Ship Recycling but is included for completeness and to show compliance with major international codes such as the WEEE (Waste Electrical and Electronic Equipment) Code. The disposal of these items is potentially very complicated, thus the inclusion of these items is important. Most of these items have simple familiar generic hazards. The drop down menus in the template and the example Green Passport in Appendix V supply guidance as to how these items can be included. Care should be taken over items such as extra batteries or radioactive components. Some items may now be made from totally lead free components. This is useful information and should be included in the inventory.

1H Constructional materials This is another new area, not included in the IMO guidance, but included here for completeness. The main items are structural steel and plastic or steel pipes. You may have an aluminium superstructure, or stainless steel tanks, plastic ballast pipes, decks made from sandwich plate steel, an aluminium heli deck, etc. Any major item can be included. For steel weight, the lightship mass, as recorded in the trim and stability booklet, is an acceptable approximation.

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1J Other substances inherent in ships machinery, equipment or fittings This is similar to 1F Chemical in Ships Equipment or Machinery and should be used similarly. Radiation hazards such as ionising smoke detectors should be included here.

1K Tanks Details of ships tanks should be copied from the capacity plan, or the trim and stability booklet, and separated into oil and non-oil tanks. Capacity can be in tonnes or cubic meters. Congratulations! The form is basically complete. Parts 2 & 3 covering operationally generated wastes and stores do not need to be completed until the final voyage.

4.

In-service use
Apart from aiding safer and more environmentally sound ship recycling, the Green Passport can provide additional in service benefits. The following is a hypothetical demonstration of a how a Green Passport could work in practice.

The owner has examined his Green Passport and from this identified the principal hazards onboard his ship. Among these are three hazards that he has identified as being cost effective to deal with at the due docking survey: Halon fire extinguishing, TBT paint and two outdated fridges with CFC refrigerant that he was previously unaware of. The halon fire extinguishing has been a problem for his entire fleet, and the Green Passport has allowed him to identify which ships, and what his potential total liability for replacement is. Accurately knowing the numbers and due dates for docking has allowed him to negotiate a sizeable reduction for replacing the halon systems with a local company on a fleet basis.

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Until recently the owner had planned to seal in his TBT paint, as allowed by the International Convention on the Control of Harmful Anti-Fouling Systems on Ships. However the Green Passport provided a focus on the end of the ships life and the strong possibility that the TBT paint may need to be removed prior to recycling. Potentially, there were considerable long term savings to be made by having a complete shot blast now to fully remove the TBT and apply a non-TBT paint, rather than sealing in the TBT and having to pay for a full blast prior to recycling.

During the Green Passport survey, two fridges were found that used CFC refrigerants. This was a considerable surprise to the Owner who had an environmental policy stating that CFCs will not be used by the company. The two fridges were replaced at the docking survey by modern fridges and the potential for the company to fail to fulfil its environmental aims was reduced. The owners environmental policy identified the fact that these fridges had to be disposed of at a licensed facility. This could now be planned in advance.

5.

Some common hazards and definitions

Asbestos Probably the most familiar hazard. Many countries have different asbestos legislation, which means it is impossible to make generalisations. Unless specific information appears to the contrary, the ship should be assumed to contain asbestos. The entry may be; unknown; all relevant materials are to be treated as Presumed Asbestos Containing Material (PACM). There are several different types of asbestos with different levels of hazard but often legislation does not differentiate between them.

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Asbestos is a small sharp particle which normally causes harm by being inhaled. The particles remain in the lung and frequently cause cancer. Death is slow and painful and may be many years after exposure (typically twenty thirty years). Asbestos commonly exists in insulation, brake linings, pipe lagging, and other similar items. During the operation of the ship, it can be sealed and considered safe provided it is not disturbed. Scrapping (or repair) can cause significant damage to asbestos containing materials such that dangerous quantities of the substance are released into the atmosphere. There are no threshold values for contamination of a substance, but industrial legislation exists for numbers of particles present in the atmosphere. The IMO publishes Guidelines for Maintenance and Monitoring of On-board Materials Containing Asbestos (MSC/Circ.1045 28 May 2002).

Ballast water Non-native organisms carried in ballast water have been recognised as an environmental problem relatively recently. The IMO International Convention for the Control and Management of Ships Ballast Water and Sediments has been adopted but not yet ratified by sufficient Member States to enter into force (as at June 2006).

Bromochloromethane (BCM) A newly developed substance released in 1998 and targeted by the Montreal Protocol in 1999 for immediate phase out due to its ozone depleting potential (ODP).

Blowing agents Items such as insulative foam, comfort foam, or any expanded plastic are commonly produced by a process known as foam blowing. A blowing agent is added to the liquid plastic and this effectively boils during the solidification process, releasing tiny bubbles which expand and populate the foam. Reinforced polyurethane foam (used in the fitting out of an LNG gas ship) is produced in the same way as polyurethane foam; however chopped strand mat is added to ensure the foam can achieve suitable strength characteristics. For a 135,000 m3 gas ship there is approximately 5,000 m3 of insulation fitted. Historically the CFCs R11 and R12 had been used as blowing agents because of their low boiling point. These substances are well known as having Global Warming Potential (GWP) and Ozone Depleting Potential (ODP). Large quantities of blowing agents can be released during the manufacturing process. Large quantities of blowing agent also remain in the foam matrix. For large vessels with extensive rigid foam insulation, there may be up to 20 tonnes of CFCs.

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On account of the Montreal Protocol, CFC R12 was replaced by HCFC R141b, which was 5% less efficient. R141b, which also had ODP and GWP, was subsequently legislated against and was finally banned from the start of 2004. As the phase out of HCFC 141b has been known about for a number of years, there have been a number of alternatives put forward for consideration. In the man-made sector the newly developed HFC blowing agents, such as HFC 245fa and the flammable HFC 365mfc, can be classed as the third generation. These new HFCs have just starting to become commercially available in large quantities but are still expensive. However, they do have GWP (although not ODP) and will ultimately be phased out under the Kyoto Protocol. The fourth generation of blowing agents are the natural substances which are unlikely to be legislated against. Natural substances currently being considered are liquid carbon dioxide and some of the gaseous hydrocarbon family such as pentane. Cyclo-pentane and CO2 blown foams are now available, although they are 10-15% less efficient. However, foams made using hydrocarbons are unlikely to be suitable for applications such as LNG ships. Although the Montreal Protocol/national legislation prohibits the use of CFC and HCFC, several countries, including South Korea, have exemptions from the governing protocols which allow their continued use. If no information is available about the expanded foam or insulative foam on the vessel in, for example, cold stores, cargo refrigeration or furniture, it should be presumed to contain substances with ODP and GWP.

Carbon dioxide (CO2) One of the six greenhouse gases targeted by the Kyoto Protocol.

Cathodic protection Anodes in ships ballast tanks contain high proportions of metals. The vessel should carry details of the cathodic protection used in the ballast tanks to resist corrosion. Most anodes will be zinc or aluminium based and will contain very high percentages of these metals (aluminium anode 95% Al, Zinc anode 99% Zn). Copper, silicon, iron, mercury and/or indium may also be present in the anodes.

CFC CFC or chlorofluorocarbon compounds include refrigerants such as R11, R12 and R502. They have both global warming potential (GWP) and ozone depleting potential (ODP), as detailed in Appendix II of this guide. CFCs are chemically inert and have a long life in the atmosphere. The use of CFC is now prohibited.

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Fire-fighting systems Ships fire-fighting systems may contain several hazards. Any halon will have both ODP and GWP and should have been phased out. CO2, foam etc may also have hazards. Details of the fire-fighting system should be given.

GWP100; global warming potential This term allows comparison between the warming effects of the different greenhouse gases. It measures the relative warming effect of a gas compared to CO2 over 100 years. CO2 has an index of 1, water 0, methane 21, nitrous oxide 310, HFC up to 3000, PFC up to 10 000 and sodium hexafluoride 23 900.

HFC Hydrofluorocarbons. This group of compounds have GWP but no ODP. Hence they are not covered by the Montreal Protocol, but are one of the six greenhouse gases identified by the Kyoto Protocol. Although their use is currently allowed, these compounds will ultimately be prohibited.

Kyoto Protocol This was an agreement reached in 1997 in Kyoto, Japan at the Third Conference of the Parties to the UN Framework Convention on Climate Change (UNFCCC). It was agreed that industrialised nations needed to reduce emissions of six key greenhouse gases by 5.2% from 1990 levels, by the year 2012. The greenhouse gases are: Carbon dioxide; Methane; Nitrous oxide; Hydrofluorocarbons (HFC); Perfluorocarbons (PFC); Sulphur hexafluoride.

Mercury Mercury is found in switches, ballast gauge systems, thermometers and fluorescent lights. Fluorescent lights generally contain small amounts of mercury, pre-1988 tubes may contain about 45mg per tube. The US EPA estimates it costs $140 per tube to test if a tube contains mercury, and it expects tubes to fail. It is therefore recommended that all tubes are declared as containing mercury, unless other information is readily available. Mercury can fatally damage the brain and the kidneys. Low levels of exposure in mothers can severely damage babies and children. Inhaled mercury is very toxic and mercury will evaporate slowly so that a broken thermometer can contaminate a room to toxic levels.

Methane (CH4) One of the six greenhouse gases covered by the Kyoto Protocol.

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Methyl bromide (CH3Br) One of the ODSs identified by the Montreal Protocol. Methyl bromide is used for fumigating agricultural products including wood, and to kill pests on crops such as strawberries. The United States is presently trying to negotiate an exemption so that it can continue to use methyl bromide to fumigate wood.

Man-made vitreous fibres (MMVF) These are substances such as glass fibre, rock wool, refractory ceramic fibres, slag wool and insulation glass wool. In 2001 approximately 9 million tonnes were estimated to be produced in over 100 factories around the world.

Montreal protocol. The Montreal Protocol on Substances That Deplete the Ozone Layer was a convention signed by many countries in 1987. It set out to greatly reduce the production of materials such as CFCs and halons and has been amended several times since, generally to quicken phase outs, for instance the London Agreement of 1990 agreed the total phase out of CFCs by 2000.

Nitrous oxide (N2O) One of the six greenhouse gases covered by the Kyoto Protocol. Used in whipped cream dispensers and as a performance booster for high performance internal combustion engines.

Organotins These are a group of compounds where tin is bound to an organic (carbon containing) molecule. The organotin, tributyltin, has been widely used as a biocide in antifouling paints.

ODS (Ozone Depleting Substance) ODSs are defined in the Montreal Protocol and include CFCs, HCFCs, halons, methyl bromide, carbon tetrachloride and methyl chloroform. Strong UV light in the stratosphere breaks the ODS into either chlorine or bromine, which catalytically destroys ozone. Ozone depletion occurs over the whole planet but is most marked over Antarctica, although the so called hole is actually very pronounced thinning. Ozone blocks UVB radiation; the declining ozone layer results in greater exposure to UVB at the earths surface.

Paint Paint has historically contained many hazardous substances. In the case of anti fouling, highly toxic substances eg. TBT or copper, are routinely added in order to achieve the desired biocidal

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effects. Any vessel built before 1992 should have paint samples checked for PCBs or the paint should be presumed containing PCB. Zinc, chloride, acrylics, copper are also commonly found in paints. Paint applied before 1960 is likely to have a high lead content, and vessels of this age should declare presumed high lead content or test for it.

PBT Persistent bioaccumulative and toxic. A generic term for substances with these characteristics.

Polychlorinated biphenyls, PCB PCBs are a family of chemicals that are good electrical insulators, chemically stable, fire resistant and do not easily give off a vapour. They were thus seen as excellent components in any electrical system reliant on the above properties. PCBs have been used as dielectric filler liquids in some types of electrical equipment such as transformers, switchgear, capacitors and in the starter units of fluorescent lights and fractional horsepower motors. PCBs are often referred to as liquid or solid, however the solid type is actually a very high viscosity fluid, or embedded in a solid matrix to make it appear solid. PCBs are toxic, persistent and bio accumulative. They are virtually insoluble in water, but highly soluble in fat (hence bio accumulative). Under certain combustion conditions they may form highly toxic dioxins. In the US, small ballasts containing PCBs may be landfilled, with the caveat that later legislation may require cleanup of a site where this has been performed. Some states limit this to 1 pound of PCB per 24 hours, equivalent to approximately10-16 small ballasts. Alternatively they may be incinerated whole in a PCB incinerator, although this will be expensive and loses many valuable recyclable products. Alternatively, PCB may be separated out. Concentrated PCBs need to be permanently removed from the environment; this is normally achieved using a dedicated incinerator.

Perflourocarbons (PFC) One of the six greenhouse gases covered by the Kyoto Protocol. Include tetrafluoromethane (CF4) and hexafluoroethane (C2F6), which have very high global warming potentials and long atmospheric lifetimes. They are released as part of the semi conductor manufacturing process.

Persistant organic pollutants, POPs These are carbon containing chemical compounds which are resistant to breakdown and are bio accumulative. Exposure is associated with cancer, neurotoxic, behavioural, reproductive, immunotoxic and other effects.

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PVC PVC commonly contains more than 50% chlorine and accounts for 30% of world chlorine usage. When it is burnt a complex cocktail of gases is given off including large quantities of hydrogen chloride gas. Dioxins, carbon monoxide and chlorinated furans may also be present.

Refrigerants Prior to 1929, highly toxic chemicals such as ammonia and methyl chloride were used in refrigeration systems; however leaks could be deadly. A new type of chemical called CFC was promoted as the wonder replacement; being non toxic and non flammable. Usage boomed from the 1930s onwards with gases such as R11, R12 and R502 becoming familiar. However in the 1980s it became apparent that CFCs caused serious damage to the ozone layer as well as affecting global warming. HCFCs such as R22 (Freon) and R123 were developed as replacements. These substances have a small ODP but significant GWP and are being phased out under the Montreal Protocol and its amendments. The subsequent replacements, the hydrofluorocarbons (HFC), are not ODS but have GWP and will ultimately be phased out under the Kyoto Protocol. Environmental characteristics for many of the refrigerants which may be found onboard ship are listed in Appendix II of this guide.

Sodium hexaflouride (SF6) One of the six greenhouse gases covered by the Kyoto Protocol.

TBT, Tri Butyl Tin TBT is an organic compound containing tin. It was first used in the 1960s as an antifouling and was highly effective. However, it is an endocrine disrupting chemical, interfering with hormones, and adverse impacts have been evident in shellfish since the 1970s. This has led to the development and adoption of the International Convention on the Control of Harmful Antifouling Systems on Ships in October 2001, which ultimately will lead to the phase out of TBT based antifouling paints.

Wires, electrical Electrical wire is valuable both as an item, and due to the copper content of the conductive core. In order to reclaim the copper, it is standard practice to burn the wires on open fires, which may potentially release many harmful substances. See also plastics and insulation generally.

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Appendices

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Appendix I - Lists of PCB Ballasts

Company Aerovox Incorporated Canada

PCB Identifier Code Two possibilities: (i) Four number code on capacitor label. The first two numbers are year; last two are month (eg, Jan 1980 = 8001). PCBs are present up to and including June 1978 (7806). (ii) Six digit letter and number code stamped on capacitor. PCBs present if fifth digit is "F". Three or four digit number code on the ballast cover. The first one or two numbers indicate the month and the last two numbers are the year. PCBs are present up to and including 1978. Two letter code on ballast plate. The first letter is the month, starting with "A" for January and second letter is the year, starting with "A" for 1969 (e.g., February 1972 = BD). PCBs present up to and including December 1980 (LL). Two possibilities: (i) Seven letter and number digit code on ballast name plate. PCBs are absent if one of the two final letters is "E" and likely present if it is "T". (dii) Four number code on ballast housing. The first two numbers, when reversed, are the year (e.g., 1976 = 67) and the last two numbers are the month. PCBs are present up to and including March 1978 (8703). Same as for Canadian General Electric (above). Letter and number code on the ballast. The last four numbers represent the year and the month. PCBs may be present up to and including June 1980 (June 1980 = 8006). PCBs are present in capacitors made in 1978-79 unless there is a green "NO PCB" sticker on the ballast label. Three digit letter and number code on ballast cover. The first letter is the month (A = January) and the last two numbers are the year. PCBs are present up to and including December 1978 (L78). PCBs are absent if "N" follows the code. Coding system changed in 1980. Units made after early 1979 are marked as being free of PCBs. Treat units not marked "PCB free" and those that have digit code ending with 79 or earlier as containing PCBs. Three digit letter & number code on ballast label. 1st letter is month (A=Jan ); last two numbers are year. PCBs present up to & including Dec 1979 (L79). Eight digit letter and number code on ballast name plate. The first two numbers are the year. Assume PCBs are present up to and including December 1979. Assume PCBs present if unit not marked "PCB Free" or not clearly dated 1980 or later.

Advance Ballasts (supplied by Phillips) Allanson Division of Jannock Ltd. Canadian General Electric

Westinghouse Canada Magnatex Polygon

Magnatex Universal Manufacturing (USA) Phillips Electronics

Sola Canada Sola Electric (USA) Other Manufacturers High Intensity Discharge Lamps

Allanson Division of Jannock Ltd. puts "N" before the code if PCBs are absent. Others are usually marked "PCB" or "No PCB". Assume PCBs are present if the label is not marked otherwise. Holophane Canada Inc. puts "BAA" before its three digit code number on capacitors with PCBs. Sola Canada marks PCB capacitors with a code beginning "ACA".

Appendix II - Compounds Used as Refrigerants or Refrigerant Blends

Family CFC CFC CFC CFC CFC CFC CFC CFC CFC Refrigerant No. R-11 R-12 R-13 R-113 R-114 R-115 R-500 R-502 R-503 Name Trichlorofluoromethane Dichlorodifluoromethane Chlorotrifluoromethane 1,1,2-trichloro 1,2,2-trifluoroethane 1,2-dichloro 1,1,2,2-tetrafluoroethane Chloropentafluoroethane Azeotropic blend of R-12 and R-152a Azeotropic blend of R-22 and R-115 Azeotropic blend of R-23 and R-13 Formula CCl3F CCl2F2 CClF3 CCl2FCClF2 CClF2CClF2 CF3CClF2 CCl2F2 CHF2CH3 CHClF2 CF3CClF2 CHF3 CClF3 ODP 1 1 1 0.8 1 0.6 0.74 0.33 0.6 GWP100 4,000 8,500 11,700 5,000 9,300 9,300 6,300 5,600 11,900

Family HCFC HCFC HCFC HCFC

Refrigerant No. R-22 R-123 R-124 R-401A

Name Chlorodifluoromethane 2,2-dichloro 1,1,1-trifluoroethane 2-Chloro-1,1,1,2-tetrafluoroethane Zeotropic blend R-22/R-152a/R-124

Formula CHClF2 CF3CHCl2 CF3CHClF CHClF2 CHF2CH3 CF3CHClF CHClF2 CHF2CH3 CF3CHClF CF3CHF2 CH3CH2CH3 CHClF2 CF3CHF2 CH3CH2CH3 CHClF2 CHClF2 C3F8 CH3CH2CH3 CHClF2 C3F8 CH3CH2CH3 CF3CHF2 CF3CH3 CHClF2

ODP 0.055 0.012 0.026 0.027

GWP100 1,700 120 620 1,130

HCFC

R-401B

Zeotropic blend R-22/R-152a/R-124

0.028

1,220

HCFC

R-402A

Zeotropic blend R-125/R-290/R-22

0.013

2,690

HCFC

R-402B

Zeotropic blend R-125/R-290/R-22

0.02

2,310

HCFC

R-403A

Zeotropic blend R-22/R-218/R-290

0.026

HCFC

R-403B

Zeotropic blend R-22/R-218/R-290

0.019

HCFC

R-408A

Zeotropic blend R-125/R-143a/R-22

0.026

3,100

Family HCFC

Refrigerant No. R-409A

Name Zeotropic blend R-22/R-124/R-142b

Formula CHClF2 CF3CHClF CH3CClF2 CHClF2 CHF2CH3 C3H6

ODP 0.048

GWP100 1,400

HCFC

R-411B

Zeotropic blend R22/R-152a/R-1270

0.032

1,600

Family HFC HFC HFC HFC HFC HFC HFC

Refrigerant No. R-23 R-32 R-125 R-134a R-143a R-152a R-404A

Name Trifluoroethane Difluoromethane Pentafluoroethane 1,1,1,2-Tetrafluoroethane 1,1,1-Trifluoroethane 1,1-difluoroethane Zeotropic blend R-125/R-143a/R-134a

Formula CHF3 CH2F2 CF3CHF2 CF3CH2F CF3CH3 CHF2CH3 CF3CHF2 CHF2CH3 CF3CH2F CH2F2 CF3CHF2 CF3CHF2F CH2F2 CF3CHF2 CF3CHF2F CH2F2 CF3CHF2 CF3CH2F CH2F2 CF3CHF2 CF3CH2F CH2F2 CF3CHF2 CH(CH3)3 CF3CHF2 CF3CH2F CF3CHF2 CF3CH3 CHF3 CF3CF3

ODP 0 0 0 0 0 0 0

GWP100 12,000 550 3,400 1,300 4,300 120 3,780

HFC

R-407A

Zeotropic blend R-32/R-125/R-134a

1,990

HFC

R-407B

Zeotropic blend R-32/R-125/R-134a

2,700

HFC

R-407C

Zeotropic blend R-32/R-125/R-134a

1,650

HFC

R-407D

Zeotropic blend R-32/R-125/R-134a

1,500

HFC HFC

R-410A R-417A

Zeotropic blend R-32/R-125 Zeotropic blend R-600a/R-125/R-134a

0 0

1,980 1,920

HFC HFC

R-507 R-508B

Azeotropic blend R-125/R-143a Azeotropic blend R-23/R-116

0 0

3,850 11,950

Family HC HC HC HC HC HC HC

Refrigerant No. R-50 R-170 R-290 R-600 R-600a R-1150 R-1270

Name Methane Ethane Propane Butane Isobutane Ethylene Propylene

Formula CH4 CH3CH3 CH3CH2CH3 C4H10 CH(CH3)3 CH2=CH2 C3H6

ODP 0 0 0 0 0 0 0

GWP100 24.5 20 20 20 20 * *

Family Nat Sub Nat Sub Nat Sub

Refrigerant No. R-718 R-744 R-717

Name Water Carbon Dioxide Ammonia

Formula H2O CO2 NH3

ODP 0 0 0

GWP100 <1 1 <1

Other refrigerants from different families The GWP100 figures for the following refrigerants have yet to be confirmed. However, it is unlikely that any of these refrigerants will be considered for commercial applications. Family Methane Methane Ethane Propane Oxygen Inorganic Unsat organic Refrigerant No. R-30 R-40 R-116 R-218 R-611 R-764 R-1130 Name Methylene chloride Methychloride Hexaflouroethane Octofluoropropane Methylformate Sulphur Dioxide 1,2-Dichloroethylene Formula CH2Cl2 CH3Cl CF3CF3 CF3CF2 CF3 C2H4O2 SO2 CHCl=CHCl ODP 0 0 0 0 0 0 0 GWP100 15 TBC * 7,000 TBC TBC TBC

The above tables are not a complete list of substances which may be used, if other blends are produced meeting the appropriate ODP and GWP limits, they should also be considered. Notes 1. 2. 3. 4. 5. 6. 7. 8. Refrigerant numbers in bold are, or were, the most commonly used. Not all HCFC blends have been included many were developed but not marketed. * - signifies not known Nat Sub natural substances (not legislated against) TBC signifies to be confirmed GWP values are taken from Intergovernmental Panel on Climate Change (IPCC), 2001 Climate Change 2001: The Scientific Basis. Current as of October 2004 The use of CFC refrigerants is banned or severely restricted under the Montreal Protocol

Appendix III - Recognition of Green Passport Sampling and Assessment Service Suppliers
1. Introduction Firms providing sampling and assessment of hazardous materials on behalf of the Owner of a ship (such as samples, tests, surveys or maintenance of systems containing hazardous materials), the results of which are intended for inclusion in the Green Passport Inventory of Hazardous Materials, may be assessed against the following procedure. 2. Objectives The objective of this procedure is to set basic standards for local LR offices in assessing the suitability of firms supplying sampling and assessment services to owners regarding hazardous material contents in ships. 3. Application This procedure applies to the approval of the following categories of service suppliers, whose results may be used by the Owner in compiling the Green Passport Inventory of Hazardous Materials. Firms engaged in sampling for hazardous materials such as asbestos, PCBs, TBTs and CFCs, onboard ships, including advising on numbers and locations of samples, as well as preparing reports, quantities, locations and estimates of these materials onboard.

Hereinafter, such firms are referred to as suppliers. 4. Procedure for Recognition 4.1 Submission of documents

The following documents shall be submitted for review: List of the hazardous materials the company wishes to be recognised for, with a brief description of each material Outline of company (e.g. organization and management structure), including subsidiaries, is to be included in the approval / certification List of nominated agents Experience of the company in sampling and assessing the specified hazardous material(s) onboard ships List of operators/technicians/inspectors, documenting training and experience in assessing the specified hazardous material(s) as well as the relevant safety procedures and qualifications, according to recognised National, International or Industry Standards Description of equipment used Training programmes for operators/technicians/inspectors Checklists and record formats for recording results of the assessments Quality manual and/or documented procedures as required Evidence of approval/acceptance by other bodies, if any

Information on the other activities that may present a conflict of interest Record of customer claims and of corrective actions requested by certification bodies Where relevant, list and documentation of licenses granted by equipment manufacturers Details and accreditation of laboratories undertaking the testing for the specified hazardous material(s) including the internationally recognised testing techniques used and testing equipment available

4.2

General requirements

(a) Extent of approval. Suppliers shall demonstrate that they have the certification and experience needed to perform the sampling and assessment. (b) Training of personnel. Suppliers are responsible for the qualification and training of their personnel to a recognised National, International or Industry Standard, as applicable. The personnel shall also have adequate experience and be familiar with the operation of any necessary equipment. Operators/technicians/inspectors shall have had a minimum of one (1) year tutored, on-the-job training. Where it is not possible to perform internal training an external training program may be considered as acceptable. (c) Supervision. Suppliers shall provide supervision for all services provided. Responsible supervisors are to have had a minimum of two (2) years experience as operators/technicians/inspectors within the activity for which suppliers are approved. For a supplier consisting of one person, that person is to meet the requirements of a supervisor. (d) Personnel records. Suppliers shall keep records of the approved operators/technicians/inspectors. These records are to contain information on age, formal education, training and experience for the services for which they are approved. (e) Equipment and facilities. Suppliers shall have the necessary equipment and facilities. A record of the equipment used along with information on maintenance and calibration is to be kept. (f) Procedures. Suppliers shall have documented work procedures.

(g) Subcontractors. Suppliers shall provide information of agreements and arrangements if any parts of the services are subcontracted. This is expected only to be laboratory testing by properly accredited laboratories. (h) Verification. Suppliers shall verify that the services provided are carried out in accordance with approved procedures. (i) Reporting. Suppliers shall provide reports detailing the results of surveys, measurements, tests, maintenance and/or repairs carried out. (j) Safety. Suppliers shall provide evidence of all the necessary training and safety procedures for sampling and handling the specified hazardous material(s), and other associated work practises as necessary.

4.3

Quality Assurance System

(a) Suppliers shall have a documented management system which meets the requirements of ISO9001:2001 or equivalent, which shall include at least the following: Code of conduct for the relevant activity Maintenance and calibration of equipment Safe handling and management of the specified hazardous material(s) Training programmes for operators/technicians/inspectors Supervision and verification of operations to ensure compliance with the approved operational procedures Recording and reporting of information Quality management of subsidiaries and agents, such as laboratories Job planning and execution Periodic review of work procedures, complaints and corrective actions, and issuance, maintenance and control of documents

(b) A documented Quality Assurance System complying with the ISO 9000 Standard or equivalent, provided the system includes the above items, will be considered acceptable.

Appendix IV Manufacturers and Suppliers Inventory Lists for Newbuilds

To: All Manufacturers and Suppliers of Components and Equipment Ref.: IMO Guidelines on Ship Recycling Resolution A.962(23) Green Passport.

Dear Sirs, The International Maritime Organization has published guidelines on ship recycling. These were adopted on 5th December 2003 and are formalized as Resolution A.962(23) on Ship Recycling. To comply with these guidelines, we need to compile an inventory of potentially hazardous materials being used for the construction of the ship. To this end, we kindly request you to complete the attached form, entering the details when the components or equipment supplied by your company have any of the materials listed. If your components or equipment contain none of them, please state none in the quantity or remarks box. In the case that only some of your supplied products contain the materials listed, please indicate them in the remarks column. Please note that the following items are excluded in the newbuilding contract, or are not allowed by some legislation to which the ship is subject, or may be prohibited for other reasons. If unsure please revert to the shipbuilder.

EXAMPLES YOU MAY LIST ARE: 1) Asbestos (except as allowed by SOLAS) 2) TBT Paint as per the Anti Fouling Convention (as applicable) 3) PCB (polychlorinated Biphenyls and related family) 4) The following refrigerants, as circulating agents in cooling systems, as blowing agents in foams and in all other uses: CFC etc. 5) etc.. 10) Other items prohibited by applicable law or regulations
We would appreciate your assistance by returning the enclosed form at your earliest convenience. Kind regards,

Appendix V Green Passport EXAMPLE 1

Lloyds Register EMEA T +44 (0)20 7709 9166 F +44 (0)20 7423 2057 E emea@lr.org 71 Fenchurch Street London EC3M 4BS, UK

Lloyds Register Asia T +852 2287 9333 F +852 2526 2921 E asia@lr.org Suite 3501 China Merchants Tower Shun Tak Centre 168-200 Connaught Road Central Hong Kong, SAR of PRC

Lloyds Register Americas, Inc T +1 (1)281 675 3100 F +1 (1)281 675 3139 E americas@lr.org 1401 Enclave Parkway, Suite 200 Houston, Texas, 77077, USA

www.lr.org
March 2008 Services are provided by members of the Lloyds Register Group. Lloyds Register Lloyds Register EMEA and Lloyds Register Asia are exempt charities under the UK Charities Act 1993.