Maintenance of IHM Part I
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What to Do If ODS Is Detected in Foam Insulation of Cold Storage Room
The detection of Ozone Depleting Substances (ODS) onboard ships has increasingly come under scrutiny as part of compliance with MARPOL Annex VI and the Inventory of Hazardous Materials (IHM) requirements. While most are familiar with ODS in systems like refrigeration or fire suppression, less is understood about their presence in foam insulation, particularly in cold storage rooms.
In one recent case, a classification society advised a shipowner to remove cold room insulation foam after it was found to contain ODS-based blowing agents. The shipowner, seeking clarity, approached us as their consultant and service provider. Upon review, we explained that the regulatory control measures do not apply to such sealed materials, and removal was not required under IMO regulations.
Foam insulation, such as polyurethane used in cold storage rooms, may contain blowing agents like CFC-11 or HCFC-141b — substances regulated under MARPOL Annex VI. However, these ODS are encapsulated within the foam and do not pose a release risk under normal conditions unless the material is cut, burned, or otherwise disturbed.
The control of ODS onboard is governed primarily by MARPOL Annex VI, Regulation 12, which prohibits intentional release of ODS and requires recording their use in designated systems. However, the regulation also explicitly states:
“The controls in this regulation do not apply to permanently sealed equipment without charging connections or removable components; this typically covers items such as small, domestic type refrigerators, air conditioners and water coolers.”
Although insulation foam is not classified as equipment, the principle applies: the material is sealed, non-serviceable, and does not have any charging or discharge mechanism. Therefore, it falls outside the regulatory scope of immediate removal requirements.
Additionally, the IMO’s MEPC.269(68) guidelines for IHM clearly require such materials to be:
– Identified and documented (in Part I of the IHM), and
– Handled responsibly at the ship’s end-of-life, not during normal operation.
After evaluating the test results and reviewing the regulatory context, we informed the ship owner that:
– There was no violation in having ODS present within sealed insulation foam.
– Removal was not required, as the material posed no operational or environmental risk.
– The appropriate compliance measure was to update the IHM to reflect the presence of ODS in the foam insulation and maintain awareness for safe handling at recycling stage.
This response was well received and addressed the classification society’s initial concern, which likely arose from a common misinterpretation of the scope of MARPOL Annex VI controls.
| Action | Description |
|---|---|
| Identify & Confirm | Use LAB testing, or MD and SDoC |
| Document in IHM | Include in Part I under ‘Ozone Depleting Substances’ |
| Do Not Remove | Avoid disturbing foam; sealed materials are exempt |
| Communicate | Proactively clarify with class/flag if needed |
| Plan for Recycling | Inform the ship recycling facility at end-of-life |
The discovery of ODS in cold storage room insulation can raise compliance concerns, but as long as the material is sealed and undisturbed, it is permissible to remain onboard. Classification societies, shipowners, and inspectors must be guided by the intent and specifics of the regulations to avoid unnecessary removals and ensure both compliance and environmental responsibility.
By ensuring proper identification, documentation, and communication, such cases can be resolved efficiently, maintaining operational continuity without compromising on safety or regulation.
