IMO Performance Standard for Protective Coatings 19th June 2006 Joo-Sung Park/Statutory Service Team

Adoption: To be adopted by MSC 82(Dec. 2006) Amendment to SOLAS regulation Amendment of SOLAS Reg. II-1/3-2 to introduce mandatory protective coating requirements in SOLAS Adoption: To be adopted by MSC 82(Dec. 2006) Enter into force: 1 July 2008 Scope Maintenance and Repair: Guidelines to be developed later 2. SOLAS Reg. XII/6.3(for bulk carriers): deleted as of 1 July 2008 Mandatory performance standard by the SOLAS II-1/3-2: “PERFORMANCE STANDARD FOR PROTECTIVE COATINGS FOR DEDICATED SEAWATER BALLAST TANKS IN ALL TYPE OF SHIPS AND DOUBLE-SIDE SKIN SPACES OF BULK CARRIERS”

APPLICATION DATE Contract date base: Vessel(s) contracted on or after 1st July 2008 or Delivery date base: Vessel(s) delivered on or after 1st of July 2012 APPLICATION SCOPE Dedicated seawater ballast tanks in all vessels above GT 500 T and above Double –side skin spaces in bulk carriers of 150m in length and above Permanent Means of Access(PMA): shall be applied to structural strength members and recommend to apply for non-structural strength members EARLY IMPLIMENTATION  By MSC circular to be approved by MSC 82 Bulk Carriers of 150 m and above: The SOLAS Contracting Government may apply the PSPC in advance for the ships in its flag constructed on or after 1 July 2006(I.e. ships under SOLAS Reg.XII/6.3)

The Contents of PSPC  (MSC 81/WP.13, Annex 3) PURPOSE DEFINITIONS GENERAL PRINCIPLES COATING STANDARD COATING SYSTEM APPROVAL COATING INSPECTION REQUIREMENTS VERIFICATION REQUIREMENTS ALTERNATIVE SYSTEM ANNEX 1: TEST PROCEDURES FOR COATING QUALIFICATION FOR BALLAST TANK OF ALL TYPES SHIP AND DOUBLE-SIDE SKIN SPACES OF BULK CARRIERS COATING - APPENDIX 1: TEST ON SIMULATED BALLAST TANK CONDITION - APPENDIX 2: CONDENSATION CHAMBER TEST ANNEX 2: EXAMPLE OF DAILY LOG AND NON-CONFORMITY REPORT ANNEX 3: DRY FILM THICKNESS MEASUREMENTS ANNEX 4: STANDARDS REFERENCE TO THE PERFORMANCE STANDARDS ON PROTECTIVE COATINGS

DEFINITIONS DFT, NDFT Edge Grinding Hard coating Target useful life: 15 years Technical Data Sheet GOOD condition GENERAL PRINCIPLES - The coating ability to reach target life 15 yrs : depend on type of coating system, steel preparation, application, coating inspection and maintenance - Inspection of surface preparation and coating process: shall be agreed between ship owner, shipyard and coating manufacturer - Coating Technical File(CTF): shall be reviewed by Admin. or RO and be provided on board: Type approval cert. Technical Data sheet, Records of coating application, inspection and repair procedure during construction, procedure for in-service maintenance and repair of the coating system

COATING STANDARD Coating system - Selection of coating system: Deck and tank boundaries to withstand repeated heating/cooling - Coating type:epoxy based system(other type shall comply with test in Annex 1) - Pre-qualification test: * Epoxy based system shall be tested in accordance with Annex 1 or equivalent test procedures (e.g. Class B1?) * Documented field exposure results(5 yrs) also acceptable * New coating system shall be tested according to Annex 1 Job specification Rust, grease, dust, salt, oil, etc. shall be removed prior to coating Abrasive inclusions embedded in the coating shall be removed

COATING STANDARD Job specification - Stripe coating There shall be a minimum of two stripe coats and two spray coats, except that the second stripe coat, by way of welded seams only, may be reduced in scope where it is proven that the NDFT can be met by the coats applied in order to avoid unnecessary over thickness. Any reduction in scope of the second stripe coat shall be fully detailed in the CTF. Stripe coats shall be applied by brush or roller. Roller to be used for scallops, ratholes, etc. only. The application scope of brush may have a different interpretation according to the personnel knowledge, background and experiences. A strong necessity for development of a stripe coating tool which is combined two characteristic of roller and brush to improve quality and efficiency of stripe coating

NDFT 320 Microns with 90/10 rule COATING STANDARD NDFT NDFT 320 Microns with 90/10 rule - max. TDFT -> according to manufacture’s spec. - Gauge type: SSPC-PA2 About 7% of paint material cost increase Increase application M/H and material cost due to the relatively wider range of DFT than Current Standard iii. More potential risk for high DFT (may impact on progress) Current Standard NDFT NDFT 300 Microns with 80/20 rule Sampling test result: DFT measuring based on the Current Standard 2 coats 300 ㎛ Mean 571.92 ㎛ Max. 1,470.00 ㎛ No. of Readings 100 (100%) STD Deviation 266.06 ㎛ Min. 251.00 ㎛ Reading above 23 (3%) Coef. of Vari. 46.52 ㎛ High Limit 700.00 ㎛ Reading below 7 (7%) Low Limit 300.00 ㎛

COATING STANDARD Primary surface preparation - Blasting and profile: Sa 2 ½ (profile: 30- 75 ㎛) (average?) – ISO 8501-1 * restriction: humidity 85% or above, surface temp. below 3℃ - ISO 8503-1/3 * surface cleanliness and roughness profile check before application - Salt limit(NaCl): ≤ 50 mg/㎡ (ISO 8502-9 Conductivity test) - Shop primer: * Inhibitor free zinc silicate based or equivalent * Compatibility with main coating system: shall be confirmed by coating manuf.

COATING STANDARD Secondary Surface Preparation(SSP): Steel condition - Edge Grinding The steel surface should be prepared so that the coating selected can achieve an even distribution at the required NDFT and have an adequate adhesion by removing weld spatter and any other surface contamination in accordance with ISO 8501-3 grade P2. Edges to be treated to a rounded radius of minimum 2mm, or subjected to three pass grinding or at least equivalent process before painting. The amount grinding activities will tremendously be increased at block assembly stage. A strong necessity for development of a grinding tool or process to mitigate the huge burden for labor and progress management.

COATING STANDARD SSP – surface treatment At block assembly stage Damaged surface of shopprimer and welds: SIS Sa 2½ ( ISO 8501-1) Compatible intact surface of shopprimer: Sweep blasting, high pressure water washing or equivalent method. (cf. compatible zinc silicate shop primer - cross over with other epoxy coatings: appdx. 1) Intact shop primer not compatible with the main coat: Sa 2 (70% removal) After erection Butts: SIS St 3 or better or Sa 2½ where practicable. (ISO 8501-1) Small damages up to 2% of total area: St 3 Contiguous damages over 25m2 or over 2% of the total area of the tank: Sa 2½ (definition of damage, calculation of damaged area?, 순차적인 덧칠로 해결?) Block division, erection procedure, working process should be take into account the limit of the amount of coating damages, erection butts to avoid the application of the blasting after erection.

Sampling of Current Standard for DUST grade COATING STANDARD i Dust grade “1” for dust size class “3” to “5” by means of adhesive tape test (ISO 8502-3) Ii Dust size classes “1” and “2”: shall be removed if visible (naked eye) SSP - DUST Dust Size (ISO 8502-3) 0 : Particles not visible under x10 magnification 1 : Particles visible under x10 magnification but not with normal or corrected vision(usually particles less than 50㎛ in diameter) 2 : Particles just visual with normal or corrected vision (usually particles between 50㎛ and 100㎛ diameter) 3 : Particles clearly visible with normal or corrected vision(particles up to 0.5mm in diameter) 4 : Particles between 0.5mm and 2.5mm in diameter 5 : Particles lager than 2.5mm in diameter Sampling of Current Standard for DUST grade Ceiling Wall Floor

ISO 8502-6: Extraction methodology (Bresel only ?) COATING STANDARD ISO 8502-6: Extraction methodology (Bresel only ?) ISO 8502-9: Assessment of soluble salt by conduct metric Soluble salt limit ≤ 50 mg/m2 of NaCl (Pre-washing is not explicitly required) A test result for the comparison of the content of Sodium Chloride in Total Dissolved Salt

QUALIFICATION OF COATING INSPECTOR i. NACE CIP(COATING INSPECTOR PROGRAM): LEVEL II, or ii. FROSIO(NORWEGIAN STANDARD NS 476): LEVEL RED, or Iii Equivalent as verified by Administration or RO - Inspection items: Table in para 6.2 Recordings: results from the inspection shall be recorded by the inspector and shall be included in the CTF – daily log and NC report. Current Status for Certified Coating Inspector (May, 2006) No. of Inspector No of Certified Remarks (FROSIO) Ship Builder 240 39 (16%) 7 major ship yard in Korea Paint Maker 507 78 (15%) 6 major paint Maker in Korea Increased inspection activities for DFT measurement acc. to Annex 3 Increased documentation for provision of CTF. Increased activity for the test such as dust, soluble salt, profiles, etc. Other activity for approval of the quality control system Ship Builder 480 At least, more than two times of the present coating inspectors are necessary to meet the PSPC comparing with the current shipbuilding standards. Paint Maker 1,014

More clarification is needed VERIFICATION REQUIREMENTS Type Approval, Quality Control and Verification Approve quality control system?) Type Approval of Costing System – by a third party (Who can be a third party?) Coating Administration Manufacturer or R.O Technical Data Check Sheet Type Approval Paint Test Test Lab. Type Approval Issue Cert. check Preparation of Coating Technical File ? Approve quality control system ? (How ?) Ship Builder Coating Verify Who will employ the inspectors ? Inspector Coating Inspection Monitoring Should IACS do direct coating inspection rather than monitoring? Inspection Check (How ?) Report Approval of Quality Control System of the ship yards? Coating Review Technical File Ship Owner More clarification is needed Safety Construction Issue Certificate

ANNEX 3 DFT measurements The following verification check points of DFT are to be taken: .1 one gauge reading per 5 m2 of flat surface areas; .2 one gauge reading at 2 to 3 meter intervals and as close as possible to tank boundaries, but not further than 15 mm from edges of tank boundaries; .3 longitudinal and transverse stiffener members: One set of gauge readings as shown below, taken at 2 to 3 meters run and not less than two sets between primary support members; Note: Arrows of diagram indicate critical areas and should be understood to mean indication for both sides. .4 Three(3) gauge readings for each set of primary support members and 2 gauge readings for each set of other members as indicated by the arrows in the diagram; .5 for primary support members (girders and transverses) one set of gauge readings for 2 to 3 meters run as shown in figure 3 above but not less than three sets; .6 around openings one gauge reading from each side of the opening; .7 five gauge readings per square meter (m2) but not less than three gauge readings taken at complex areas (i.e. large brackets of primary support members); and .8 Additional spot checks to be taken to verify coating thickness for any area considered necessary by the coating inspector.

Expected additional man power Construction schedule delay (Day) Evaluation sheet Items Expected increase of ship building cost based on evaluation of new performance standards Expected additional man power (Area/persons) Remarks Cost (USD) Man power (M/H) Construction schedule delay (Day) New facilities (USD) Total (USD) NDFT 320 ㎛ (90/10) Dust (ISO 8502-3) Soluble Slat (ISO 8502-6, 9) Stripe coating Edge grinding (ISO 8501-3, P2) Secondary surface preparation Block Hull Qualified Inspector Verification DFT measurement (ANNEX 3) Others (incl. provision of CTF)