Inventory of Hazardous Materials FAQ

All have heard/read about the new regulation IHM (Inventory of Hazardous Materials). From January 2021 all vessels must have an IHM certificate on board. Therefore we have to start with the short FAQ

FAQs

After reviewing a lot of SDoC MD Logs and receiving a lot of questions I would like to give you the following on hand:

SDoC/MD or Material Safety Data Sheets (MSDS)? What is needed for which items?

Generally: for IHM Part I items you need an MD. - see your IHM Maintenance Manual and the MEPC.269(68) which is on your IHM Disc. -they are listed.

IHM Part I relevant items are items which contain

Table A - Materials listed in appendix 1 of the Annex to the Convention

No.	Materials		Inventory			Threshold value
No.	Materials		Parti	Part II	Partill	Threshold value
A-1	Asbestos		X			0.1%⁴
A-2	Polychlorinated biphenyls (PCBs)		X			50 mg/kg"
A-3	Ozone depleting substances	CFCs	X			no threshold value⁶
		Halons	X
		Other fully halogenated CFCs	X
		Carbon tetrachloride	X
		1,1.1-Trichloroethane (Methyl chloroform)	X
		Hydrochlorofluorocarbons	X
		Hydrobromofluorocarbons	X
		Methyl bromide	X
		Bromochloromethane	X
A-4	Anti-fouling systems containing organotin compounds as a biocide		X			2,500 mg total tin/kg'

Table В - Materials listed in appendix 2 of the Annex to the Convention

No.	Materials	Inventory			Threshold value
No.	Materials	Parti	Part II	Part III	Threshold value
B-1	Cadmium and cadmium compounds	X			100 mg/kg⁸
B-2	Hexavalent chromium and hexavalent chromium compounds	X			1.000 mg/kg⁸
B-3	Lead and lead compounds	X			1.000 mg/kg⁶
B-4	Mercury and mercury compounds	X			1.000 mg.'kg®
B-5	Polybrominated biphenyl (PBBs)	X			50 mg/kg⁵
B-6	Polybrominated diphenyl ethers (PBDEs)	X			1.000 mgjkg⁸
B-7	Polychlorinated naphthalenes (more than 3 chlorine atoms)	X			50mg/kg¹⁰
B-8	Radioactive substances	X			no threshold value¹¹
B-9	Certain shortchain chlorinated paraffins (Alkanes. C10-C13, chloro)	X			1%¹²

From experience and interviews indicative lists - see page 30 ff. of attached MEPC.269(68) - had been developed where different hazardous materials had been found. For these mentioned items you must request a MD if they are not already mentioned in the below list.

The relevant pages with the indicative listings are attached separately, so that you can hand them to the persons involved.

For ship stores as being Part II/III items (to be listed if vessel will be recycled) and which are containing HM (and not being item of Part I, for example paint), such as chemicals, special glues, special sprays etc. you do NOT need a MD - just a MSDS due to safe working procedures - if it is not properly labeled.

Table C - Potentially hazardous items

No.	Properties		Goods	Inventory
No.	Properties		Goods	Parti	Part II	Part III
C-1	Liquid	Oiliness	Kerosene			X
C-2			White spirit			X
C-3			Lubricating oil			X
C-4			Hydraulic oil			X
C-5			Anti-seize compounds			X
c-e			Fuel additive			X
C-7			Engine coolant additives			X
C-8			Antifreeze fluids			X
c-e			Boiler and feed water treatment and test re-agents			X
C-10			De-ioniser regenerating chemicals			X
C-11			Evaporator dosing and descaling acids			X
C-12			Paint stabilizers/rust stabilizers			X
C-13			Solvents/thinners			X
C-14			Paints			X
C-15			Chemical refrigerants			X
C-16			Battery electrolyte			X
C-17			Alcohol, methylated spirits			X
C-18	Gas	Explosives/ inflammables	Acetylene			X
C-19			Propane			X
C-20			Butane			X
C-21			Oxygen			X
C-22		Green House Gases	CO2			X
C-23			Perfluorocarbons (PFCs)			X
C-24			Methane			X
C-25			Hydrofluorocarbon (HFCs)			X
C-27			Nitrous oxide (N2O)			X
C-28			Sulfur hexafluoride (SFs)			X
C-20	Liquid	Oiliness	Bunkers: fuel oil			X
C-30			Grease			X
C-31			Waste oil (sludge)		X
C-32			Bilge and/or waste water generated by the after-treatment systems fitted on machineries		X
C-33			Oily liquid cargo tank residues		X
C-34			Ballast water		X
C-35			Raw sewage		X
C-36			Treated sewage		X
C-37			Non-oily liquid cargo residues		X
C-38	Gas	Explosibility/ inflammability	Fuel gas			X

No.	Properties	Goods	Inventory
No.	Properties	Goods	Parti	Part II	Part III
C-39	Solid	Dry cargo residues		X
C-40		Medical waste.'!nfectious waste		X
C-41		Incinerator ash¹³		X
C-42		Garbage		X
C-43		Fuel tank residues		X
C-44		Oily solid cargo tank residues		X
C-45		Oily or chemical contaminated rags		X
C-46		Batteries (ind. lead acid battenes)			X
C-47		Pestiddes/insectidde sprays			X
C-48		Extinguishers			X
C-49		Chemical cleaner (ind. electrical equipment deaner. carbon remover)			X
C-50		Detergentibleacher (could be a liquid)			X
C-51		Miscellaneous medicines			X
C-52		Fire fighting dothing and Personal protective equipment			X
C-53		Dry tank residues		X
C-54		Cargo residues		X
C-55		Spare parts which contain materials listed in Table A or Table В			X

All other general consumable items and ship stores, which are NOT going to be fixed to the ships construction or that will NOT be mounted into any vessel's machinery equipment do NOT need any MD.

Old order forms are sometimes still in use

Don't use the old forms anymore! Even if you still used them and did not set a “x” for IHM relevant items you must review them by November 2020. IHM relevant items to be listed in the log and MD must be ordered with Purchase Dept.

Insert all orders into the log

Pls note that all orders must be inserted. In case no IHM relevant item is in the order, then just insert "none" as per my example I sent to you initially. The point is, that during future inspections, they want to see that you reviewed all orders, and you will keep a better overview!

SDoC MD Logs for Engine and Deck orders

It is your free choice if you make a Log for Engine and Deck orders separately (some prefer to do so) but in that case both must be filed and sent. Keep in mind that this is a LIFETIME log! Save it properly on your computer.

Filing of SDoCs/MDs and Material Safety Data Sheets (MSDS) / SDOC MD log

Should be filed directly behind the delivery notes in the Deck and Engine order folders

The SDoC MD log(s) in the front of each folder

So, you always have a direct view what you received and what is still missing.

This is also important in case of any PSC, flag state or class inspection. Then you have everything on hand immediately.

Missing SDoC's/M Ds

In case you did not receive any you have to order it in general from your PIC in the Purchase Dept. and you must insert the date into the SDoC MD Log. This is important to proof the constantly maintenance of the IHM Inventory. This should be done directly after receiving of goods - pls take care about it in future.

MDs for identical IHM relevant parts necessary?

MDs for identical parts ordered are not needed if you are holding an MD for the same part from same maker from last delivery or if the part was already sampled with the initial IHM Inventory Report. Otherwise, you cannot prove that it is free of HM.

Battery list

If it differs from the initial one you sent to me because you got a new type etc. then you must make an update, file the update in your IHM folder and send a copy to me so that I can drop it down into the DNV IGS Server. Keep in mind that this list must be maintained constantly.

400

Neptune