In order to make the world a safer place there is always a great progress. This leads to a plenty of new rules and regulations, where not only the crew on board, but also the employees ashore have to take care of. One of this newer regulation is the Inventory of Hazardous Materials (IHM), which is implemented by the Hong Kong International Con-vention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention) and the European Parlia-ment and the Council on ship recycling (EU SRR). The IHM certification came into force to prevent the people and environment from incidents, illness and pollution due to dangerous materials like asbestos, which might have been used, installed and built-in on existing vessels.
To get an IHM certification, the vessel will be inspected by a HazMat expert and certified by the relevant class. Messrs.
Eurofins, a company from the Netherlands, is appointed by Briese Shipping to conduct these inspections.
In first instance this means, that collecting information like battery plans, smoke detector details, lube oil charts, Mate-rial Safety Data Sheets (MSDS), plans, diagrams and much more as first input for a risk assessment is necessary, which will be carried out by the HazMat Expert.
Next instance is the sampling / inspection itself. During the inspection different samples must be taken from the vessel and visual checks will be done based on the collected ship-specific information. These samples will be analyzed in labo-ratories and findings examined through company Eurofins.
A few vessels have been inspected already and the aim is to have all vessels inspected until October 2020.
Findings of the inspection will be captured by the Hazmat Expert of Messrs. Eurofins in IHM Part I – the Structure and Equipment list. In general, the IHM is split in three parts.
Findings of the inspection will be captured by the Hazmat Expert of Messrs. Eurofins in IHM Part I – the Structure and Equipment list. In general, the IHM is split in three parts.
Part I identifies the hazardous materials that are contained in the ship’s structure or equipment, where it is located and in which quantities hazardous materials can be found. This is the relevant part for all existing ships.
Development and method of inventory For the inventory of hazardous materials, the following methodology provided by the guidelines is followed.
Step 1: collection of necessary information;
Step 2: assessment of collected information;
Step 3: preparation of visual/sampling check plan;
Step 4: onboard visual check and sampling check;
Step 5: preparation of Part I of the inventory and related documentation.
Part II (operational wastes) and Part III (stores) must be prepared before the vessel will be recycled. In case a re-cycling is scheduled, the shipowner needs to issue Part II and III and a verification is necessary. Based on the IHM, the ship recycling facility will prepare a ship recycling plan (SRP). Afterwards a final survey by the class will be done of both, IHM and SRP and a “Ready for Recycling” certificate will be issued by the class surveyor.
Part I is split in two further parts. In Table A (as defined by the Hong Kong Convention) respectively Annex I (as defined by the EU SRR) and Table B (as defined by the Hong Kong Conven-tion) respectively Annex II (as defined by the EU SRR). Table A includes hazardous materials like asbestos, PCB, ozone deplet-ing substances, TBT or PFOS, what means materials, which are mandatory to be listed, while Table B shows heavy metals, PBB, PBDE, PCN, SCCP, radioactive substances or HBCDD, which are mandatory to be listed as far as practicable.
Once the IHM Part I has been issued, same needs to be certified by a classification society. DNVGL will carry out the certification of the whole Briese fleet. This certificate is valid for 5 years and might be subject to periodical inspec-tions by the flag states, by class during renewal surveys or by port state controls. A missing IHM certificate may be a reason for a Port State Control detention.
Deadline for this full procedure is end of the year 2020, which means there is still a lot to do.
What remains important for the staff ashore and on board is to keep the records up to date and to maintain IHM Part I properly. This means, for example that every new item, which will be installed / replaced / renewed on board or if hull coating is renewed, needs to have a MSDS or Supplier’s Declaration of Conformity (SDoC) from the manufacturer or supplier, which has to be collected and retained on board.
Additionally, the Part I of the IHM shall be updated if the hazardous material situation of the vessel changes. Even for supplied products, which do not contain any hazardous materials as listed in Table B / Annex II, a MSDS or SDoC form must be collected from the suppliers. Same needs to clearly state the absence of hazardous materials.
It has to be kept in mind, that if a Port State Control officer has reason to believe that there is no procedure implemented on the board the ship for the maintenance of Part I, it might be possible that a detailed inspection will be carried out.
Of course, all vessels will be provided with detailed instruc-tions and guidelines to this special topic shortly.