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Inventory of Hazardous Materials

Marine Mechanics

IHM

Inventory of Hazardous Material

Marine Mechanics has a strong team of DNV-GL trained IHM experts who can handle IHM for both new builds and existing ships in a professional manner, below script will give a brief description of IHM, its importance, process of obtaining and maintaining the IHM for your ships.

Inventory of Hazardous Materials (IHM) is a structured system to control hazardous materials onboard ships and achieve compliance with the EU Ship Recycling Regulation (EU SRR) and Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships.

From December 31, 2020, any ship which is 500 GT or over, regardless of flag, will require a valid and certified IHM on board if calling at an EU port or anchorage. Non-EU flagged vessels can also be certified against EU SRR by complying with the HKC IHM requirements.

IHM is a list that provides ship-specific information on the actual hazardous materials present on board, their location, and approximate quantities. The IHM has following parts:

  • Materials contained in ship structure or equipment
  • Operationally generated wastes, and
  • Stores

Why is IHM Important?

From the mid-1980s, the center of the ship scrapping industry shifted towards Asia, 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. 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. These voluntary guidelines introduced the concept of a ‘Green Passport’ Inventory for the first time. In parallel with this activity, the International Labor Organization (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.

Further, IMO adopted “The Hong Kong International Convention for the safe of environmentally sound recycling of ships” in the year 2009 followed by the EU Ship Recycling Regulation (EU SRR) in 2013 that requires every ship calling at EU Port to carry an inventory of hazardous material (IHM) verified by the relevant administration or authority and specifying the location and approximate quantities of those materials.

A comprehensively compiled IHM can help you minimize risk, potential liabilities, and enhance the safety of your ships’ crews by identifying, recording, and controlling hazardous materials onboard your ships, in line with existing and forthcoming legislation.

As well as assisting with your in-house management systems, you can demonstrate your commitment to safe and environmentally sound practices at the end of your ship’s life.

Initial IHM Survey & Part 1 Preparation

The survey can take place while the vessel is at sea or in port and our surveying teams / HazMat experts are able to meet and leave the vessel at most ports internationally.The IHM should undergo annual verification to ensure its relevance and a full re-survey of the vessel carried out every five years.

  • Collect necessary documents from vessel / owner
  • Visual Sampling Check Plan (VSCP) - assessment of vessel information.
  • Onboard verification and sampling survey - validates the information within the VSCP and with verification through sampling
  • Sample Analysis
  • Interpretation of analysis results and IHM Report delivery (in Classification specific format, where required)

Hazards that are commonly found on vessels include Asbestos, polychlorinated biphenyls (PCBs), Organotin Compounds, including TBTs and microbiological contaminants, Ozone Depleting Substances (ODS), Heavy Metals, Polybrominated biphenyl (PBBs), Polybrominated diphenyl ethers (PBDEs), Polychlorinated naphthalene’s (PCN - more than 3 chlorine atoms), Radioactive substances, Certain short chain chlorinated paraffins (SCCP - Alkanes, C10-C13), Perfluorooctanesulfonic Acid (PFOS) and Hexabromocyclododecane (HBCDD).

IHM Maintenance post Initial Survey and issuance of SOC

Having a fully compliant IHM Part I and SoC is just the beginning, all existing and newly built vessels in operation must maintain their IHM Part 1 throughout the life cycle as per IMOs MEPC 269(68) and EMSA guidelines. This means all future supplies to the vessel must be continuously and thoroughly monitored for hazardous materials, this is a requirement to get the SoC endorsed / renewed by the classification societies. To be fully compliant to these requirements, we have developed a Web-Based IHM Maintenance platform that will integrate with any procurement software to fetch the details of all the purchase orders which will be vetted by our team of experts.

MMPL’s web-based IHM Part I Maintenance Software is designed to efficiently maintain and streamline the requirements of Hong Kong Convention and EU Regulations. API integrated, plug and play software provides comprehensive reporting and tracking of all purchase orders. Tailor made software along with the company expertise has capability of being a Designated Person (DP) for IHM Maintenance. Software has the following inbuilt features:

  • Logical workflow which compares each line item of the purchase order with the coherent big database of MD and SDOC.
  • MD’s and SDOC’s are automatically tagged to the respective PO’s from the database.
  • MMPL IHM experts follow up with the vendors to collect missing MD’s and SDOC’s, automatic emails are triggered to the vendors.
  • Dedicated support to guide Ship Staff and Office Staff on IHM requirements.
  • Proactive alert system to the purchasers to stop procurement of Asbestos and other prohibited Table A materials.
  • User-friendly dashboard for Fleet Manager, Superintendent and Ship, with easy to download Certificates, updated IHM Part I and Purchase Order status.
  • Live data and IHM Part 1 status report available for PSC Inspections.
  • Software automatically updates IHM Part I by capturing all the changes, with a history of revision maintained for record purpose.
  • Provision to incorporate company specific IHM Maintenance policy and forms if required.
  • IHM Guidance and Circulars.
  • Stay in compliance with IHM regulations digitally.
  • We relieve the technical & procurement team from all the burden by acting as the Designated Person on behalf of the Ship Owner or Manager.

Beyond a business model, we see this web-based software as a customized service support tool for the Maritime Industry to methodically maintain the IHM. It is commonly noticed that majority of the vessel’s do not comply with IHM Maintenance, and it is difficult to make the Ship staff and Superintendent understand the IHM requirements. Without proper IHM Maintenance it becomes a huge task for the Ship Owners to convince the Class Surveyors to endorse / renew / re-issue the IHM certificate. This can be availed for a competitive annual maintenance fee, please contact us for a demo at mmconsultants@marinemechanics.biz and we would be happy to assist.

Asbestos Removal, Disposal & Management

As per SOLAS, ships built before 1 July 2002 can have Asbestos Contained Materials (ACMs) on board. However, the ACMs are only allowed if they do not pose a risk to the crew’s health. The crew should be aware of the dangers of asbestos and should know how to deal with asbestos in case disturbance of the ACMs cannot be avoided, it should be properly maintained with an Asbestos Management Plan as stated in MSC/Circ.1045. For Ships built after 1 July 2002, because of the serious risk to crewmembers, inspectors, and shipyard workers, every action must be taken to remove ACMs within a maximum of 3 years from the date at which it was found on board. This task must be developed in close consultation and supervision of the Flag State concerned; it should be carried out by a professional asbestos removal company.

We have tied up with asbestos abatement companies worldwide where we can arrange removal and disposal of asbestos contained materials, all our technicians are qualified asbestos experts, and the disposal will be carried out as per local government regulations.

References

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of ships

Resolution MEPC269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous MaterialDeclaration

COMMISSION REGULATION 1257/2013 - EU Regulation on Ship Recycling (SRR) Regulation (EU) and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC