The presence of hazardous materials on ships are commonplace and are unlikely to go away as they are necessary for the construction and maintenance of a vessel. Asbestos, for example, is one of the most common materials found onboard and is used primarily in the walls and doors of an engine room due to its thermal insulation and fire-resistant properties. However, it is also extremely hazardous when it is broken up and can lead to fatal diseases if inhaled. Long-term exposure to heavy metals like lead or mercury (which can be found in paints, batteries, etc) can also cause irreversible neurological damage.
As awareness of hazardous materials grows in response to the safety and environmental concerns, various efforts have been initiated by authorities to regulate the inventory and management of hazardous materials throughout the lifecycle of a ship, in particular the Hong Kong Convention and the EU Ship Recycling Regulation (EU SRR).
With the impending deadline for existing ships to comply with the EU SRR set to 31st December 2020, this could be a major cause for concern for all vessels calling at EU ports. That means most of the ocean-going fleet worldwide should comply for all practical purposes or risk restricting the trading options for their fleet. Ships are often fixed for cargo in different parts of the world on very short notice, so make sure that your ship does not get caught out by not meeting the requirements of the different port-states beginning next year.
History of IHM
In May 2009, the International Maritime Organization (IMO) adopted the ‘Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships’ at a diplomatic conference in Hong Kong (the Convention). The Convention purported to “prevent, reduce, minimize and, to the extent practicable, eliminate accidents, injuries and other adverse effects on human health and the environment caused by ship recycling, and enhance ship safety, protection of human health and the environment throughout a ship’s operating life” (Article 1).
The EU Ship Recycling Regulation No 1257/2013 came into force in December 2013 with the same purpose. The regulations set by the EU SRR is similar to that of the Convention but with additional requirements for EU ships (and any ships calling at EU ports), ship owners and ship recycling facilities, and additional substances prohibited in the Inventory of Hazardous Materials (PFOS and HBCDD).
“Hazardous Material is defined as any material or substance which is liable to create hazards to human health and/or the environment.” – Article 2
Chapter 2, regulation 5 of the Convention and Article 5 of the EU SRR sets out the requirements for every ship under the IMO and EU flag to carry and maintain an Inventory of Hazardous Materials (IHM) specifying the location and quantities of each material, verified by the relevant administration or authority.
Formerly known as a “Green Passport” in the IMO Guidelines on Ship Recycling, the IHM is ship-specific and covers the entire life of the vessel, from the construction of the vessel up to the scrapping and recycling at the end of the ship’s operating life.
The Convention will come into force two years after 15 states, representing 40% of the world merchant shipping by gross tonnage, and on average 3% of recycling tonnage for the previous 10 years, have either signed it without reservation as to ratification, acceptance or approval, or have deposited instruments of ratification, acceptance, approval or accession with the Secretary-General.
As of September 2020, 15 states have already signed but they only represent 30.21% of the gross tonnage of the world’s merchant fleet.
Who is responsible for IHM compliance?
It is significantly easier for new ships to comply with the Convention and EU SRR with regards to the creation of the IHM. During the building of the ship, suppliers are now required to provide the Supplier’s Declaration of Conformity (SDoC) and the Material Declaration (MD), which states the location and quantity of hazardous materials used in the particular part. The shipyard is then responsible for compiling the information into the Inventory of Hazardous Materials (IHM) for each ship.
When it comes to providing the MD and SDoC, it is the Tier 1 suppliers’ responsibility to request from their suppliers (Tier 2 suppliers) if they do not have the information available.
New ships are defined as “ships that are built on or after the entry into force”. Since the EU SRR has already entered into force, new EU ships, or any new ships planning to call at an EU port, are already required to comply with the IHM. As for other new ships, it is recommended that shipyards start adopting this process as early as possible to save time and resources later when the Convention comes into force.
Creating an IHM for existing ships can be a laborious process and requires a great deal of care and accuracy. It should be prepared by the shipowner with the cooperation and help of IHM professionals. Among others, this involves:
- going through the manuals and drawings of machinery and parts
- tracking repairs and modifications throughout the life of the vessel
- checking the procurement and consumption history of supplies
- preparation and review of the Visual Sampling Check Plan (VSCP), and
- testing and analysis of samples.
As mentioned above, the EU SRR’s deadline for existing ships to comply is fast approaching at the end of this year. In fact, existing ships are given a deadline of only 5 years after the Convention comes into force to comply with the IHM. Due to the amount of time that is needed to develop the IHM for existing ships, it is therefore strongly recommended that all ship owners begin the process as soon as possible.
There are 2 main certificates that should be obtained with regards to IHM: The International Certificate on Inventory of Hazardous Materials and an International Ready for Recycling Certificate. Inspections are first and foremost limited to verifying that the ship has the valid certifications. If the ship does not have both, a detailed inspection will be carried out based on the IMO guidelines.
Explained in a recent webinar by an international accredited registrar and classification society, the IHM certification is a three-step process:
- IHM preparation: In the first step, the agreement for the IHM preparation is signed, followed by an inspection onboard. After that, the IHM and the report are prepared and are submitted to the shipowner.
- RO approval: In the second step, the agreement for the IHM plan approval is signed, and the relevant documents are reviewed. Comments may be added at this stage (if any). Finally, there is the approval and the approval letter submitted to the shipowner.
- IHM initial survey: The third step involves the onboard verification of the IHM, which follows a specific checklist. The verification can last a couple of hours, after which, if everything complies, the IHM certificate or statement of compliance will be issued by the surveyor with a maximum of 5 years’ validity in harmonization with the ship’s main class renewal date.
The certification of the Ready for Recycling Certificate involves preparing and sending the IHM to a ship recycling facility that is included in the European List of Ship Recycling Facilities. The facility will then create a Ship Recycling Plan (SRP) that is specific to the ship. The owner must then request for a final survey from the ship’s flag or an RO for verification of the IHM and SRP.
Rajesh Purkar, Vice President of Product Management and Marine Operations at BASS warns, “Do not underestimate the time it takes to prepare an IHM for a vessel, let alone an entire fleet. The certification process itself can take months to complete. It is imperative that shipowners get started on the compliance process if they have not already.”
IHM in BASSnet
As part of our integrated ship management system, BASSnet now includes the features necessary to assist shipowners and designated persons with the creation and management of the IHM.
We have included registers for Hazardous Material in BASSnet for users to create a comprehensive inventory of such hazardous materials. Each material can be categorized by class (i.e. PCHM) and part of the IHM (i.e. Part 1 consists of Hazardous Materials contained in ship structure or equipment). Any item or component that contains hazardous materials can then connect to them in their respective records and be flagged as hazardous as well. For each hazardous material and component, the MD and SDoC provided by the supplier can also be attached to the record. These hazardous materials and components will be clearly indicated when selecting materials throughout BASSnet, including flagging jobs and purchase records involving them, to ensure that the crew is always aware when they are dealing with dangerous substances.
It is also important to remember that the IHM is a living document and should be kept up to date. Creating an IHM is only the first step towards compliance, and ship owners must ensure that there are procedures in place to maintain it (for more information on that, see Managing Your Inventory of Hazardous Materials). BASSnet helps you do that by keeping track of the quantity and location of items that contain hazardous materials. This is done by automatically updating the stock count in the location every time the item is consumed during a maintenance/repair job or procured in a purchase order. When purchasing a new item that contains hazardous materials, you can also directly add the MD and SDoC obtained from the supplier to the item in the purchase order.
IHM reports can then be generated at any time directly from BASSnet using the readily available data for the preparation or renewal of certification, reporting or for any other purpose where an updated IHM is required.
For more information on our IHM features, click here.