The concept of an inventory for hazardous materials was first introduced as a means to improve the handling and breaking of hazardous materials when ships are scrapped at the end of their operating lives (for a summary and history of the IHM, see Inventory of Hazardous Materials (IHM): A Brief Explanation). However, the presence of hazardous materials onboard also affects the health and safety of crew and external resources, and it has an impact on the environment should unforeseen circumstances occur while in operation.
As such, the IHM should be treated as an integral part of ship management and should not be overlooked after the initial creation of the inventory. This sentiment is reflected in Regulation 5.3 of the Hong Kong Convention that the IHM “shall be properly maintained and updated throughout the operational life of the ship”.
Ships may also be subjected to inspections by authorized officers of flag states and port states to determine that the ship’s IHM remains compliant. Any inconsistencies in the inventory will be reported to the flag state and an alert message will be recorded. Similar audits and inspections will also take place during vetting by charterers and oil majors, so the upkeeping of IHM is also important commercially.
The continued conformity of the IHM extends beyond inspections and ship recycling regulations. For example, if a ship is due for dry docking, yards are likely to request for the updated list of hazardous materials on board before allowing the ship to dock. When requesting assistance from external parties such as salvage and tug companies, they would also want to know what hazardous materials are on board as proper equipment and procedures may be required.
Paragraph 5.2.1 of the IMO Guidelines for the Development of IHM (Res. MEPC.269(68)) requires that the shipowner “designate a person as responsible for maintaining and updating the inventory. The designated person may be employed ashore or on board”.
This person should be a qualified IHM professional or, lack thereof, should acquire the proper knowledge, qualifications and training on the relevant legislation, as they will be responsible for making sure that it continues to conform with the Convention and EU SRR.
They should also be familiar with the best practice guidelines by IMO and European authorities such as the European Maritime Safety Agency (EMSA) and European Community Shipowners’ Associations (ECSA) to assist the shipowner in setting up a system to maintain and update the inventory.
Besides that, the designated person is also responsible for recording all the relevant changes for any conversion or repair works undertaken on the ship. This includes an updated IHM report for any new installations or changes to the structure, machinery and equipment on the ship. In the case of a survey or sale of the ship, they are also to provide any relevant documents as required.
It must not be forgotten however that, despite the important role of the designated person, the shipowner is the one primarily responsible for the maintenance of the IHM during the entire lifetime of the ship.
Lifetime Quality Management System
Paragraph 5.2.2 of the IMO Guidelines for the Development of IHM (Res. MEPC.269(68)) requires that a system be established to ensure the necessary updating of the inventory. This system should be developed by the shipowner in collaboration with a competent IHM expert to establish the proper communication lines and procedures that should be in place to maintain compliance of the IHM throughout the ship’s life.
The EMSA Guidance on IHM outlines the requirements for such a system:
- Specific provisions to safeguard the quality and continuity of the IHM when building, buying or selling a ship, or changing ship’s registry or ship’s IHM designated person.
- Identify the procedures to safeguard the proper updating of the IHM during scheduled or unscheduled works involving changes, replacements or repairs to the structure, equipment, systems, fittings, arrangements and material, which has an impact on the IHM.
- Proper maintenance of an archive of all associated documentation.
- New installations of equipment, repairs and refitting are accompanied by a Material Declaration (MD) and the Supplier’s Declaration of Conformity (SDoC), as provided by the suppliers of parts and equipment delivered.
- Targeted or random sampling policies to identify the presence or absence of hazardous materials contained in equipment, systems and/or areas on board a ship by suitable methods such as laboratory analysis.
- A software tool may be used to support the IHM development and maintenance process, and the management of all the relevant documents, information and data.
It is important to also pay close attention to items or components that could potentially contain hazardous materials (PCHM) and understand their properties. Every effort has to be taken to clear the PCHM list as quickly as possible by investigating and gathering evidence (i.e. analyse the MD and SDoC, testing, sampling, etc) to either classify as a hazardous material or not. Until then, the designated person should monitor any purchase orders and job orders involving PCHM and update the IHM when a PCHM is successfully classified.
Where do we go from here?
“Although the original intention of the IHM is focused on the scrapping of ships, its ultimate goal is to enhance ship safety and the protection of human health and environment throughout a ship’s operating life,” Haakon Dalan, Vice President at BASS re-iterates. “With that in mind, the inventory should not and cannot be a one-off document created for the sake of getting over the first hurdle of compliance. It has to be maintained as part of day-to-day operations in order to meet these goals.”
The IHM should be treated as a living document and must be kept up-to-date and accurate at all times following the management system put in place to ensure that it remains relevant whenever it is required. Failure to do so may cost irreparable damage to anyone and anything exposed to such dangerous substances.
IHM in BASSnet
As part of our integrated ship management system, BASSnet now offers a complete end-to-end solution for creating, managing and reporting of 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.
As alluded to in this piece, the creation of the IHM is only the beginning. BASSnet helps you maintain the inventory 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 certification renewal, reporting or for any other purpose where an updated IHM is required.
For more information on our IHM features, click here.