A detailed document outlaying all potentially hazardous material onboard a vessel

• Hazardous material is any substance that can pose a risk to the health and safety of people or to the environment as identified and listed by the Hong Kong Convention (2009) & EU Regulation 1257/2013
• Inventory of Hazardous Material (IHM) is a document in which all potentially hazardous materials onboard a vessel are identified, located and quantified and follows IMO Resolution MEPC.269(68) guidelines.

Hazardous Material Inventory (Inventory of Hazardous Materials-IHM)

As you know, as of December 31, 2020, an Inventory of Hazardous Materials (IHM) has been approved for all ships above 500 GT that will visit the EU ports and iron fields. IHM Part I and its certification will be checked frequently and meticulously whether it has been properly prepared in the EU port state controls and whether necessary updates have been made.

There are many classes of hazardous substances to be checked for IHM Part I. The IHM Part I hazardous materials analyzes specified in the regulation, including asbestos analyzes, are carried out by our Accredited Laboratory.

In general, more than 35,000 ships in total will need IHM under these rules. Given the current situation with the Covid-19 and pandemic process experienced worldwide, it does not seem possible for HazMat Experts and analysts to meet this capacity and provide certification. We recommend you to plan according to this information.

Scope & Definitions

The Regulation applies to ships on international voyages, of 500 GT and above flying the flag of a Member State or the flag of a third country under the conditions of Article 12 of the Regulation.

The Regulation applies to all vessels of any type whatsoever operating or having operated in the marine environment including submersibles, floating craft, floating platforms, self-elevating platforms, FSUs and FPSOs, as well as ships stripped of equipment or being towed.

It does not apply to any warships, naval auxiliary or other ships owned or operated by a state and used, for the time being, only on government non-commercial service. ‘New’ and ‘existing’ ships, ‘ships going for recycling’ as well as ‘ships flying the flag of a third country’ shall have on board an IHM in accordance with the relevant provisions of Article 5 or Article 12 of the Regulation.

Definitions

The terms used in this guidance document have the same meaning as those defined in the Regulation and in the IMO guidelines with the following additional definitions which apply for the purposes of this guidance document only

IHM process is the whole process of development and maintenance of an IHM throughout the operational life-cycle of the ship. It involves all the steps of developing an IHM including issuing/checking of any relevant documentation (e.g. Material Declarations), sampling and analysis, verification and life-cycle management

Individual IHM expert is a person who has the appropriate training, qualifications and knowledge to conduct HM surveys for the development and maintenance of an IHM. He or she should have experience on ship structure and on handling of HM and sufficient knowledge of how to compile an IHM and of all the relevant international and EU legislation14

IHM expert company is an entity employing or contracting individual IHM experts to conduct any relevant work or task in relation to the IHM process for the purpose of compiling or updating Inventories of Hazardous Materials. The IHM expert company should use a documented management system and should work on suitable standards, covering the relevant activities of the company

HM survey is an investigation to trace and identify the presence or absence of Hazardous Materials contained in the equipment, systems, and/or areas on board a ship and may include review of any relevant documents, visual inspections and sampling

Sampling check is the taking of samples to identify the presence or absence of HM contained in the equipment, systems, and/or areas on board a ship, by suitable and generally accepted methods such as laboratory analysis

Representative sampling is a method to sample materials of the same kind in a representative manner. Such materials should be checked to ensure that they are of the same kind

Blank Sample is a clean sample or sample of matrix processed so as to measure artifacts in the measurement (sampling and analysis) process

Blind Sample is a sample submitted to evaluate performance with concentration and identity unknown to the analyst

Bulk Sample is a sample taken from a larger quantity (lot) for analysis or recording purposes

Specific testing is a repeatable and reliable method of testing samples, which can demonstrate definitively whether a Hazardous Material exists or not and provide a known type of the Hazardous Material

Accredited laboratory is a laboratory accredited in accordance with ISO 17025 or an equivalent standard for the purpose of conducting specific tests for HMs included in the SRR and capable of providing a written report that can be relied upon by all parties.

Source: ihmexpert

Applicability: shipowners, ship operators, ship managers and ship masters. ​​​Advice for owners of ships going for recycling and recycling facilities wishing to be included in the UK and EU maintained lists of recycling facilities.

As of 1 January 2021, the United Kingdom (UK) has finished its transition period to leave the European Union (EU). The UK Ship Recycling Regulation (UK SRR) now retains the requirements of the EU Ship Recycling Regulation 1257/2013 (EU SRR) in UK domestic legislation. Note that the EU SRR applies in the European Economic Area (EEA) (EU countries plus Iceland and Norway).ⁱ

This Class News summarises the information contained in MGN 633 (M+F) Amendment 1 regarding requirements for final surveys and ship recycling facilities under the UK SRR, as well as further direct correspondence with the UK Administration.

The UK SRR does not apply to:

• Ships of less than 500 GT;
• UK ships operating throughout their life only in UK waters; and
• Any warships, naval auxiliary, or other ships owned or operated by a state and used, for the time being, only on government non-commercial service.

Note that the EU SRR still applies to UK ships operating throughout their life only in UK waters when they go to a recycling facility in an EEA member stateⁱ.

A. Final survey requirements

These are required for compliance with the UK SRR (from 1 January 2021) as an owner of:

1. a UK flagged ship going for recycling at an EEAⁱ recycling facility; or
2. a UK flagged ship going for recycling at a recycling facility in Great Britain (GBⁱⁱ); or
3. an EEA flagged ship going for recycling in a GBⁱⁱ recycling facility; or
4. a third country flagged ship (to both the EEA and UK) going for recycling in a GBⁱⁱ recycling facility.

Source: info

Recent reports from Brussels indicate that the EC is considering reviewing and revising the EU Ship Recycling Regulations (EUSRR), with a view to strengthening its controls. This Update covers the recent development of following issues:

• Revisions to the EU Ship Recycling Regulations
• Interpretation to assess the equivalence between the Hong Kong Convention and the Basel Ban (& action requested)
• IHM Approval Processes – Feedback from IHM services providers

Source: intercargo