The Hong Kong Convention requires a certified Inventory of Hazardous Materials (IHM) for each vessel no later 5 years after entry into force of the Convention, which probably will happen many years ahead of us.  Nevertheless, the EU has implemented the EU Ship Recycling Regulation setting a clear deadline for IHM onboard. The EU Regulation has entered into force in 2013 allowing the industry 7 years for compliance with the requirement. Legislators also provide related guidelines like e.g. Guidelines for the Development of IHM (Res. MEPC.269(68)); Guidelines for Safe and Environmentally Sound Ship Recycling (Res. MEPC.210(63)) and; ECSA Best Practice Guidance on IHM.

The IHM is needed for identification of suitable Ship Recycler by owners. It can be used for identifying risks during ship operations as it informs crew, repair and conversion yards about hazardous materials onboard, contributing to incident and accident preparedness and response. It enables ship recyclers to plan the recycling of a ship by considering hazardous material during ship recycling and planning of decontamination activities in order to deploy specifically trained workers, select and use of proper PPE (personal protective equipment) and plan in advance the removal and disposals of HazMats. Also, ships are getting ready for recycling certification needed. The IHM for new ships is completely different from the IHM of existing ships. In my opinion, IHM for new ships requires much more effort as it is much more time consuming.

IHM for new ships

The shipyard is responsible for compiling the IHM based on information provided by suppliers via the Suppliers Declaration of Conformity (SDoC) and the Material Declaration (MD) in which the supplier makes a clear statement whether or not HazMats are contained. If they are contained, the supplier must specify place and quantity. The EU has added two more HazMats, the so called PFOS and HBCDD, therefore the EU IHM is different from the IMO IHM.

IHM for existing ships

The owner is responsible for the IHM which should be prepared by IHM professionals and is based on investigation, samplings, analyses, calculations and documentation. The accuracy of an IHM depends on planning; expertise on sampling locations (materials – indicative lists); number of samples taken; detail of documentation; laboratory standards and expertise; and the interpretation of laboratory results.

EU Regulation on Ship Recycling

New ships are required to have an IHM onboard from 30 Dec 2015 while all existing ships under EU-flag or any flag when visitng an EU-port, until 30 Dec 2020. All EU-ships heading sent for recycling since end of 2016 are obliged to have a certified IHM onboard as well.

The Hong Kong Convention will apply to approximately 48,000 ships while the EU Regulation on Ship Recycling to 30,000 ships. The deadline means that from today and onwards until 2020, 36ships per day have to get a certified IHM. The truth is that at the moment we´re far below this figure; the industry is not prepared.

There are three possible scenarios regarding the supply and demand of the IHM:

Firstly, to have a linear increase due to constant demand and doubling of supply every year.

Secondly, to have a gradual increase due to increasing demand and supply.. At the moment, there is more supply than demand, meaning that if you go for an IHM at the moment, you can easily negotiate on the price. We are expecting in the couple years this situation to change as supply & demand ratio affects pricing. This means that prices will go up in future.

Thirdly, to have a progressive increase which I believe it is most likely due to last minute rush for the IHM-deadline, as previous examples in the industry have indicated as well. In that case, the supply will try to follow the demand and of course the price will go up higher.

Nevertheless, no matter what, I do believe that it is highly unlikely for all the 30,000 ships to have an IHM onboard at the end of 2020. When I discussed about it at the European Commission, they didn’t consider granting extensions, because the industry had seven years to prepare from entry into force of EU-Regulation in 2013.

In conclusion, the deadlines are fixed and a huge number of ships is addressed, therefore, an increase of IHM-orders is necessary. IHMA global network ensures compliant and effective IHM preparations already and plans for training of more IHM experts. Owners are advised to ensure timely preparation, therefore, the following actions are recommended:

• For existing fleet: acquire IHM latest by 2020; order HazMat Professional for IHM soon and get class for certification of IHM
• For new builds: include IHM in building specification (since end of 2015) and get class for certification of IHM
• For last voyage: the EU ships must have a certified IHM onboard and be scrapped at a recycler who is included in the EU-list (published in Dec. 2016)
• For operation: nominate a designated person, use data repository to maintain IHM; set up process to get MDs and SDoCs (suppliers need intensive communication with their supply chains and this may take long time).
• Source: safety4sea

Ships over 500GT flying the flag of a Member State or the flag of a third country calling on European Ports, must carry on board a ship-specific Inventory of Hazardous Materials (IHM) and a valid certification which will be subject to Port State controls. Specifically,

• Existing ships, by 31^st December 2020
• New ships, by 31^st December 2018

In both cases, the IHM shall be properly maintained and updated, reflecting new installations and relevant changes in the structure and equipment of the ship.

• For EU flagged ships to be recycled, the IHM should be on board from the date when the European list of ship recycling facilities was first published, 19 December 2016.

Why have an IHM?

Identifying hazardous substances onboard vessels is imperative to ensure crew’s health and safety, the vessel’s sustainability throughout the operational life and respect to the environment when it needs to be recycled.

Yet to be adopted, the Hong Kong Convention (HKC) covers the design, construction, survey, certification, operation and recycling of ships to facilitate safe and environmentally sound recycling. In accordance with Regulation 5 of the Annex of the HKC, each ship shall have on board an IHM.

The EU SRR regulation 1257/2013 on ship recycling sets a few more requirements for the Inventory than HKC does, and makes IHM necessary in accordance with Article 5 and Article 12 of the Regulation (EU) 1257/2013 of the European Parliament and the Council on ship recycling.

Source: epe

An IHM certificate is valid for five years at a time, given that the IHM is being continuously updated and maintained. An IHM provides an inventory of hazardous materials contained in a ship’s structure or fittings, together with details of their location and quantities.

IHM Life Cycle Solution

Through  IHM Life Cycle Solution we provide a turnkey IHM (Inventory of Hazardous Materials) / Green Passport solution for shipowners that has been approved by DNV GL, ABS, Lloyd’s Register, BV, Class NK, RINA and Korean Register.

IHM Maintenance & IHM Inspection / Survey

We offer IHM maintenance as a stand-alone service when an IHM inspection is not required or has already been performed.

An IHM inspection / survey will be conducted on vessels without an IHM. An IHM Report describing the inspection and providing lab results from the onboard sampling of more than 20 materials including asbestos will be compiled after the inspection and approved by the vessel’s class society.

We then perform IHM maintenance through the vessel’s life cycle with state-of-the-art software. An introduction to IHM maintenance, the Hong Kong Convention and the EU Ship Recycling Regulation can be downloaded here.

HazMat Experts stationed around the world

IHM Inspections are performed by our certified HazMat Experts with global reach, operating out of Norway, Holland, UK, Greece, France, Spain, Turkey, Singapore, Shanghai, South Korea, USA, Canada, Brazil and Australia.

Get IHM Compliance now

Request a call-back to discuss your needs or to receive a free price quote. Optionally, send us a prefilled free price quote request by e-mail, or fill out this form.

Customers include Frontline, DOF, Torvald Klaveness, Siem Offshore, Buksér & Berging, Eidesvik, OSM, Viking Line and many more around the globe.

Metizoft handles all types of vessels, including Offshore vessels, Wind farm vessels, Tugs, Well boats, Barges, Ferries, Yachts, Cruise ships, Fishing vessels, Shipping & Cargo vessels, Rigs, FPSOs and Defence & Security vessels.

One of our inspectors at work

At Metizoft we have the special competence needed to resolve issues related to IHM, ensuring that your company’s environmental profile is being safeguarded in a professional way. Easy access to the IHM documentation is provided through our customer portal.

IHM Regulations & Rules

This green ship recycling solution is in compliance with current rules, regulations and guidelines, including the EU Ship Recycling Regulation, the EMSA Guidance on Inventory of Hazardous Materials, the Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, and IMO Guideline MEPC.269(68).

IHM Newsletter

The EU Ship Recycling Regulation

The EU Ship Recycling Regulation (EU SRR) that entered into force on 30 December 2013 has the following requirements for commercial vessels above 500 GT that are operating outside the flag state’s borders:

• EU-flagged newbuildings are required to have onboard a verified IHM with a Statement of Compliance at the earliest by 31 December 2015 and at the latest by 31 December 2018.
• Existing EU-flagged vessels are required to have onboard a verified IHM with a Statement of Compliance at the latest by 31 December 2020 (or if the ship is to be recycled, the IHM should be on board from the date when the European list of ship recycling facilities was first published, 19 December 2016).
• Non-EU-flagged vessels calling at EU ports are also required to have onboard a verified IHM with a Statement of Compliance at the latest by 31 December 2020.

Source: metizoft

Developed with input from the International Maritime Organisation (IMO) and its members, the Inventory of Hazardous Materials was introduced in the 2009 Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships.

The inventory of hazardous materials was introduced to ensure the safety of all those who could potentially be exposed to hazardous materials (including workers in shipyards, on the ships and at recycling yards), by providing a comprehensive list of hazardous materials onboard the ship.

Briefly, the Hong Kong Convention requires ship owners to:

• When the Convention comes into force, all ships will be required to have an initial IHM survey followed by surveys throughout the ships life
• Ships being sent for recycling must have an up to date IHM (specific to each ship). Prior to the ship arriving at the recycling facility, the ship must have an end of life IHM
• Shipyard recycling facilities must provide a Ship Recycling Plan that details the method used to dismantle the ship, accounting for the information provided in the IHM survey
• The IHM must be conducted by a qualified supplier to ensure the IHM is accurate and resists unnecessary potential risks to both individuals and the environment

According to the new rules, the installation or use of certain hazardous materials on ships will be prohibited or restricted. These hazardous materials include for instance asbestos and ozone-depleting substances.

Currently the Hong Kong Convention is not compulsory. However, when the convention becomes compulsory, expected within the next couple of years, all ships weighing over 500GT will be required to carry the inventory. In the meantime the EU has introduced regulations that all ships visiting EU ports will have to have an approved IHM by December 2020.

Regulation (EU) No 1257/2013 – “Ship Recycling Regulation”

The EU Ship Recycling Regulations follow a very similar structure to HKC. The regulation, however, does set out some additional requirements for compliance which must be achieved by all vessels exceeding 500GT, carrying the flag of a European Member State, calling at a European Port or operating in European Waters, ahead of the deadline of 31 December 2020. These further obligations include consideration for additional hazards during IHM compilation. Namely; PFOS (Perfluorooctanesulfonic Acid) and HBCDD (Hexabromocyclododecane).

What is included in a Lucion IHM Survey?

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

• Collation of necessary information
• 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)

The survey can take place while the vessel is at sea or in port and our surveying teams 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.

How long does an IHM Survey take?

The length of time to conduct an IHM Survey can vary depending on the size of the vessel, how the vessel is currently being used (if the vessel is live i.e. commercial passenger ship will take longer than a tanker that is largely unoccupied), the amount of potential hazardous materials on board, and any unforeseen logistical issues.

Why should I use Lucion to conduct my IHM Survey?

Whilst it is not a requirement by the Hong Kong Convention to use a qualified supplier to conduct your IHM Survey, it is recommended to do so to ensure that your vessel is comprehensively and accurately surveyed in a safe manner that resist unnecessary exposure to any onboard hazards. Sampling should be carried out by a competent IHM expert. Testing and analysis should be conducted at accredited ISO 17025 laboratories or equivelant.

As an established international Hazardous Materials testing, inspection, and consultancy provider, our team of specialist shipboard hazardous material experts are trusted to deliver our services to multiple clients throughout the world.

Lucion holds approval status with major IACS Classification Societies, including Lloyds Register, Bureau Veritas, American Bureau of Shipping (ABS) as well as having directly employed DNV GL certified Marine HazMat Experts.

What are my responsibilities?

The impact of poor ship recycling decisions has been heavily documented over recent years. To combat this negative impact on individuals and the environment, the European Union adopted the Hong Kong Convention 2009 early (in 2013) which outlines requirements that ships flying the flag of Member States of the Union and recycling facilities within the EU have to fulfil in order to make sure that ship recycling takes place in an environmentally sound and safe manner.

If you are a ship or fleet owner bearing the EU member states flag, you are required by law to conduct an initial IHM Survey by December 2020. Our team provides surveys for hazardous materials on vessels around the world, whether they are newly built, currently trading, or due to be recycled.

Source: lucionmarine

• As per the SARPS, the monitoring, reporting and verification (MRV) is to take place based on an EMP approved by the national authority. We have had to conclude some verifications with this non-compliance because the operator couldn’t get their EMP approved by their authority.  As explained above there was missing necessary information from the EMPs which counts as both a non-compliance with the EMP and a non-compliance with the SARPS.
• Some EMPs had conflicting declarations in the methods tab, with both CERT and a FUMM (fuel use monitoring method) selected as primary methods within the same period.
• It was also noted in certain cases that the implementation of the selected fuel use monitoring method was incorrect, which reflected a lack of understanding. This was the case with operators choosing to use the fuel uplift and fuel allocation by block hour methods. On a similar note, the incorrect use of the declared data gap approach was also encountered.

• The wrong use of method A or method B due to an improper chronological order.
• The use of incorrect, outdated ICAO codes for airports and in some cases the incorrect attribution of an airport to another state. On a similar note, many reports used state names that were not in line with the ICAO template.
• In a few rare cases, missing international flights were counted as data gaps, international positioning flights were missed while some wet leased out flights were included.
• In one particular case, the operator was unable to edit the destination airport of a flight on their system. Their IT system prevented editing of the airport codes due to linkages with several other systems. This led to a situation where when an aircraft was diverted to another airport and subsequently left from the diverted airport it would result in a break in sequence. Often this diversion would be international, which would impact the state pairs to be reported.

• Perhaps the most common one was regarding filling in the Emissions report. Which aircrafts to declare in the fleet tab, how to fill the reporting/identification sheets, which dates and what is the approved aggregation were a few of the many points on which we have had to work.
• Some operators had duplicated flights, which were discovered during the verification.
• Most operators had breaks in sequence which upon investigation would at times reveal missing flights. It is highly recommended that all operators implement some measures to ensure that the each aircraft has a logical sequence of consecutive flights.
• Most operators haven’t prepared a CORSIA manual or included CORSIA in their internal annual audits. This builds to the point that operators attest that they have several quality control activities in place but do not possess any documents/reports to back them up.