Inventory of Hazardous Materials (IHM) Archives

Environment management regulators in Turkey have advised that a new inventory of hazardous materials (IHM) must be conducted prior to the export of a Brazilian aircraft carrier to a Turkish shipbreaking yard, AllAboutShipping reported on August 23.

Reports indicate, however, that the six-decade-old carrier, the Sao Paulo, has already set sail for Turkey.

The trade news site reported that the Brazilian government and ship recycler Sok Denizcilik Tic.Ve Ltd.Sti (SOK) of Aliaga, Turkey, the buyer of the Sao Paulo, were sent scrambling when the regulators sent a letter to the Brazilian agency IBAMA, the competent authority for the Basel Convention, requiring the new IHM.

“… As a result of the [Turkish] Supreme Court’s interim injunction, news in the press, and the hazardous materials notices made to our [Turkish Environment] Ministry, it has emerged that a new Inventory of Hazardous Materials for the ex-naval vessel in question should be prepared while the vessel is in Brazilian territorial waters before it comes to our country,” the regulators wrote.

Environmental and labour rights groups working on the matter in Turkey, Brazil, and internationally have claimed for weeks that the export of the ship from Brazil to Turkey was illegal under the Basel and Barcelona Conventions and that the current IHM was not credible.

“Turkey is to be applauded for asking for a true and accurate survey and inventory,” Nicola Mulinaris of the NGO Shipbreaking Platform was cited as saying. “The current one is simply not believable based on what we know about older aircraft carriers. We have real concerns that the provided inventory grossly underestimates the hazardous and radioactive materials on board the Sao Paulo.”

AllAboutShipping said it must be noted that Grieg Green, the survey company that issued the IHM for SOK, among other things:

admitted they had access to only 12% of the ship;

did not have access to the IHM prepared by the Brazilian Navy;

concluded that there might be more asbestos onboard the aircraft carrier than the estimated nine tons;

and

recommended further sampling during dismantling operations.

The Sao Paulo’s sister ship Clemenceau was estimated to have at least 760 tonnes of asbestos, a figure later confirmed by Bureau Veritas upon its dismantling at scrap yard Able UK, the news outlet added.

Jim Puckett, executive director of the Basel Action Network, was reported as saying. “The rush by the Brazilian government to get out to sea without checking to see if Turkey has laws against such import, to alert transit countries, and before a court injunction can be properly served, is not an excuse for Turkey to ever allow this ship into our territory.”

The Sao Paulo was first commissioned by the French Navy as Foch in 1963 and was sold to Brazil in 2000 for around $30mn, where she became the new flagship of the Brazilian Navy. The ship was demobilised and decommissioned in 2017.

Source: https://www.intellinews.com/toxic-materials-warning-as-brazilian-aircraft-carrier-sets-sail-for-date-with-turkish-shipbreaker-254373/?source=turkey

Although the Other Regulated Material-Domestic (ORM-D) designation was phased out on January 1, 2021 for highway shipments, many shippers have questions about how to move forward. PHMSA recently responded to one question: Is a shipper required to remove or cover the ORM-D marking entirely, or can it appear in addition to the required limited quantity marking?

The Hazardous Materials Regulations (HMR) require limited quantity packages prepared for highway transportation to be marked with the limited quantity marking. There is no explicit requirement for the outdated ORM-D marking to be removed.

In an interpretation dated May 18, 2022, PHMSA warns that although the ORM-D marking may remain on a package when the correct limited quantity marking is used for ground shipping, this can be confusing and potentially problematic.

If both markings appear, the package may be rejected or removed from transportation since hazardous materials are no longer permitted to be reclassed as ORM-D. Not every shipper, carrier, or freight forwarder will see this letter of interpretation. Those that do not may be unsure about accepting or loading a package with both ORM-D and limited quantity markings.

Since the packages display the currently required limited quantity marking, the old ORM-D marking is not required to be removed prior to shipment. However, it is the opinion of this Office that the display of the ORM-D marking is confusing and may frustrate transportation of these packages because hazardous materials are no longer authorized to be reclassed as ORM-D for transport. Therefore, while not covering the phased-out ORM-D marking is not in violation of the HMR, we suggest that the best way to avoid frustration of the shipment is to cover the ORM-D marking and to discontinue its use in future shipments.

PHMSA Reference No. 22-0019

To help address this issue, PHMSA is working on a rulemaking to remove all references to ORM-D in the 49 CFR 172.101 Hazardous Materials Table. An FAQ page on PHMSA’s website to convert letters of interpretation like this one into an easy-to-read, public format is also under consideration. A public webinar is scheduled for June 27, 2022 to discuss the FAQ page and will accept comments until July 22, 2022.

What Happened to ORM-D?

The last day to use the ORM-D classification for highway shipments was December 31, 2020.

Shippers who used the ORM-D designation to ship small quantities of hazardous materials packaged for retail sale benefited from a multitude of reliefs. Now that ORM-D has been phased out, the same materials, in the same quantities, in the same packaging, mostly continue to qualify for relief under US DOT’s limited quantity regulations.

What changed was the label you affix to your packages. Ground shipments of limited quantities must carry the blank limited quantity mark. Limited quantity air shipments must display a “Y” limited quantity marking.

Want More on Limited Quantities?

Be confident you know how to package, mark, and label your limited quantity shipments now that ORM-D is O.V.E.R.

The Shipping Limited Quantities and Consumer Commodities online course provides reliable, up-to-date training to help satisfy DOT, IATA, and IMDG training mandates for hazmat employees who prepare or offer limited quantity shipments for ground, air, or vessel transport.

In the increasingly urgent path to the decarbonisation of shipping, there is no excuse for waiting, according to Steve Esau, the general manager SEA-LNG, a sustainable shipping specialist.

The obvious immediate solution is fossil-derived LNG because it is low risk and available. “You can start the decarbonisation process right now,” he told a Riviera Maritime Media webinar in late May. “In our view, waiting is not an option.”

Meantime, other panellists expressed concerns about the high capital investment required to install emissions-reducing technologies, putting the viability of smaller shipowners and operators under threat.

Entitled Future fuels and technology, plotting a path to decarbonisation, the webinar featured a high-level panel that explored the numerous issues complicating the journey to the industry’s 2050 deadline for zero emissions. Sponsored by Wärtsilä, the event was supported by SEA-LNG and produced as part of Asia Maritime Webinar Week.

Citing the example of an LNG-fuelled 14,000-teu container ship coming into service in 2025, with a 25-year working life and renewable fuels coming on stream around 2030, Mr Esau explained that its lifetime emissions would fall substantially below those of rival fuels.

Although fossil LNG is not the final answer in a sector that has proven one of the most difficult to decarbonise, he emphasised that it provided a vital incremental solution, whose virtues as a fuel had already been proven and that already had a global infrastructure.

However, there was no single solution in a diverse industry accommodating short- and deep-sea shipping. The base requirements for any fuel are energy density, technological maturity and safety, he said. “It needs to be utterly reliable and completely safe for both crew and port communities.”

“You can start the decarbonisation process right now”

And so far, LNG leads on all three counts. However, alternative fuels such as ammonia, hydrogen and methanol could be catching up, he explained through an interesting timeline that showed the first two could become commercially available by the latter half of the current decade, while methanol is already in operation, for instance in some ferries and methanol carriers.

“The primary feedstock for all four fuels is natural gas,” he said. “The starting point is fossil. The end point is dependent on sufficient production from renewable electricity.”

Jay K Pillai (JP Maritime): “We need clarity to invest in a new breed of ships with dual-fuel engines with zero-emission fuels” (source: JP Maritime)

Sitting on the fence

Taking a broader view as a shipowner, Jay K Pillai, founder and director of Hong Kong-based JP Maritime, explained that shipowners and operators rely on reliable and cost-efficient solutions being provided by a large and wide-spread shore-based network.

“[They are] fuel suppliers and bunkering infrastructure at major seaports, engine makers and engineering system designers for reliable and user-friendly technologies, ship designers and builders for energy-efficient ships with operational reliability and ease of maintenance,” he said.

The main problem for shipowners was an absence of a clear direction. “[We] need clarity to invest in a new breed of ships with dual-fuel engines with zero-emission fuels, at the latest by 2030 to achieve net-zero emissions by 2050,” he said.

Meantime shipowners and operators are faced with a number of sometimes confusing options and are reluctant to take the plunge. “Retrofitting engines on an existing fleet for future fuels is unlikely,” he said, citing the energy-saving devices and systems that have been tried over the last two decades in the interests of cost efficiencies.

Meantime, underlining the presentation made by Mr Esau, he added that zero-emission fuels and vessels will need to be deployed at scale over the next decade to achieve full decarbonisation of the shipping sector by 2050. However, the dual-fuel engines that are capable of burning future fuels such as green methanol, green ammonia and biofuel are being ordered mainly in the liner sector, which is led by container lines.

“Most shipowners are opting to follow rather than lead in decarbonisation [and] are sitting on the fence, Mr Pillai said. “They want somebody else to try first.”

Moving target

In a presentation that also highlighted a fast-changing scene for shipowners, Wärtsilä’s Sanjay Verma, general manager for market innovation and marine power, showed how they “need to plan their future fleet against moving targets” by being prepared to invest in emissions-reducing technologies as they went along.

In newbuilds, while focusing on design efficiency, it was important to invest in upgradable assets throughout the vessel’s lifecycle so that, by around 2030, vessels are zero-carbon. In existing ships, he favoured the installation of energy-saving devices and power limiters, while anticipating conversion to an alternative fuel by around 2025.

“Most shipowners are opting to follow rather than lead in decarbonisation”

And echoing other panelists, he warned against adopting a one-size-fits-all approach. “Design and operational efficiency are both important,” he said. “Decarbonisation is a journey. It’s not about a single solution.”

Bringing the discussion down to the bottom line, Sudhir Bhimani, group environmental compliance director of ship management group Anglo-Eastern, said the key factor in the entire debate is the vessel’s commercial viability. He highlighted the huge additional cost on the industry of complying with IMO and EU regulations, amounting to over US$1Tn a year, assuming ships use the same kind and amount of fuel as they did in 2020.

On the bright side, he explained that Anglo-Eastern, a specialist in smaller-tonnage, is project-managing 32 advanced ammonia-ready vessels. Some designs had lost nothing in cargo volume because of the fuel tanks. Meantime, the group is working on a concept for an 82,000- to 90,000-dwt bulk carrier that will surely attract attention.

Ultimately, the panelists agreed, every ship is unique, and its fuel should be chosen according to its operational role throughout its life cycle.

Whatever solutions are adopted, it is vital that the welfare of the crew should be put at the forefront of all decisions, urged JP Maritime’s Mr Pillai: “A people-centred approach is essential [and the technologies] must be less reliant on seafarers so they are not overburdened.”

Ships should be designed, built and equipped with the safety of the crew and operational efficiency in mind. [“We must] invest heavily in training crew for this challenging transition [and] mitigate risks,” he said.

Verifavia, the global leader in carbon emissions verification services to the maritime and aviation industries, has sold a majority stake to Normec, the leading Dutch testing, inspection and certification organisation.

This strategic transaction will greatly reinforce Normec’s sustainability offering and marks a key milestone in the company’s development with its entry in the French market. Normec’s sustainability services include, among others, biodegradability and compostability and ecotoxicity testing, waste and recycling management, and air, soil and water analyses.

Julien Dufour, President of Verifavia Group – which also provides preparation and maintenance services for Inventory of Hazardous Materials (IHM) on board vessels – revealed that his company had received several offers from global organisations during the acquisition process. However, the board chose Normec because it shared the same entrepreneurial spirit, values and culture.

“We and Normec are both flexible, agile companies that can respond quickly to clients’ requests – which is vital for maritime and aviation companies that need to meet industry regulations on carbon emissions or industry specific legislation such as IHM,” Dufour said.

Dufour added that Verifavia will continue to operate autonomously following the transaction. “Normec’s management wants us to retain the entrepreneurial mindset that has served us so well over the years, which this partnership allows us to do,” he said.

Normec’s purchase of Verifavia gives it a controlling stake in a company that has achieved many milestones since launching in 2010. In shipping, Verifavia was one of the first organisations to offer EU Monitoring Reporting and Verification services, as well as being the original independent verifier to provide the IMO Data Collection System verification for several flag states.

Additionally, Verifavia launched the world’s first real-time Carbon Intensity Indicator (CII) Dashboard in November 2021, allowing owners, operators and charterers of ships over 5,000GT to accurately measure a vessel’s current and predictive CII rating. The CII dashboard provides guidance for ship efficiency, generating data on the amount of carbon produced and, through its calculator, insight into whether emission levels for a single voyage or reporting period meet industry regulation.

“Verifavia stays agile to new regulatory requirements, such as the Energy Efficiency Existing Ship Index and the EU Emissions Trading System (ETS) for shipping, and guides its customers through the awareness and compliance process,” Dufour said.

In aviation, Verifavia was the first verification body to be accredited for the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). As the world’s leading verifier for the industry, Verifavia serves more than 300 airlines in 100 countries for carbon emissions verification under the EU ETS, UK ETS and CORSIA, giving it an overwhelming global market share.

Another gain for Normec is Verifavia’s IHM service, which supports ships that are subject to the EU Ship Recycling Regulation and the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. Verifavia works with shipowners, managers and class societies to develop and implement an IHM maintenance procedure. The IHM must be updated by a collection of suppliers’ declarations if any non-identical or new machinery or equipment is added to, removed or replaced, or the hull coating is renewed.

For Verifavia, the merger gives it access to Normec’s markets, clients and services – including materials testing sites, building services and laboratories that complement the vendor’s IHM services – in The Netherlands, Belgium, and Germany.

Verifavia will also benefit from Normec’s established HR, sales, marketing, IT and finance functions, processes, and procedures, meaning Verifavia can scale its operations, while focusing on service development and delivery.

“We’re particularly excited about tapping into Normec’s advanced IT systems, which aligns with our commitment to developing bespoke software that supports companies across the maritime and aviation industries,” Dufour said.

Joining Normec will create a stronger organisation with knowledge-sharing and career opportunities for employees of both businesses, according to Dufour. “Together, Normec and Verifavia can continue to grow and become even more complete in their services.”

Joep Bruins, CEO of Normec Group, added that the opportunity to acquire a majority stake in Verifavia was too good to miss. “We are very impressed by the position and reputation that Verifavia has built up in the global aviation and maritime markets. The company delivers high-quality services to customers and has a high level of knowledge,” he said.

“Verifavia’s team has extensive experience and expertise. We’re looking forward to working together to participate in the global effort to control CO2 emissions and the carbon footprint.”
Source: Verifavia

1. Instructions

You are required to go through these notes before filling the application form in GoBusiness. Please retain this set of notes with you for future reference.

The application form for Hazardous Substances Licence/Permit can be used to apply for a

Hazardous Substances Licence issued under the Environmental Protection and Management Act for the import, use, storage and supply of hazardous substances controlled under the Act.
Hazardous Substances Permit issued under the Environmental Protection and Management (Hazardous Substances) Regulations for purchasing hazardous substances controlled under the Regulations from local supplier for own use and/or for storage.

2. Guidance Notes

(To be read together with the application form)

Section 1 – Purpose of Application (for Hazardous Substances Licence Only)

Please tick the relevant box to indicate the reason for your application.

Section 1 – Particulars of Company

The company name and registered address shall be the same as the name and address that your company filed with the Accounting and Corporate Regulatory Authority.

Section 1 – Particulars of Applicant

Applicant’s name shall be the same as in NRIC, PR status, work permit or employment pass.

Applicant for a Hazardous Substances Licence should be a professional in his field or a senior management staff in his company. His academic qualification must be at least a technical diploma. He will be required to sit and pass the Management of Hazardous Substances (MHS) course. MHS course is not required for applicant dealing with only (i) Ozone Depleting Substances (ODS) and Hydrofluorocarbons (HFCs) other than Methyl Bromide, (ii) Restriction of Hazardous Substances (RoHS) in Electrical and Electronic Equipment and (iii) paints in which the total lead exceeds 0.009% by weight of the paint.

Applicant for a Hazardous Substances Permit should be a management staff in his company.

Section 2 – Purpose of Hazardous Substances

Please tick the relevant box to indicate the purpose for the hazardous substances in your application. You may tick more than one box. Please specify the use of the Hazardous Substances in Section 3 and/or 4 for each and every substance.

Section 3 – Details of Storage Premises/Facilities

Address of Store:
Please state address of storage premises.

If you propose to store the hazardous substances at more than one premises, you may add new storage premises at Section 3 of the application form

If storage is not required, please update Section 4 with the hazardous substance and its respective transaction modes of import, transport, sales and/or use of hazardous substances that will be carried out (e.g. deliver direct from port to customer’s store or from supplier’s store to port, etc).

Industrial Allocation / Industrial Siting Consultation Letter

The letter shall be submitted along with the respective Hazardous Substances Licence/Permit application relating to a new site premises. The letter shall include details of the proposed activity at the listed industrial premises.

No-objection letter (for storage at a 3rd party warehouse)
If your company proposes to store hazardous substances at an approved chemical warehouse, please attach a letter of consent from the warehouse (along with company letterhead) stating the name, percentage and maximum quantity of hazardous substances to allow for storage at the stated premises.

No. and Capacity of Fixed Storage Tanks
Please indicate the number and capacity of the tank(s), along with the hazardous substances intended to be stored in the bulk tank. The Certificate of Statutory Completion (CSC) for the bulk tank shall be uploaded along with the application as a supporting document. Alternatively, a certification of the fixed bulk tank from a Professional Engineer is acceptable as well.

Emergency Response Plan to Mitigate a Spill/Release of Hazardous Substances

The plan needs to address the containment/mitigation procedures, the equipment used for mitigation of any incidents involving a spill/release of hazardous substances, the collection and disposal of contaminated waste generated from the incident.

Source: nea.gov.sg

The Partnered Carrier program allows you to send your Fulfillment by Amazon (FBA) inventory from India to fulfillment centers in the US. The program enables you to commercially ship your FBA shipments in a cost-effective manner. Once the partnered carrier picks up your shipment, they will handle shipping from customs clearances to delivery to an Amazon fulfillment center. Doorstep pickup and drop-off at a carrier facility in India is available.

Below is a detailed list of program features:

Integration into Seller CentralYou can book shipments, enter customs information, schedule pickup by the carrier, and pay logistics freight charges directly in Seller Central while creating your FBA shipment.
Amazon-facilitated shippingYou don’t need to create a separate account with the carrier or do any credit checks to use the Partnered Carrier program for global shipments. Just make sure that your shipment documents and Know-Your-Customer (KYC) documents are ready at the time of pickup. KYC documents establish your proof of identity and address.
Commercially clearedPartnered carrier shipments will be commercially cleared, with the carrier taking care of both origin and destinations customs clearance.
Amazon-negotiated rates and seamless paymentsYou can rely on Amazon’s negotiated rates along with seamless Seller Central integrated payments.
Door-to-door pickup and deliveryOnce you schedule pickup from your location, the carrier will come to your door for pickup and will take ownership for delivery to a US fulfillment center.
End-to-end trackingYou can track the status of your FBA shipment within Seller Central.
Express shipping solutionThis program offers an express shipping solution. The average delivery time will be 6 to 8 business days for FedEx International (Priority) and 14 to 16 business days for FedEx International (Economy).

Source: sellercentral

As people become more concerned about their environment, the shipping community is changing too – to take on a more responsible approach for every single step in the life cycle of a ship. The conventions and regulations adopted by governments across the world are a testament to this change and we, at IRClass, are committed to support your environmental goals.

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. (Correct?)

Source: irclass

The IHM provides detailed information with regard to potentially hazardous materials utilised in the construction of the ship, its equipment and systems.
Therefore, all the ship’s upgrades and equipment substitution performed on board during the life of the ship are to be reflected into a constant updating of the IHM allowing the Owner to have an updated document at the time of the delivery of the ship to the recycling facility.

Regulatory Focus

The service is provided in application of the requirements of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009, and of the UE regulation on Ship Recycling (N°1257/2013) 30th December 2013.
The verification of IHM, and the related laboratory testing activities, are performed in compliance with UNI EN ISO 9001:2008 and UNI ENI ISO 14001:2004 and accredited in compliance with UNI CEI EN ISO/IEC 17025:2005.

Deliverables

The steps to be followed before delivering the ship to the recycling facility are:

List of hazardous materials contained in the structure or equipment of the ship, their location and approximate quantities (Part I);
List of the waste present on board the ship, including waste generated during the operation of the ship (Part II);
List of the stores present on board the ship once the decision to recycle it has been taken (Part III).

The procedure to draft the IHM is:

Collection and relevant assessment of necessary information
Preparation of visual/pick up sampling plan
Onboard visual inspection and pick up sampling campaign
Preparation of Part I of the Inventory and related documentation.
Preparation of Part II and III of the Inventory once the vessel will arrive at the recycling facility.

Why RINA?

RINA, having participated in the development and update of both IMO and EU regulations, developed an integrated service of verification and testing covering all aspects relevant to the Inventory of Hazardous Materials (IHM).
We have a long experience on this matter, starting from the requirements established in our rules since 2006 (we called GREEN PASSPORT), and updated in 2011 (GREEN PASSPORT PLUS).
Today we have the proven capacity to perform the survey on board necessary to verify the presence of Haz Mat, conduct, together with partners, testing on samples in accordance with relevant regulations where necessary.

Reference standards:

“Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009”, SR/CONF/45
UE regulation on Ship Recycling (N°1257/2013) 30th December 2013
“2015 Guidelines for the development of the Inventory of Hazardous Materials”, MEPC.269(68)
RINA MNO n°73 “EU Regulation on ship recycling – UPDATED”

Source: rina

From July 1st 2021, any ship which is 500GT or over, regardless of flag, will require a valid and certified Inventory of Hazardous Materials (IHM) on board if calling at an EU port or anchorage.

This training focusses on the key issues that crewmembers will have to deal with.

The STCW.online IHM Awareness online course provides knowledge for all officers and crewmembers involved in the IHM protocol on board.

Developed in accordance with:

European Union Ship Recycling Regulation – EU SRR

Inventory of Hazardous Materials – IHM, comes into force 1 July 2021

Source: stcw

The EU Ship Recycling Regulation came into force on 31 December 2020 and effects any in-service ship of 500 GT or over calling at any EU* port or anchorage (regardless of flag). It requires that vessels hold a valid and certified Inventory Hazardous Materials (IHM) on board.

This also continues to apply under the UK Ship Recycling Regulation (UK SRR), following the UK’s exit from the EU.

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

Source: lr

Older Posts

Toxic materials warning as Brazilian aircraft carrier sets sail for date with Turkish shipbreaker

CAN I USE THE ORM-D AND LIMITED QUANTITY MARKINGS TOGETHER?

What Happened to ORM-D?

Want More on Limited Quantities?

Complying with environmental regulations to cost shipowners an additional US$1Tn annually

Shipping & Aviation To Reap Benefits Of Normec Group’s Acquisition Of Verifavia

Guidance Notes For Filling of Hazardous Substances Licence/Permit Application Form

1. Instructions

2. Guidance Notes

Partnered carrier shipping from India to the US

Inventory of Hazardous Material 2021

Inventory of hazardous materials 2021

Regulatory Focus

Deliverables

Why RINA?

Reference standards:

IHM Awareness

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