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Hazardous materials are handled onboard daily, exposing crew, ships and the environment to potential risk. If these materials are not properly recorded, ship owners can face significant liability.

An Inventory of Hazardous Materials (IHM) helps ship owners maintain control of hazardous materials by detailing the types, quantities and locations of such materials onboard each vessel.

Most importantly, a thorough and accurate IHM is required for compliance with the EU Ship Recycling Regulation (EU SRR) and the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships. With the deadline to comply with IHM requirements quickly approaching, ship owners must prepare to act now.

Achieving IHM Compliance: A 3-Step Guide

1- Plan for the IHM Compliance Deadline

Ship owners should keep in mind that the entire process for IHM compliance can take up to 3 months. While the delay caused by COVID-19 is unprecedented, it represents only a 6-month period since the adoption of the EU SRR 7 years ago.

Starting 31 December 2020, any ship which is 500 GT or over, regardless of flag, will require a valid and certified IHM onboard if calling at an EU port or anchorage. Non-EU flagged vessels can also be certified against EU SRR by complying with the HKC IHM requirements.

The IHM consists of three parts:

  • Part I: Hazardous materials contained in the ship’s structure and equipment
  • Part II: Operationally generated waste
  • Part III: Stores

2- Gain IHM Compliance

Owners need a seamless and effective way to meet IHM requirements. The ABS Nautical Systems (NS) Asset Management software solution can guide owners and operators through this process.

To help global mariners comply with the IHM requirements, NS has launched comprehensive capabilities that are fully integrated into the existing NS Maintenance Manager and NS Purchasing Manager software modules.

Key IHM compliance features will:

  • Identify equipment, spaces and structures that contain hazardous materials
  • Produce an Inventory of Hazardous Materials report in an approved format
  • Identify spare parts that are hazardous, including hazard type and quantity of hazardous material per part
  • Capture initial inventory using an Export Excel tool
  • Provide automatic updates for IHM Part I through standard maintenance and purchasing processes
  • Document required periodic audits of inventory in the HSQE and Vetting Manager module

ABS Nautical Systems Inventory of Hazardous Materials Features

3- Maintain IHM Compliance

As the deadline to achieve IHM Certification approaches, the focus will soon shift to how to best demonstrate and maintain compliance with IHM requirements. IHM documentation is crucial, as it stays with the ship throughout its operational lifetime. Keeping information up to date is important not only to demonstrate compliance but to minimize the risk and potential liability of the crew and ship.

Nautical Systems IHM Compliance capabilities will provide the tools to maintain long-term compliance simply. With a unified approach to planning, NS software records data seamlessly, integrating the complexities of reporting into daily onboard activities. Created to meet the compliance challenges of the maritime industry, our tools facilitate planning, execution and documentation of all compliance activities.

Source: abs


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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

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Inventory of Hazardous Materials (IHM) is a structured system to control hazardous materials onboard ships and achieve compliance with the EU Ship Recycling Regulation (EU SRR) and Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships.From December 31, 2020, any ship which is 500 GT or over, regardless of flag, will require a valid and certified IHM on board if calling at an EU port or anchorage. Non-EU flagged vessels can also be certified against EU SRR by complying with the HKC IHM requirements.

Read our IHM requirements guide.

We offer end-to-end IHM services for both LR and non-LR classed ships for each stage of their lifecycle – new build, in-service or end of life.

Why is this important?

A comprehensively compiled IHM can help you minimise risk, potential liabilities, and enhance the safety of your ships’ crews by identifying, recording and controlling hazardous materials onboard your ships, in line with existing and forthcoming legislation.As well as assisting with your in-house management systems, you can demonstrate your commitment to safe and environmentally sound practices at the end of your ship’s life.

Technical insights from LR – Read IHM Technical Matters here.

Jennifer Riley-James, LR’s Senior Ship Recycling Specialist, shares her expertise on the upcoming IHM regulatory deadline, and considers how best to ensure that compliance with the regulation is a swift and straightforward process.

Why choose LR?

Our well established IHM service offers reputable and consistent global service delivery, helping to promote better hazard management and sustainable ship recycling. Since 2004, over 2,000 ships spanning both new construction and in service have entrusted LR to provide inventory certification services.

What we offer

LR offers end-to-end IHM services to both LR and non-LR classed ships. We provide an intuitive and competitively priced approval, verification, and certification service to ensure compliance with EU and HK legislation – for both newbuilds and existing ships.

Access to LR approved Hazardous Material Expert companies:

We have a list of independently LR approved companies who can provide you with expert IHM compilation and hazardous materials sampling/testing services against legislative requirements. To date we have checked and approved the procedures and operations of around 40 Hazardous Material expert companies.

Need help searching the database? Take a look at our IHM approved service supplier database user guide.

An easily editable IHM template:

Our simple, tried and tested IHM template is carefully designed against legislative requirements and allows easy compilation and maintenance of the IHM.

LR experts every step of the way:

A specialist from our dedicated IHM Approval Teams then takes care of the desktop approval, and finally a surveyor local to the vessel undertakes onboard verification and certification.

Certification:

We will issue a statutory certificate against EU SSR (for  EU flagged ships) or Statement of Compliance (for non-EU flagged ships). We can also issue a Statement of Compliance against HKC at the same time for no additional charge.

Source: lr


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Every year, around 1,000 ships reach the end of their operating life. The European Ship Recycling Regulation (EU SRR) was introduced to ensure proper vessel dismantling methods are used to achieve safe disposal or recycling of all ship components, including hazardous materials. To assist shipyards and owners with this process, Bureau Veritas Solutions Marine & Offshore supports preparation of an Inventory of Hazardous Materials (IHM) and development of a Ship Recycling Plan (SRP) that complies with EU SRR.

Shipyards must comply with numerous regulations governing hazardous materials, including EU SSR requirements concerning the ship dismantling process. To ensure compliance, vessel owners and operators need to draft, certify and maintain an Inventory of Hazardous Materials (IHM) to accompany the ship throughout its life. In addition, they must develop an approved Ship Recycling Plan (SRP) for dismantling a decommissioned vessel safely and without emitting harmful pollutants.

  • Bureau Veritas Solutions Marine & Offshore helps you gain a comprehensive understanding of all mandatory regulations concerning hazardous materials and vessel dismantling

  • Our GreenPassport EU notation supports you to maintain compliance with EU SRR

  • Complying with EU SRR enables you to minimize reputational risk by ensuring people safety and environmental protection when dismantling vessels

  • We offer advanced digital tools that give you fast access to data

EU Ship Recycling Regulation & IMO Hong Kong Convention

OUR OFFER

A GLOBAL IHM SOLUTION

Bureau Veritas Solutions Marine & Offshore can establish and certify an Inventory of Hazardous Materials (IHM) to help shipyards prepare for safe dismantling operations and enhance QHSE management.

GREENPASSPORT EU NOTATION

Prior to vessel construction, Bureau Veritas Solutions Marine & Offshore supports owners in obtaining GreenPassport EU notation by ensuring the compliance of all materials. This notation accompanies the ship throughout its life, guaranteeing safe and eco-responsible ship recycling upon dismantling.

CUSTOMIZED SHIP RECYCLING PLANS (SRPS)

Bureau Veritas Solutions Marine & Offshore helps shipyards develop Ship Recycling Plans (SRPs) tailored to the specific needs of vessels reaching the end of their operating life. These plans minimize risks during the dismantling process and prepare the ship for scrapping.

MANAGEMENT AND MONITORING OF DISMANTLING OPERATIONS

Bureau Veritas Solutions Marine & Offshore helps limit potential risk to people and the environment throughout the dismantling process with rigorous monitoring of all phases. We provide onboard survey, hazardous materials sampling, and laboratory tests. Our advanced digital tools provide clients and surveyors alike with fast access to data.

Source: marine-offshore


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Every year, around 1,000 ships reach the end of their operating life. The European Ship Recycling Regulation (EU SRR) was introduced to ensure proper vessel dismantling methods are used to achieve safe disposal or recycling of all ship components, including hazardous materials. To assist shipyards and owners with this process, Bureau Veritas Solutions Marine & Offshore supports preparation of an Inventory of Hazardous Materials (IHM) and development of a Ship Recycling Plan (SRP) that complies with EU SRR.

Shipyards must comply with numerous regulations governing hazardous materials, including EU SSR requirements concerning the ship dismantling process. To ensure compliance, vessel owners and operators need to draft, certify and maintain an Inventory of Hazardous Materials (IHM) to accompany the ship throughout its life. In addition, they must develop an approved Ship Recycling Plan (SRP) for dismantling a decommissioned vessel safely and without emitting harmful pollutants.

  • Bureau Veritas Solutions Marine & Offshore helps you gain a comprehensive understanding of all mandatory regulations concerning hazardous materials and vessel dismantling

  • Our GreenPassport EU notation supports you to maintain compliance with EU SRR

  • Complying with EU SRR enables you to minimize reputational risk by ensuring people safety and environmental protection when dismantling vessels

  • We offer advanced digital tools that give you fast access to data

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OUR OFFER

A GLOBAL IHM SOLUTION

Bureau Veritas Solutions Marine & Offshore can establish and certify an Inventory of Hazardous Materials (IHM) to help shipyards prepare for safe dismantling operations and enhance QHSE management.

GREENPASSPORT EU NOTATION

Prior to vessel construction, Bureau Veritas Solutions Marine & Offshore supports owners in obtaining GreenPassport EU notation by ensuring the compliance of all materials. This notation accompanies the ship throughout its life, guaranteeing safe and eco-responsible ship recycling upon dismantling.

CUSTOMIZED SHIP RECYCLING PLANS (SRPS)

Bureau Veritas Solutions Marine & Offshore helps shipyards develop Ship Recycling Plans (SRPs) tailored to the specific needs of vessels reaching the end of their operating life. These plans minimize risks during the dismantling process and prepare the ship for scrapping.

MANAGEMENT AND MONITORING OF DISMANTLING OPERATIONS

Bureau Veritas Solutions Marine & Offshore helps limit potential risk to people and the environment throughout the dismantling process with rigorous monitoring of all phases. We provide onboard survey, hazardous materials sampling, and laboratory tests. Our advanced digital tools provide clients and surveyors alike with fast access to data.

Source: bureauveritas


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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 31st December 2020
  • New ships, by 31st 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.

Green Recycling Services by an Expert

EPE has a record with hundreds of IHM surveys onboard vessels since 2006, and is an active company in marine business worldwide for more than 30 years dedicated to the protection of marine environment and human life.

EPE has established –on a constant basis- cooperation with accredited laboratories according to EN ISO/IEC 17025:2005, and testing methods which are in line with the requirement of Appendix 9 of the MEPC.269(68) Guideline and Annex C of EMSA IHM Guidance for analysis of asbestos and other hazardous materials.

Classification Approvals

EPE has been approved by major classes for services onboard ships as Hazmat Expert Company and for Quality Assurance for identification, sampling, reporting and
preparation of Inventory of Hazardous Materials – namely DNV GL, Lloyd’s Register, ABS and Bureau Veritas. All EPE’s HazMat engineers have been trained and certified as Hazardous Materials Experts from DNV GL.

Approved I.H.M Services Provider by:

Member of:

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


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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 FrontlineDOF, 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, YachtsCruise shipsFishing vesselsShipping & Cargo vessels, Rigs, FPSOs and Defence & Security vessels.

Inspector at work
One of our inspectors at work

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


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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


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Verifier’s Perspective of 2019 Emissions Report Verification 

As the verification season for the first CORSIA monitoring period draws to an end, its magnitude dawns on us. We have just taken the monumental first step in our journey towards a cleaner and greener aviation industry. The verification of the first CORSIA baseline year was overshadowed by the pandemic which wrought havoc on the entire aviation industry. Nevertheless, airlines strove to comply with the CORSIA regulations amidst all uncertainty and hardships.

From a verification body’s point of view, we found it inspiring that despite the COVID crisis, national authorities were holding the airlines to their obligations under CORSIA albeit with prolonged deadlines. We witnessed several airlines struggle to access and provide certain documents needed for the verification due to the restrictions and mandated remote work policies. In these situations, we had to pivot and get creative under the guidance of the ISO 14064 standards and the SARPS to find other ways to manage risks and arrive at a reasonable assurance where possible.

Having concluded 188 CORSIA verifications with another 45 underway, we have learnt a lot and wish to share our experience with everyone. The purpose of this article is to share our perspective on the various issues we observed during these verifications with the intention of sharing best practices and recommended improvements that all operators can benefit from. In line with the above, find below a list of the most commonly observed “non compliances”, “misstatements” and other points of improvement. The below sections have been compiled with inputs from VERIFAVIA’s team of auditors.

Non-Compliances with the EMP

A non-compliance with the EMP arises when the monitoring, reporting was not performed according to what is declared in the Emissions Monitoring Plan.

We came across a number of varied non-compliances with the EMP. By far one of the most common one was that the EMP did not have a procedure listed for the handling of wet leased flights and their data. This is also a non-compliance with the SARPS, owing to its importance. Similarly, it was also noted that a lot of the EMPs were lacking information about the procedures concerning the handling of exempted flights, documentation and record keeping, identification and handling of data gaps. In a few cases, the source of flight data was found to be different to the actual used data and was many a times accompanied by the incorrect application of a fuel use monitoring method.

Non-Compliances of the EMP with the SARPS

A non-compliances of the EMP with the SARPS occurs when the EMP has procedures listed which do not comply with a particular aspect of the regulation (SARPs, ETM, National Regulation for CORSIA).

  • 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.
Non-Conformities and Misstatements*
*These pertain solely to the Emissions Report (ER).When the process in place does not conform to the procedures described in the EMP resulting in incorrect numbers or missing information in the ER it is deemed a non-conformity. These will always result into a misstatement. Misstatements are errors in the data/report ER resulting in incorrect numbers or missing information in the ER. These misstatements can be material or non-material.

  • 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.

Other Notable Points Of Improvement

Keeping the above aside, we also encountered a diverse assortment of issues. These do not qualify for any of the above categories as long as they are corrected/rectified prior to the issuance of the verification report.

  • 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.

In conclusion, CORSIA 2019 is one small step for airlines but a giant leap for the planet. Yes, there have been many challenges along the way and most of the procedures associated with reporting and verification are novel to most operators which haven’t been exposed to the EU ETS. Admittedly, the COVID crisis will present a new set of challenges during the verification season for 2020, but with concerted efforts we can overcome them and continue growing.

Source: verifavia


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Issue

The historic aircraft carrier INS Viraat, beached at Alang on September 28, will continue to stay in its place until a team of workers start dismantling it.

 

Details

  • Usually, when a vessel is beached at Alang, it uses the force of high tide as well as its own engine power to glide on to the shore at speeds ranging between 15-20 knots.
  • Viraat has been secured by iron ropes that are tied to diesel-powered wrenches. This ensures that the vessel does not tilt or change its position during tides and ebbs.
  • The owners of Shree Ram Group which bought INS Viraat from an auction said their plots were “green ship recycling” yards which have certificates from Hong Kong Convention and European Union.
  • As it is a green yard, it is ensured that the ship is not broken down in the sea and the entire vessel is broken once it is dragged to the shore. Cranes are also used to ensure that the broken parts do not fall into the sea.
  • During high tide, the sea-facing wrenches which are connected with iron ropes fastened to the aircraft carrier will be switched on. These wrenches will slowly drag the warship to the empty space on the beach.
  • The ship will need a “cutting permission” from the Gujarat Pollution Control Board and the Gujarat Maritime Board before the dismantling can commence. This will be done after a physical inspection of the ship by different agencies post-beaching.
  • The oil in engines and other machinery have to be emptied. Old batteries have to be removed. Any flammable liquids including the left-over fuel in the tanks will have to be pumped out.
  • These tanks have to be cleaned and made free of any residue gases accumulated inside the fuel tanks.
  • Once the ship comes on the shore, an independent agency will prepare an Inventory of Hazardous Materials (IHM). This agency will go on-board, take all samples including the persistent organic pollutants (POPs).
  • This IHM acts as a guide and the ship breaker makes marking on board the vessel indicating the hazardous portions of the ship. Then the HAZMAT (hazardous material) team of the ship breaker will remove the hazardous substances before the breaking begins.
  • Once the cutting begins, hazardous substances like asbestos, batteries, and ozone-depleting gases will have to be tackled and disposed of safely.
  • Being a naval ship, it not only has a double hull made of steel plates that are several inches thick but also has multiple small compartments which take time to cut and dismantle.
  • Parts dismantled from ships at Alang are usually recycled or sold. As far as INS Viraat is concerned, automobile companies have already contacted the ship-breaker for the steel salvaged from the warship.

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Source: currentaffairs


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