New environmental rules are coming into force and Global Maritime is ready to help you with certified experts to perform IHM analysis. Going forward Shipowners and Shipbuilders must demonstrate safe and environmentally viable management of Hazardous Material.

Global Maritime has experts certified as “Approved Hazmat Experts” by DNV-GL and can assist with an effective process for generation of correct IHMs, to comply with the following new regulations:

EUSRR – European Ship Recycling Regulations

HKC – Hong Kong International Convention for the Safe Environment Sound Recycling of Ships

What is Inventory of Hazardous Material (IHM)?

An IHM is a document that states what types and quantities of hazardous materials are present on board your vessel.

The IHM Consists of three (3) Parts:

PART I: Hazardous materials contained in the Ship’s Structure and equipment

PART II: Operationally generated wastes

PART III: Stores

(PART II & III Should be prepared only prior Recycling)

How are these new regulations being implemented?

EU-Flagged New-buildings are required to have onboard a verified IHM with a statement of Compliance 31st December 2018, at the latest

Existing EU-Flagged vessels are required to have onboard a verified IHM with statement of compliance at 31st December 2020, at the latest

Non-EU-Flagged vessels calling EU ports are required to have onboard a verified IHM with a statement of compliance at the earliest by 31st December 2020.

Source: globalmaritime

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

From 31 December 2020, all ships of 500 GT and above – regardless of the flag they are flying – will be required to carry an inventory of hazardous materials (IHM) when calling a port or anchorage of a country that is a member of the European Union (EU) or European Economic Area (EEA). Failure to do so may result in penalisation.

The European Union’s Ship Recycling Regulations (EUSRR) that came into force in December 2018 pose certain obligations to all ships of 500 gross tonnage (GT) and above, flying the flag of countries in the EU or EEA, with certain exceptions such as warships, naval auxiliary or other ships on non-commercial service.

In addition, there is a requirement in EUSRR that applies to not only ships flying the flag of countries in the EU or EEA but also to all ships of 500 GT and above, regardless of the flag they are flying, when calling a port or anchorage of a country that is a member of the EU or EEA.

The requirement is that from 31 December 2020, all such ships should carry an inventory of hazardous materials (IHM) that is compliant with EUSRR, and for ships flying a flag of country outside the EU/EEA region, this must be accompanied by a statement of compliance from the flag state.

Port state control officers will control the certificate and the quality of the IHM and in case of non-compliance, ships may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of a member state.

For existing ships, the IHM should be based on visual and sampling checks and include the approximate quantity and location of a number of specified hazardous materials on board. While the IHM can be generated by own resources of a shipowner, there are IHM service providers, including classification societies, which already offer such services.

The following guidance documents on this subject are available for users through:

International Maritime Organization (IMO)
A guidance document developed by industry associations including BIMCO
The European Maritime Safety Agency’s (EMSA)
When external companies are used, visual and sampling checks require IHM service providers to board each ship. Experience has shown that the whole process may take three months or longer, depending on the size and construction of the ship and how the desktop review has been prepared by the shipowner.

The International Association of Classification Societies (IACS) provides the following guidance about IHM surveys: “The initial desktop review may be performed remotely and followed up by onboard verification at a later date, subject to flag administration’s approval.”

In the present COVID-19 situation however, possibilities of having IHM service providers and surveyors on board is limited due to travel restrictions and lock-down measures arising from COVID-19.

It is therefore recommended that owners and operators of existing ships, who trade in EU and EEA countries, plan well in advance to comply with EUSRR IHM requirements by the 31 December 2020 deadline.
Source: BIMCO

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