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.

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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.

Completing an Inventory of Hazardous Materials (IHM), is only the beginning of compliance.

It is the ship owner’s responsibility to ensure continuous conformity of the Inventory.

If you have completed the Inventory of Hazardous Material (IHM) process for your vessel, congratulations you have completed an important step to future proof your vessel’s compliance to the following regulations:

Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009)
EU Ship Recycling regulations (SRR)
After completion of IHM survey, obtaining SOC from Class Society will be mandatory to remain compliant. Any Class Society that has the Flag State approval may issue the SoC.

It is the shipowner’s responsibility for the maintenance of Part 1 of the IHM process during the lifetime of the vessel. Continuity and conformity of the information should be confirmed, especially if the flag, owner or operator of the ship changes.

IHM renewal survey is required for every five years after the IHM initial survey. The requirements are as below:

Ship’s existing IHM certificate and IHM Part I;
The updated IHM (Part I), reflecting any change, replacement or significant repair of structure, equipment, systems, fittings, arrangements and materials since last survey;
Ship’s IHM Part I maintenance record, MDs and SDoCs reflecting the ship’s hazardous materials management since last IHM survey;
Our offering of IHM maintenance server (VSIMS) is designed to help ship owners and managers comply with HKC 2009 and EUSRR regulations.

We believes in staying a step ahead, using data and record collection in the simplest and most economical way possible without any disruption to the day to day managerial operations.

The VS software (VSIMS) not only collects the MDs and SDoCs when items are delivered on board but it also tracks their location onboard till they are finally off landed and providing a clear audit trail of the 15 elements of the hazardous materials identified in the regulations.

At any time a clear snapshot of the vessel can be provided showing how they came on board, how they moved and their current location on board.

A historical data will also be maintained showing how and with whom they were off landed thus providing a circular record with a cradle to grave approach.

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The JMS Yachting management team and the crew of 90m motoryacht DAR have announced the successful certification of the Inventory of Hazardous Materials (IHM) list on board. The certificate was issued by Lloyd’s Register under the authority of the Government of Cayman Islands.

As of 31 December 2020, the EU Ship Recycling Regulation requires that any ship of 500gt and above, of any flag calling at an EU port or anchorage, maintains a Certificate of Compliance (if EU flagged) or Statement of Compliance (if non-EU flagged) supplemented by a verified Inventory of Hazardous Materials (IHM) on board.

This aims to regulate the ship-recycling industry to ensure that end-of-life vessels are dismantled safely, with minimum impact to human health and the environment. The Certificate of Compliance means, among other things, that the vessel shall only be sent to recycling facilities included in the European List of Ship Recycling Facilities at the end of its life.

The IHM then provides ship-specific information on the actual hazardous materials present on board in order to protect health and safety and to prevent environmental pollution at ship-recycling facilities. “It was a lot of work for such a large vessel, but I’m glad we delivered well ahead of the deadline,” commented Rob Pijper, operations director at JMS Yachting.

Many flag states have delegated the authority for the verification of compliance to their respective classification societies, such as Lloyd’s Register. But, with IHM compliance taking some time to achieve and only a matter of months left until the regulations come into force, there is growing concern that many superyachts are ill-prepared for the onset of these regulations.

Source: superyachtnews

Ship recycling

Worldwide hundreds of outdated ships are scrapped every year. The recycling occurs mostly in recycling facilities or yards. A lot of times, these ships are beached (driven onto a flat sandy beach at high speed) for subsequent manual dismantling often without any regards to environmental or occupational health and safety standards.

Ship Recycling Convention will set global standards

The International Convention for the Safe and Environmentally Sound Recycling of Ships, or Hong Kong Convention, is meant to address these problems. This Ship Recycling Convention was adopted by the International Maritime Organization (IMO) in 2009 but so far has not entered into force because the agreement has not been joined by enough member states. The convention contains regulations for shipowners, ship builders, manufacturers, suppliers and for recycling yards.

The Hong Kong Convention will apply to all new and existing sea-going vessels with a gross tonnage of 500 or more.

The new convention introduces two key components to be considered in future:

• Ship-specific Inventory of hazardous materials which lists all hazardous materials such as asbestos, PCB, ozone depleting substances and antifouling paints containing TBT as well as their location and approximate amount.
• Authorization of recycling facilities. Sea-going vessels may only be recycled by authorized yards complying fully with all environmental and safety requirements of the Hong Kong Convention.

The convention will enter into force two years after ratification by at least 15 states representing more than 40 per cent of the gross tonnage of the world’s merchant shipping. The convention was adopted in May 2009 but has not yet entered into force. This is where you can find the current status of this and other IMO conventions (under the heading “Summary Status for each Convention”).

EU Regulation already implements some of the requirements

For all ships

• On international voyages and
• Flying an EU flag and
• With a size of 500 GT or more,

Regulation EU 1257/2013 on ship recycling on the recycling of ships applies and it contains among other things the following requirements:

• These ships may only be recycled on authorized recycle yards on the EU list of recycle yards.
• These ships must carry a ship-specific Inventory of Hazardous Materials/IHM stating as a minimum the hazardous materials on board (structure and equipment) listed in Annex II as well as their location and the approximate amount.
• These ships must hold a Certificate on Inventory of Hazardous Materials.
• Existing ships only require the Inventory of Hazardous Materials and the associated certificate from 31 December 2020.
• The Inventories of Hazardous Materials and the associated certificates are approved by the respective Flag State.
• The ships intended to be passed to be recycled must have a Ready for Recycling Certificate.

Further information can be found in  ISM Circular 03/2019.

Ships flying a flag of a non-EU State that call on a European port are required to carry an Inventory of Hazardous Materials as well as a Document of Compliance.

Source: deutsche-flagge