The Inventory of Hazardous Materials (IHM) was introduced in the 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships. All ships weighing over 500GT will be required to carry the Inventory of Hazardous Materials.
The purpose of an IHM survey is to provide ship owners, managing agents, crews, engineers and workers with a management report of all the hazardous materials, which are on-board the vessel.
Part I Tables A and B of the IHM Survey is for newly built and active ships. Parts II & III Tables C and D of the IHM Survey, this will be far more intrusive in nature and will determine a more in-depth report, ideally aimed at vessels undertaking major refurbishment works or vessels going for recycling in accordance with the Ships Recycling Regulations (SRR).
Guidance on IHM survey and certification
The Hong Kong Convention was adopted in 2009 to ensure safe and environmentally friendly ship recycling of ships that have reached the end of their operating lives.
Upon entry into force, the Hong Kong Convention will require new ships and existing ships of 500 GT and above, no later than 5 years after the entry into force of the Convention, or before going for recycling, if this is earlier, to have onboard a valid International Certificate of Compliance (IHM).
The Hong Kong Convention identifies the following surveys to be performed by the Administration or ROs:
-Initial IHM survey: to verify whether Part I of the IHM has been prepared in accordance with the Hong Kong Convention. Note that there are different requirements for the initial surveys of new ships and those for existing ships.
Initial survey for new ships:
- Prior to the initial survey for a new ship, a request for the initial survey should be submitted by the shipowner or the shipyard to an authorized Recognized Organization along with the ship data required for the Statement of Compliance on IHM;
- The request for an initial survey should be supplemented by Part I of the IHM along with the MD and SDOC and all other documents used to develop the IHM;
- The survey should verify that Part I of the IHM identifies the Hazardous Materials, their location and approximate quantities, by checking the MD and SDOC and especially the location of Hazardous Materials, is consistent with the arrangements, structure and equipment of the ship, through onboard visual inspection.
Initial survey for existing ships
- In the case of an existing ship, an initial survey shall be conducted before the Statement of Compliance on IHM is issued;
- Prior to the initial survey, a request for the initial survey shall be submitted by the shipowner to an authorized Recognized Organization along with the ship data for the Statement of Compliance on IHM;
- The request for an initial survey shall be supplemented by Part I of the IHM;
- Part I of the IHM shall be developed through a visual check and/or sampling check on board the ship, based on the visual/sampling check plan in accordance with Resolution MEPC.268(68) and be submitted by the shipowner to an authorized Recognized Organization along with supporting information such as the report of the visual/sampling check and/or MD and SDOC;
- The visual/sampling check plan and Part I of the IHM shall be prepared by an IHM Expert Company in accordance with Resolution MEPC.269(68);
- The survey shall verify that Part I of the IHM identifies the Hazardous Materials, their location and approximate quantities, by checking supporting information such as the report of the visual check and/or sampling check and/or MD and SDOC. the MD and SDOC and especially the location of Hazardous Materials, is consistent with the arrangements, structure and equipment of the ship, through onboard visual inspection;
- The survey shall further verify that the IHM, especially the location of Hazardous Materials, is consistent with the arrangements, structure and equipment of the ship, through onboard visual inspection;
-Renewal IHM survey: is to be carried out at intervals not exceeding five years. This survey shall verify that Part I of IHM complies with the requirements of this Convention.
Additional survey: at the request of the shipowner after change, replacement or significant repair of the structure, equipment, systems, fittings, arrangements and material, which have an impact on the IHM.
-Final IHM survey: conducted before a ship is taken out of service and before the recycling of the ship has started. Prior to recycling, the Inventory shall, in addition to the properly maintained and updated Part I, incorporate Part II for operationally generated wastes and Part III for stores, and be verified by an authorized Recognized Organization, taking into account the guidelines in Resolution MEPC.269(68).
Issuance and endorsement of certificates
A Statement of Compliance on IHM shall be issued either by an authorized Recognized Organization after successful completion of an initial or renewal survey conducted in accordance with the above.
Upon entry into force of the Hong Kong Convention, the Statement of Compliance may be replaced with an International Certificate on IHM without additional onboard surveys, provided the IHM has been maintained and updated as required.
EU Regulations on IHM
The EU pursues an ambitious policy to make ship recycling greener and safer. Currently, a vast majority of large vessels are dismantled in poor social and environmental conditions in South Asia. The impact of ship recycling has been documented in a thematic issue of Science for Environment Policy published by the Commission in June 2016.
The Ship Recycling Regulation adopted in 2013 by the European Parliament and the Council of the European Union aims to reduce the negative impacts linked to the recycling of ships flying the flag of Member States of the Union. The Regulation lays down requirements that ships and recycling facilities have to fulfil in order to make sure that ship recycling takes place in an environment sound and safe manner.
Rules relating to hazardous materials on ships
The Regulation first prohibits or restricts the installation and use of hazardous materials (like asbestos or ozone-depleting substances) on board ships.
New European ships and EU-flagged ships going for dismantling must also have on board an inventory of hazardous materials (IHM) verified by the relevant administration or authority and specifying the location and approximate quantities of those materials. This obligation will also apply from 31 December 2020 to all existing ships sailing under the flag of Member States of the Union as well as to ships flying the flag of a third country and calling at an EU port or anchorage.
This will facilitate the recycling of vessels and reduce the presence of toxic materials on board ships. In November 2016, EMSA, the European Maritime Safety Agency, published a Best Practice Guidance on the Inventory of Hazardous Materials for practitioners on the field, ship owners and national authorities. EU Member States’ port authorities will control ships to verify whether they have on board a ready-for-recycling certificate or a valid inventory of hazardous materials.
The EU Regulation and the Hong Kong Convention
The Regulation brings forward the requirements of the 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, therefore contributing to its global entry into force. The Regulation also includes additional safety and environmental requirements, as authorised by Article 1(2) of the Convention. The Hong Kong Convention has not entered into force.
Source: https://ec.europa.eu/environment/waste/ships, http://www.imo.org/en/OurWork/Environment/ShipRecycling/Pages/Default.aspx