A Detailed Document Outlaying All Potentially Hazardous Material Onboard a Vessel
Hazardous material is any substance that can pose a risk to the health and safety of people or to the environment as identified and listed by the Hong Kong Convention (2009) & EU Regulation 1257/2013
Inventory of Hazardous Material (IHM) is a document in which all potentially hazardous materials onboard a vessel are identified, located and quantified and follows IMO Resolution MEPC.269(68) guidelines. Hazardous Material Inventory (Inventory of Hazardous Materials-IHM)
Hazardous Material Inventory (Inventory of Hazardous Materials-IHM)
As you know, as of December 31, 2020, an Inventory of Hazardous Materials (IHM) has been approved for all ships above 500 GT that will visit the EU ports and iron fields. IHM Part I and its certification will be checked frequently and meticulously whether it has been properly prepared in the EU port state controls and whether necessary updates have been made.
There are many classes of hazardous substances to be checked for IHM Part I. The IHM Part I hazardous materials analyzes specified in the regulation, including asbestos analyzes, are carried out by our Accredited Laboratory.
In general, more than 35,000 ships in total will need IHM under these rules. Given the current situation with the Covid-19 and pandemic process experienced worldwide, it does not seem possible for HazMat Experts and analysts to meet this capacity and provide certification. We recommend you to plan according to this information.
Scope & Definitions
The Regulation applies to ships on international voyages, of 500 GT and above flying the flag of a Member State or the flag of a third country under the conditions of Article 12 of the Regulation.
The Regulation applies to all vessels of any type whatsoever operating or having operated in the marine environment including submersibles, floating craft, floating platforms, self-elevating platforms, FSUs and FPSOs, as well as ships stripped of equipment or being towed.
It does not apply to any warships, naval auxiliary or other ships owned or operated by a state and used, for the time being, only on government non-commercial service. ‘New’ and ‘existing’ ships, ‘ships going for recycling’ as well as ‘ships flying the flag of a third country’ shall have on board an IHM in accordance with the relevant provisions of Article 5 or Article 12 of the Regulation.
Definitions
The terms used in this guidance document have the same meaning as those defined in the Regulation and in the IMO guidelines with the following additional definitions which apply for the purposes of this guidance document only
IHM Process is the whole process of development and maintenance of an IHM throughout the operational life-cycle of the ship. It involves all the steps of developing an IHM including issuing/checking of any relevant documentation (e.g. Material Declarations), sampling and analysis, verification and life-cycle management
Individual IHM Expert is a person who has the appropriate training, qualifications and knowledge to conduct HM surveys for the development and maintenance of an IHM. He or she should have experience on ship structure and on handling of HM and sufficient knowledge of how to compile an IHM and of all the relevant international and EU legislation14
IHM Expert Company is an entity employing or contracting individual IHM experts to conduct any relevant work or task in relation to the IHM process for the purpose of compiling or updating Inventories of Hazardous Materials. The IHM expert company should use a documented management system and should work on suitable standards, covering the relevant activities of the company
IHM Survey is an investigation to trace and identify the presence or absence of Hazardous Materials contained in the equipment, systems, and/or areas on board a ship and may include review of any relevant documents, visual inspections and sampling
Sampling Check is the taking of samples to identify the presence or absence of HM contained in the equipment, systems, and/or areas on board a ship, by suitable and generally accepted methods such as laboratory analysis
Representative Sampling is a method to sample materials of the same kind in a representative manner. Such materials should be checked to ensure that they are of the same kind
Blank Sample is a clean sample or sample of matrix processed so as to measure artifacts in the measurement (sampling and analysis) process
Blind Sample is a sample submitted to evaluate performance with concentration and identity unknown to the analyst
Bulk Sample is a sample taken from a larger quantity (lot) for analysis or recording purposes
Specific Testing is a repeatable and reliable method of testing samples, which can demonstrate definitively whether a Hazardous Material exists or not and provide a known type of the Hazardous Material
Accredited Laboratory is a laboratory accredited in accordance with ISO 17025 or an equivalent standard for the purpose of conducting specific tests for HMs included in the SRR and capable of providing a written report that can be relied upon by all parties.
Faq
Faq Frequently Ask Questions about Inventory of Hazardous Materials
1Who has the responsibility for organizing the IHM report?
The ship owner or managing agent is responsible for commissioning an Inventory of Hazardous Material.
2What are the different types of IHM surveys?
There are 2 different types of Inventory Hazard Material Surveys. Part I which includes Tables A and B and Parts II & III which includes Tables C and D.
3Which IHM Survey do I need?
We can assist with the process by asking about the ships future plans, if the ship is going to be recycled, refurbished or kept in service, we can design the most effective solution for your requirements.
4What is Part I of an IHM Survey?
This is Part I of the Inventory of Hazardous Materials standard for newly built and active ships. Tables A and B are only completed as described in the MEPC.269.(68). This provides the ship owner with a comprehensive management plan of all the hazardous materials on-board the ship.
5What is Parts II & III of an IHM Survey?
This is Parts II & III and Tables C and D are completed, as described in MEPC.269.(68). This will be far more intrusive in its nature and determine a more complete hazardous inventory, ideally aimed at those vessels nearing the end of service or being dismantled.
6What are the main materials reported in an Inventory of Hazardous Material report?
The 5 main categories to be identified in Table A are, Asbestos, PCB’s, TBT’s, ODS & PFOS. Other 10 hazardous materials in Table B are Mercury, Hexavalent Chromium, HBCDD, Radioactive Substances, Certain shortchain Chlorinated Paraffins, Cadmium, PCN, PBDE, PBB, & Lead will be determined in the later part of the report.
7What is Asbestos?
It is a naturally occurring fibrous mineral that has the ability to resist heat, fire and electricity. If you inhale these fibres they can damage your lungs. Asbestosis – a non-malignant scarring of the lung tissue. Asbestos-related lung cancer. Mesothelioma – a form of cancer mainly affecting the lining of the lungs.
8What are the main types of Asbestos?
There are 6 different types of asbestos mineral fibre. Chrysotile belongs to the Serpentine family. Amosite Crocidolite, Anthophyllite, Tremolite and Actinolite belong to the Amphibole family.
9What if I discover Asbestos?
If you don’t know whether or not a material you discover is potentially containing asbestos, contact IHM Marine Surveys and our Consultants will advise you on the safest way of managing the material.
10What are PCB’s?
A polychlorinated biphenyl (PCB) is an organic chlorine compound with the formula C12H10−xClx. Polychlorinated biphenyls were once widely deployed as dielectric and coolant fluids in electrical apparatus, carbonless copy paper and in heat transfer fluids.
11What are TBT’s?
Tributyltin (TBT) is an umbrella term for a class of organotin compounds which contain the C4H9 3Sn group, with a prominent example being tributyltin oxide. For 40 years TBT was used as a biocide in anti-fouling paint, commonly known as bottom paint, applied to the hulls of ocean going vessels.
12What are ODS?
Ozone depleting substances (ODSs) are those substances which deplete the ozone layer and are widely used in refrigerators, air-conditioners, fire extinguishers, in dry cleaning, as solvents for cleaning, electronic equipment.
13What is PFOS?
Perfluorooctane Sulfonic Acid (PFOS) is chronically toxic, injurious to reproduction, carcinogenic, toxic to marine organisms. In the marine industry, it can be found in fire-fighting foams of the type AFFF on vessels carrying inflammable fluids and those with helicopter decks, rubber and plastic materials (cable sheaths, PVC flooring, gaskets & seals) and coatings (paint).
14How long does the IHM survey take?
Depends on the type of vessel requiring an IHM. The report can take for a few days to a week or a number of months depending on the size of vessel and any future plans.
15Where can the IHM survey be carried out?
We can carry out the IHM survey around your schedule, this can be carried out while the vessel is at sea or in a port. We can have a survey team on-board within 24 hours.
16How long is the IHM survey valid for?
The IHM Report is valid for 5 years and requires an annual inspection by a competent person. We can provide your crew and engineers with training in the management of the recommendations within the IHM report.
17Once I have the Inventory what is the next procedure?
Once you receive your IHM report we will impose recommendations that are to be followed to make the vessel compliant. Also you will be made aware of any urgent recommendations that require immediate attention and our Consultants will assist you with this.
18Why conduct Inventory of Hazardous Materials Survey- IHM?
Be in line with current Regulations, Prepare for compliance regional requirements, Be able to manage maintenance and investments smoothly, Realize a higher resale value of the vessel, Boost your image as a Green Company, Market advantage through better environmental performance, IHM improves the Company’s ISO Management System, IHM contributes to a better health and safety environment on board and Enhancement of ship building quality through IHM (Asbestos and ODS free status).