During the SAFETY4SEA Hamburg Forum 2024, Henning Gramann, CEO, GSR Services GmbH, gave a presentation focusing on the Inventory of Hazardous Materials (IHM). IHM is a document outlining all the existing hazardous material onboard ships.
Basically, when we look into the regulations, what we see in many more industries is that we follow a cradle-to-grave approach. The same is followed ship recycling regulations. The core aspect for the shipping industry, including suppliers, manufacturers, and building yards, but also, of course, ship owners and ship managers, is the IHM, the inventory of hazardous materials, documentation of the hazardous substances in the structure and equipment of the ships.
Accordingly, each group of stakeholders has its own tasks on this road. For manufacturers, we talk about material declaration development; they have to document what hazardous substances are contained in their products. The suppliers have to get these documents and provide them to their customers, which means the shipyards or the ship owners. Ship owners have to get the inventory prepared for their existing ships primarily based on inspection and sampling. For new ships the only option is based on suppliers´ documents. The maintenance of IHM has to follow the same approach as applicable for newbuildings and once time has come be provided to the ship recycler so that he can plan for the safe and environmentally sound recycling of ships.
Key requirements for ships
Today ships have to have a certified IHM, and they have to maintain it under EU ship recycling regulation since end of 2020 when a ship visits in EU Port regardless of flag and all EU flagged vessels.
The international convention for safe and environmentally sound ship recycling so-called “Hong Kong Convention” will enter into force on 25th of June 2025, and will become a more global requirement.
The core meaning of IHM maintenance
The IHM for a ship that is certified describes the status quo of the hazardous substances in the structure and equipment of the ship. We are not talking about cargo; we are not talking about loose items. IHM-Maintenance means that we have to focus on the changes that happen during refit, repairs and also during normal ship operations. That means we have to track the hazardous materials in case a change is happening onboard. This is really what we have to digest, and we have to think about how we can put that into practice. It all starts with the order by ship owners.
IHM maintenance
#1: Categorize order items: Owners, when making an order, each and every order item has to be evaluated whether or not it is IHM-relevant and might cause a change on board the ship first. The big obstacle here is that some understand that they have to evaluate whether or not an order item might contain hazardous materials, no, that’s a completely wrong approach! We have to check order items to see whether or not they are relevant for the IHM maintenance or excluded by the rules and regulations.
#2 Relevant: Request to Supplier (<5%): If your performance is good, an average of only 5% of all order items is classified as relevant for IHM maintenance. If well above, those involved should look at the approach. Certainly wrong is to send out requests based on assumptions that a hazardous material might be contained in a product.
For each justified request, the supplier must furnish a Suppliers Declaration of Conformity (SDoC), which specifies the legal basis, and product or product group specific Material Declarations. Traders often lack detailed knowledge in this area. Consequently, when a ship owner or his service supplier bombards the supply chain with numerous requests for these declarations, it sets off a complex chain reaction. Owners must exercise discretion in their requests as every inquiry can prompt inquiries down the supply chain to manufacturers and beyond, creating a web of exchanges, liabilities and costs. Same applies requesting order, ship or customer specific documents, that is not necessary and only increases efforts without adding any value.
#3 Monitoring and checking documents: When you request documents from a supplier, you have to monitor whether they are provided or not and if they are accurate. Little mistakes can shift liabilities towards customers, but that needs to be prevented.
#4 Segregate “Positive” &”Zero MDs”: When we get a so-called zero declaration – where a supplier states that none of the hazardous substances are contained – we can put it straight into the archive.
#5 Track positive items onboard: Only those where the supplier states via a “positive MD” that a hazardous substance is contained, it needs to be tracked onboard the ship. And that only applies to 1% of the 5% of relevant order items. Little activity on board a ship is required for proper IHM maintenance , but owners need to have a sound system, a very good process and the people who are involved in this process have to be trained.
#6 Update IHM & report 24/7/365: If the chief engineer onboard is responsible for the tracking of these items onboard but he is on shore leave, the information is gone with him, if he is not updating the documents before he takes his leave. As such his input should be possible 24/7 via a suitable system, not by emails or phone calls.
A targeted compliance data exchange for IHM-Maintenance is crucial; failure in applying such principles could lead to serious consequences.
What about your IHM approach?
- Dedicated knowledge
- Cost effective and selective processing
- Convenient & Supportive
- Efficient and
- Compliant
Answering all with a “Yes” is possible when the above principles are applied.
The views presented are only those of the author and do not necessarily reflect those of SAFETY4SEA and are for information sharing and discussion purposes only.
Above article is a transcript from Henning Gramann’s presentation during the 2024 SAFETY4SEA Hamburg Forum with minor edits for clarification purposes.
Explore more by watching the video presentation here below
