During the last SAFETY4SEA Hamburg Forum, Gunther Zeitzmann, Ship Recycling Engineer and member of the International HazMat Association (IHMA), highlighted the importance of preparation, certification and maintenance of an Inventory of Hazardous Materials (IHM) for compliance with the requirements of Hong Kong Convention and EU-Ship Recycling Regulation. He further referred to key steps for effective development of IHM and certification; the operations and maintenance of the IHM and the importance of control with flags, classes and PSC.
For every ship, it’s only a matter of time when it becomes waste – a term of Basel Convention about the regulated transboundary movement of wastes. But a ship consists of above 90% Recyclables and Re-usables. A ship might contain Hazardous Materials for human health and environment as well but therefore the IHMA professionals are predestined to identify those materials in so called hot spots and exchange their experiences within meetings.
A certified and maintained IHM is required by:
- IMO: “Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009) (not in force yet)
- EU-Ship Recycling Regulation (1257/2013) (EiF: 30.12.2013)
Both are valid for floating structures above 500GT except governmental owned ships and ships operating in national waters, and address all stakeholders who are involved in a ship’s life, started with component manufacturers and ends up with Ship Recycling Facilities (SRF).
The IHM is divided into three Parts – with a clear focus on Part I, which has to be fulfilled when the ship is being delivered or in operation. Part II and III have to be prepared prior ship recycling and contains operationally generated waste and those from stores and household appliances.
In case of ship newbuildings, shipyard is responsible for preparing an IHM based on information from suppliers of ships´ structure and equipment. In that case, Suppliers need to provide Material Declarations (MDs) and Suppliers Declaration of Conformity (SDoC) for related deliveries to Shipyards (for ships under construction) and Shipowners (for IHM maintenance).
The supply chain follows the following procedure: the ship yard requests MDs and SDoC from their Tier 1 supplier which forward their possible requests for subcomponents further down the line to Tier N supplier. After issuance of IHM together with the delivery of ship, shipowner is responsible to maintain the IHM according to IHM Guidelines. This IHM will be certified e.g. by classification societies and after 5 years potentially recertified.
Regarding existing ships, shipowners are responsible for the development of an IHM Part I during the operational phase; additionally for IHM Part II & III prior to recycling. As per indicative list from IHM Guidelines and shared experience, it is recommended to shipowners to seek support from approved hazardous materials experts. According to EU-SRR, every ship flying the flag of an EU-Country or entering European waters, have to have a certified IHM, by the end of 2020.
The IHM-Preparation is based mostly on sample takings and visual inspections for which detailed documentation is required. Both are documented e.g. in a General Arrangement Plan. Positive findings are listed in the IHM. Sampling documentation, laboratory results and related IHM (Part I) are essential parts in the IHM-Report.
The IHM is a “Technical File” which requires accuracy. Not being able to provide an accurate IHM to i.e. PSC could come to a cost which might outweigh the costs for the development of a decent IHM by far. Approximately 48,000 ships are addressed worldwide under the Hong Kong Convention whereas approximately 30,000 are falling under EU-SRR, meaning that appr. 75 vessels have to be equipped with a certified IHM daily to comply with the requirements until the deadline. However, availability of HazMat Experts, classification societies and accredited laboratories seems to be limited.
MEPC.269(68) provides details on the maintenance of IHMs referring also that a Designated Person is required to monitor and supervise the maintenance process, and what kind of new installations have to be considered. The maintenance of an IHM could be also checked by PSC.
At a glance, IHM-maintenance is a convenient approach which consists of
- Evaluation of purchases and exchange with suppliers
- Data processing and control involving ship – shore – supplier – IHM
- Changing contents of certified IHM (“working copy”)
The IHM Maintenance can theoretically be prepared paper based but this might not be a sustainable approach. Instead, the use of a software tool for IHM development could be an advantage also with respect to IHM maintenance which will be required afterwards.
Conclusion: the IHM is a key requirement for ships since one day they will become waste! The deadline of certified IHMs for all ships is approaching fast and the resources are limited as far as IHM experts, accredited laboratories and classification societies are concerned. The guidelines are precise but application and control are not. In this regard, shipowners need to select their service supplier carefully and consider responsibilities and associated risks. Action of everybody involved has to be taken because the inhouse implementation of the overall IHM processes might be a challenge. An IHM is basis for safe and sound recycling; it’s not rocket- science but quick action is required.
Above text is an edited version of the Gunther Zeitzmann’s presentation during the 2019 SAFETY4SEA Hamburg Forum.
You may view his presentation here.
The views presented hereabove are only those of the author and not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.
About Gunther Zeitzmann, Ship Recycling Engineer, IHMA
As an engineer for Naval Architecture & Ocean Engineering, Gunther started his career in ship recycling business in 2008 by investigating efforts for shipowners implementing the IMO Hong Kong Convention (HKC). In that, he initiated a project consisting of a shipping company, classification society and a HazMat consultancy to equip a first ship with a certified Inventory of Hazardous Materials (IHM). While working for Germanischer Lloyd, he was involved in IHM related surveys, approving IHM’s, training of surveyors and witnessing of HazMat Experts. For two years later on, he was in charge for compliance of Integrated Management Systems and HSEQ matters within the class’ Oil and Gas sector in Germany. Since April 2015 he works as Ship Recycling Engineer for GSR Services GmbH in all the company specific fields.