Guidance on IHM survey and certification

Liberia Maritime Authority issued practical guidance to shipping on the development and maintenance of inventories of hazardous materials (IHM), in line with Regulation 5 of the Hong Kong Convention and Article 12 of the EU Ship Recycling Regulation (EU SRR).

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:

1. 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;
2. 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;
3. 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

1. In the case of an existing ship, an initial survey shall be conducted before the Statement of Compliance on IHM is issued;
2. 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;
3. The request for an initial survey shall be supplemented by Part I of the IHM;
4. 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;
5. 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);
6. 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;
7. 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.