A ship owner who has completed an Inventory of Hazardous Material (IHM) process for a vessel can achieve the vessel’s compliance to the Hong Kong Convention and the EU Ship Recycling regulations (SRR). However, this is only the first step to compliance, as the owner must ensure continuous conformity of the Inventory, according to Rick Power, Senior Manager – IHM at Wilhelmsen.
To ensure compliance to regulations, Mr. Power highlights some practical points when it comes to IHM maintenance of the Inventory list:
- Review current approved IHM report. In particular, take note of the list of PCHM in the report.
- Understand what can be potential hazardous materials onboard. These information are commonly available in Visual Sampling Check Plan (VSCP), location diagram & approved IHM report.
- Identify purchase orders that could contain potential hazardous materials. In particular, purchase orders related to:
- Renewal of spare parts list – that could potentially contain hazardous materials (PCHM)
- Structural conversions or repairs
- Dry dock
- Machinery or equipment is added
- Hull painting
Work relevant to insulation, gasket and break lining could contain hazardous materials.
- Begin the data collection process for purchase orders with potential hazardous materials. This can be done by sending Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) templates to your suppliers (Tier 1 suppliers).
- Analyze the MD and SDoC, and update Part 1 of IHM if hazardous materials are found.
- Send the updated Inventory to Class. WSM recommends a monthly delivery to Class if there is any update on the Inventory list.
Mr. Power further notes it is the Tier 1 supplier’s duty to provide MD and SDoC. The Tier 1 suppliers may request from their own suppliers (Tier 2 suppliers) for relevant information if they cannot develop the MD based on the information available.
Thus, the collection of data on hazardous materials may involve the entire supply chain. The information data flow is illustrated herebelow:
WSM recommends keeping your Inventory a living document. To ensure the sustainability of this effort, cooperation between the shipmaster, vessel manager/superintendent, procurement department and the DP is very important.
