Inventory of Hazardous Materials: From theory to practice

Fotis Ploumitsakos, Naval Architect & Mechanical Engineer, EPE, gave a presentation entitled “Inventory of Hazardous Materials: From theory to practice’’. Mr. Ploumitsakos underlined the obligation for an IHM onboard all vessels with EU flags and those which visit EU ports according to the EU Ship recycling regulation 1257/2103. He referred to the practical parameters on the preparation of an IHM in order to be considered sufficient and also to the required qualifications and credentials for the HazMat Experts who are responsible to prepare it on behalf of ship operators.

Based on EU Regulation 1257/2013 and IMO Guidelines, the following steps are required for the preparation of an IHM:

1. Collection of necessary information
2. Assessment of collected information
3. Preparation of visual/ sampling check plan (VSCP)
4. Sending VSCP for approval by the Classification (if required)
5. Onboard visual/ sampling survey
6. Preparation of IHM Part I and related documentation
7. Delivery of IHM Part I

According to the E.U. Regulation the Hazardous Materials are separated in 2 annexes which are corresponding to Tables A & B of IMO Guidelines plus 2 additional materials (PFOS & HBCDD).

Annex I includes the materials that are mandatory to be recorded in IHM Part I (asbestos , Ozone depleting substances , PCBs , PFOS , and anti-fouling compounds and systems).

Annex II includes Annex I and materials which should be identified in the IHM as far as practicable.

For the preparation of an IHM, it is important to note that the first stage, which is the collection of proper information, becomes difficult for an old vessel as in many cases, the data are neither accurate nor updated and don’t contain vessel’s whole history. However , Visual/ Sampling Check Plan (VSCP)  is prepared based on available information and HazMat experts’ experience, including all areas / systems / equipment  which are needed to be checked visually or by using samples. Afterwards, having the plan ready, we are able to start onboard survey in which we should check not only visible areas but also to see below the surface. We have to check as more as possible areas because some areas onboard may have same definitions and same use but they may include different materials, for example different types of cabins in a passenger vessel. The same applies to different materials for the same use; therefore, conversions, repairs, modification and new installations may increase the need of sampling.

While all accessible areas are being checked (voids, non-visible areas , etc) in accommodation, engine room and machinery areas by collecting samples of different types (bulk samples , oils’ samples, wipe tests, etc), safety of crew and passengers onboard and vessel’s proper and safe operation should be the first priority. Also, during the survey, HazMats experts may require targeted visual check of equipment and of the areas which are being characterized as ‘contained’ in the VSCP. Again, we need to highlight that checking behind the obvious is of outmost importance! Therefore, HazMats experts should check to the whole depth all hidden layers and hidden materials. Restoration of sampled areas could be applied if needed to any possible extend; even temporarily until permanent restoration. During the survey, we need to mark the sampling points on vessel’s General Arrangement. Then, sample analysis follows in Laboratories Accredited according to ISO 17025 for the analysis of the specific types of materials using appropriate testing methods.

Finally, records of samples analysis’ results and approximate calculation of Hazardous Materials Quantity are required for IHM reporting and the document is ready for check and certification.

 The IHM is consisted of three parts: the first is for paints and coating systems , the second is for equipment and machinery and the third part is for structure and hull. In order to locate easily all HazMats found onboard, we mark the areas on the vessel’s plan.

“An 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 should have experience on ship structure and on handling of HM and sufficient knowledge of how to compile an IHM and all relevant international and EU legislation.” EMSA’s Best Practise Guidance on the I.H.M.

 “He should work within a general quality assurance framework provided by a management system in accordance with the overarching principles for the development and maintenance of the IHM.” EMSA’s Best Practise Guidance on the I.H.M.

“An 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 HazMats. The IHM expert company should use a documented management system and should work on suitable standards, covering the relevant activities of the company.” EMSA’s Best Practise Guidance on the I.H.M.

Principles like independence ,  quality and accountability should be apply during the whole process of preparation and maintenance of an IHM for all relevant stakeholders.

 To be approved, companies have to meet certain standard’s requirements according to ISO 9001, ISO 17020 or ISO 17025, especially if they are offering laboratory services.

Above text is an edited article of Fotis Ploumitsakos presentation during 2017 GREEN4SEA Conference & Awards

You may view his presentation video by clicking here

The views presented hereabove are only those of the author and not necessarily those of  GREEN4SEA and are for information sharing and discussion  purposes only.