Liberia Maritime Authority issued operational guidance on how to maintain and update Part I of the inventories of hazardous materials (IHM) during operations, in line with Regulation 5 of the Hong Kong Convention and Article 12 of the EU Ship Recycling Regulation (EU SRR). Part I of the IHM shall remain with a vessel throughout its operational life, and be updated as all new installations enter the ship, as these may potentially contain hazards.
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 IHM consists of:
- Part I: Hazardous materials contained in ship structure or equipment, their location and approximate quantities and referred to in Appendices 1 and 2 of the Hong Kong Convention and clarify that the ship complies with the controls of ships hazardous materials;
- Prior to recycling – Part II: Operationally generated wastes; and
- Part III: Stores.
Part I of the IHM shall remain with a vessel throughout its operational life, and be updated as all new installations enter the ship, as these may potentially contain hazards.
The presence of the inventory will then ensure the safety of crew members during the vessel’s operational life, and the safety of workers during the recycling process.
The shipowner is responsible for developing Part I of the IHM and should draw upon expert assistance, for safety and health protection reasons and to ensure that the work is carried out by competent personnel, under a quality management system and in accordance with IMO guidelines in Resolution MEPC. 269(68).
However, such IHM Expert Company should not be the same as the Recognized Organization authorized by the Administration to approve the IHM. The development and maintenance of the IHM should be subject to the principles of independence, quality and accountability.
The following procedure should be followed for determination of Part I of the IHM:
- Collection of necessary information;
- Assessment of collected information;
- Preparation of Visual/Sampling Check Plan (VSCP);
- Onboard Visual/Sampling Check; and
- Preparation of Part I of the IHM and related documentation
Maintaining and updating Part I of the IHM during operations
The Hong Kong Convention requires that the shipowner maintain the IHM, throughout the operational life of the ship.
If any machinery or equipment is added, removed or replaced or the hull coating is renewed, Part I of the IHM should be updated.
Updating is not required if identical parts or coatings are installed or applied.
Part I of the IHM should belong to the ship and the continuity and conformity of the information should be confirmed, especially if the flag, owner or operator of the ship changes.
Requirements for ascertaining the conformity of Part I of the IHM
The conformity of the IHM for new ships (or new installations on existing ships) should be ascertained by reference to the Supplier’s Declaration of Conformity and the related Material Declarations collected from suppliers at the design and construction stage.
To enforce the delivery of Material Declarations, builder’s and operator’s purchase departments are strongly advised to include related clauses in the contracts with suppliers of equipment, systems and installations.
Material Declaration (MD) Suppliers to the shipbuilding industry should identify and declare whether or not the materials listed in Appendices 1 and 2 of the Hong Kong Convention.
However, this provision does not apply to chemicals which do not constitute a part of the finished product.
Information required in the MD At a minimum the following information is required in the MD:
- date of declaration;
- MD identification number;
- supplier’s name;
- product name (common product name or name used by manufacturer);
- product number (for identification by manufacturer);
- declaration of whether or not the materials listed in Appendices 1 and 2 of the Hong Kong Convention are present in the product above the threshold value stipulated in reference (b); and
- mass of each constituent material listed in 6. above
See also: Guidance on IHM survey and certification
Suppliers Declaration of Conformity (SDOC)
The purpose of the Supplier’s Declaration of Conformity is to provide assurance that the related Material Declaration conforms to the information above, and to identify the responsible entity.
The SDOC should contain the following:
- unique identification number;
- name and contact address of the issuer;
- identification of the subject of the Declaration of Conformity (e.g. name, type, model number, and/or other relevant supplementary information);
- statement of conformity;
- date and place of issue; and
- signature (or equivalent sign of validation), name and function of the authorized person(s) acting on behalf of the issuer.
For maintaining and updating the Part I of the IHM throughout the operational life of the ship, reflecting new installations containing Hazardous Materials listed in Appendix 2 of the Hong Kong Convention including the additional materials in the EU SRR and relevant changes in ship structure and equipment, shipowners should implement the following measures in order to ensure the conformity of Part I of the IHM:
-Management policy to maintain the IHM: Designate a responsible person (ashore or onboard);
-Management System to maintain the IHM:
- Request of Hazardous Material Information
- Review of Collected Information of Hazardous Materials o Development of Revision of the Inventory
- Review of Revision and Instruction of Updating Inventory o Update of the Inventory on Board
- Ascertaining the Conformity of the Inventory;
-Continuity of Conformity of the inventory;
-Provide related documents as required for the survey or sale of the ship