Marshall Islands issue guidance on IHM requirements

The Republic of the Marshall Islands has issued guideline to inform shipowners and operators about the requirements for the development and maintenance of an Inventory of Hazardous Materials (IHM) for new and existing ships under the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the “Ship Recycling Convention” or “Convention”).

This Guideline provides advice about how to create and what to include on a ship’s inventory of materials, both hazardous and non-hazardous, in order to facilitate a ship’s eventual recycling. This is an updated guidance issued by Marshall Islands which specifically adds the need to include radioactive materials on the IHM.

Ship Recycling Convention

The Convention applies to ships of 500 gross tons or more. Although ships operating through their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly are exempt from the Convention requirements, they are expected to act in a manner consistent with the Convention, so far as reasonable and practicable.

The Ship Recycling Convention was adopted by the IMO in 2009 and continues to be open for signature. The Convention will enter into force 24 months after the date on which 15 States, representing 40 percent of world merchant shipping by gross tonnage (and a combined maximum annual ship recycling volume during the preceding 10 years of not less than three percent) accede to it. The Republic of the Marshall Islands has not yet ratified the Convention. 

The Convention undertakes to prevent, reduce, minimize and, to the extent practicable, eliminate accidents, injuries and other adverse effects on human health and the environment caused by ship recycling, and enhance ship safety, protection of human health and the environment through a ship’s operating life. Although the Convention is comprehensive, the details necessary to comply with it are contained in IMO guidance. The Convention addresses new and existing ships.

Inventory of Hazardous Materials (IHM)

An underlying principle of the Convention is that ship recycling facilities have to be capable of recycling a whole ship, including both hazardous and non-hazardous materials. Though nonhazardous materials are normally not a concern, because of the potential diversity of hazardous materials on board ships, developing and maintaining an IHM would permit a potential ship recycling facility to determine if it has the ability to handle the recycling of all of a ship’s materials completely, or whether its recycling may require partnership with another facility

Regulations 5.1 and 5.2 of the annex to the Convention require that ships have on board an IHM which shall be prepared and verified taking into account guidelines, including any threshold values and exemptions contained in those guidelines, developed by the Organization. The most current version of these guidelines is Resolution MEPC.269(68), Guidelines for the Development of the Inventory of Hazardous Materials.

The IHM is divided into three (3) parts:

• Part I Materials contained in ship structure and equipment;
• Part II Operationally generated wastes; and
• Part III Stores.

Part I is required to be continuously maintained and updated, while Parts II and III are to be prepared before the end of the ship’s life and prior to the preparation of a ship recycling plan by the recycling facility.

Click below to find IMO Resolution MEPC 269(68)

Source: Marshall Islands