Maintaining your IHM
Rick Power , Senior Manager - IHM
If you have completed the Inventory of Hazardous Material (IHM) process for your vessel, congratulations you have completed an important step to future proof your vessel's compliance to the following regulations:
- Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009)
- EU Ship Recycling regulations (SRR)
To ensure you remain compliant to the regulations, you need to know the following:
Is obtaining Statement of Compliance (SOC) mandatory?
If your vessel will be in service after completion of IHM survey, obtaining SOC from Class Society will be mandatory to remain compliant.
However, if the vessel transits directly to its recycling facility after IHM inspection, then there is no requirement for Class SOC.
How long is the SOC validity?
5 years. To renew, you will be required to provide your most recent IHM report and proof of documentation for IHM maintenance.
Who is responsible for maintaining the IHM process?
It is the shipowner's responsibility for the maintenance of Part 1 of the IHM process during the lifetime of the vessel. Continuity and conformity of the information should be confirmed, especially if the flag, owner or operator of the ship changes.
When should the IHM maintenance process start?
As soon as any changes occur during vessel operations such as below, you are required to update Part 1 of IHM.
- 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
Do I need to be a certified Hazardous Material (HazMat) expert to execute the IHM maintenance process?
No, but you must have knowledge of indicative listing of hazardous materials in line with European Maritime Safety Agency (EMSA) Guidelines & MEPC 269(68). WSM recommends having a designated person (DP) responsible to maintain and update the Inventory.
What are the available tools to support my Inventory maintenance process?
Availability of tools are dependent on the class society issuing your vessel’s SOC. Different class society would offer integrated software catered for IHM maintenance tracking. User license can be purchased for fleet or individual vessels through classification societies.
Here are some practical pointers 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:
In our experience, 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.|
Data from suppliers
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 below:
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.