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THE REGULATION AND ENTRY INTO FORCE

The regulation government the requirement for IHMs are found in IMOs Hong Kong convention(HKC) on ship recycling, which is yet to enter into force, and the mandatory EU ship recycling regulation(SRR) which includes all provisions og the HKC, and a few additional requirements.

The SRR entered into forced in 2013 and the somewhat more stringent regulation already applies to EU flagged ships going for recycling and new ships. All provisions pertaining to IHM will apply by 2020 and all vessels over 500 GT flying an EU member state port must carry an on-board valid IHM.

VESSELS CAN NOW GET A 6 MONTH IHM EXTENSION - BUT WITH CONDITIONS

In MARHAZ we are glad that the European Commission(EC) has listened and reacted to industry´s concern about adhering strictly to the upcoming deadline on 31 December 2020 for EU SRR owing to the disruption caused by the Covid -19 pandemic. On 20 October 2020 the EC published guidelines on the harmonised enforcement of the EU SRR effectively granting the industry as 6 month extension on IHM-related obligations, e.i. to the 30 June 2021.

However, a shipowner/ ship master must provide evidence og the measures taken to complete the IHM work in due time of the original deadline and document that this was not possible. In MARHAZ we expect that a shipowner as a minimum will be required to have a signed contract with an IHM supplier and proof that an effort is undertaken to arrange for the IHM inspection and sampling activities in the coming months. In MARHAZ we are ready to work with you to accomplish this in the months to come, and we are ready to guarantee a paper trail that will provide you with transparent documentation and to complete your IHM report in due time.

All you need to do is to sign up with MARHAZ

THE INVENTORY OF HAZARDOUS MATERIALS - IHM

The IHM is the core document containing information on the presence of hazardous materials in a ship’s construction and equipment. An IHM is mandatory for existing ships flagged in Europe and all ships calling European ports from December 31st 2020.

The IHM provides the owner with information that may reduce the risk of crew and third parties being exposed to hazardous environments during maintenance and retrofitting. Ultimately, the IHM allows safe handling of hazardous materials at the ship’s end-of-life for the good of the environment and the people involved in the ship recycling process.

The IHM comprise information on a long range of hazardous materials, including asbestos, PCB, TBT, ozone depleting substances, heavy metals and flame retardants. Many of the hazardous materials and substances can lead to chronic and/or life-threatening diseases in humans.

The process

The IHM inspection itself rarely takes more than a day and can be arranged on short notice, reducing the entire process from your call to the report in your hands to as little as 15 working days. Under normal circumstances the IHM process runs over 4-6 weeks for a ship and comprise the following activities:

1. Ship operator activities

Delivery of ship documentation and other relevant information to MARHAZ

2. MARHAZ activities

- Development of Visual Sampling and Check plan
- On-board inspection and sampling
- Analysis of samples using an accredited laboratory
- Processing of laboratory and inspection data
- Compiling of IHM documents
- QA and delivery of documents to client

3. Ship operator activities

Submission of IHM documents to class

4. Classification society activities

- Desk top evaluation of IHM
- Class liaison with MARHAZ for questions/clarifications
- On-board validation
- Issuing of IHM Statement of Compliance

IHM Maintenance

It is mandatory to keep the IHM continuously updated during operation, maintenance and retrofitting. Any new piece of equipment or material covered under Part 1 of the IHM guidelines should be provided with Material Declaration(MD) and suppliers Declaration of Conformity for Material Declaration Management(SDoC).

The continuously work on keeping the IHM updated may be conducted by the ship owners, however, the work is a heavy administrative load to lift. To ease the process, an easy-to-use and cost-efficient IT platform has been developed by Verifavia Shipping, which with very little effort from the ship owners side, will ensure that your IHM is fully updated at all times.

MARHAZ represents Verifavia Shipping in Northern Europe. Please contact us here for a demo or more information.

IHM preparation for new ships - IHM, MD & SDoC

It is mandatory for all new ships flying the flag of an EU/EEA member state to have a Material Declaration(MD) and Suppliers Declaration of Conformity(SDoC) based IHM on board. This typically amounts to several thousand documents which have to assessed and structured.

The MD and SDoC contain information on whether hazardous materials, as listed in Annexes I and II of the EU SRR and/or Appendixes 1 and 2 of the HKC, are present in the specified products. These documents must be provided by the suppliers for all machinery, equipment, materials and coatings installed on board a vessel.

Verifavia Shipping has developed a system to handle this process with little effort for the ship builder, and/ or ship owner. MARHAZ represents Verifavia-Shipping in Northern Europe. Please contact us here for more information.

Asbestos management plan

Vessels which have had asbestos identified onboard should take adequate measures to manage the asbestos following the provisions in the SOLAS guidelines.

A core part of this work is to have an Asbestos mangement Plan(AMP) developed. The AMP will describe the actions required to maintain an asbestos safe environment onboard a ship with asbestos containing materials(ACM) present and under normal working situation prove asbestos safe.

MARHAZ can develop the needed asbestos management procedures to seamlessly integrate with your QMS system and conduct the risk assessment needed for the individual locations where asbestos is present.