Assisting early compliance with the Ship Recycling Convention
What is required from manufacturers and suppliers?
Suppliers to the shipbuilding industry should identify and declare whether or not the materials listed in Table A and B of MEPC.269(68), appendix 1, are above the threshold levels by completing a ‘Supplier’s Declaration of Conformity’ and a ‘Material Declaration’ form.
The presence of materials listed in Table A of MEPC.269(68), appendix 1, should be checked and confirmed; the shipyard / shipowner should list the quantity and location of these materials in Part I of the IHM.
If materials listed in Table B of MEPC.269(68), appendix 1, are present in products above the threshold levels the shipyard / shipowner should list the quantity and location of the products and the contents of the materials present in them in Part I of the IHM.
This list is relatively simple as any vessel having equipment installed after January 1, 2011 must be free of asbestos, free of PCBs since roughly the mid-1990s, free of ODS no later than 2004 (depending on the country / various extensions) and free of TBTs since approximately 2009.
Therefore, to comply with various IMO Conventions a supplier should be contractually obliged by the shipyard or shipowner to ensure that these materials are not in the item(s) supplied.
These items are not excluded, but, for new ships when the Convention enters into force, must be listed in all homogenous materials if present in amounts above the given threshold level. The same will apply to new installation of machinery or equipment onboard existing ships.
Materials listed in Table B that are inherent in solid metals or metal alloys, provided they are used in general construction (such as hull, superstructure, pipes, or housings for equipment and machinery) are not required to be listed in the IHM.
Material Declaration (MD)
Suppliers to the shipbuilding industry should identify and declare whether or not the materials listed in Table A or Table B are present above the threshold level. This provision does not apply to chemicals which do not constitute a part of the finished product.
Supplier’s Declaration of Conformity (SDOC)
The purpose of the Supplier’s Declaration of Conformity is to provide assurance that the related Material Declaration is in compliance with requirements, and to identify the responsible entity.
The above information should be viewed as a summary only. Please refer to MEPC.269(68) – Guidelines for the Development of the Inventory of Hazardous Materials – for full requirements and recommendations on developing the IHM.