Lead Specialist for Governmental Affairs
The end of year deadline for compliance is hardly breaking news – regulations have been around since 2009, with the formal adoption of the IMO Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships (HKC). But it’s only in recent years, with the phased entry of the 2013 EU SRR, that shipowners have really started engaging with the task of IHM compilation en-masse.
With many well on the way to compiling their IHM’s to gain certification ahead of the deadline, the focus is shifting to how best to implement ongoing maintenance. These are, afterall, documents that stay with ships throughout their operational lifetime. So it’s important to keep them up-to-date. Not only to ensure compliance but because a comprehensively compiled document minimises risks and potential liabilities, and does much to enhance the safety of ships’ crews in the longer term.
With so much else to occupy minds (and resources) in marine, keeping this maintenance process simple is essential. Staying consistent – by using the same user-friendly IHM template across your fleet – is a great starting point.
Here, LR can help by providing a standard, editable PDF that can be updated as many times as needed and easily stored/transferred due to its small file size. This takes care of the need to quickly update the IHM if any items onboard (which are, or could be, part of the ship’s structure or fitted equipment), are added, removed or replaced.
These updates should be based on information from a completed Material Declaration (MD) and Supplier Declaration of Conformity (SDoC), requested from the supplier. To streamline this process, LR also offers carefully designed templates for these documents as part of our service - ensuring a simple and consistent approach for you and your suppliers.
It is also worth noting that the request for your suppliers to complete an MD and SDoC should be included specifically in your procurement policies.
A procurement policy should ideally:
- Request any items supplied to the ship are accompanied by a completed MD and SDoC as per Resolution MEPC. 269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials and the EMSA best practice guidance.
- Make explicit reference to:
- Resolution MEPC.269(68) – 2015 Guidelines for the Development of the Inventory of Hazardous Materials to cover HKC.
- Regulation (EU) no 1257/2013 if inclusion of EU SRR hazards is required.
- The policy should preferably cover the hazards listed in both Appendix I and II of HKC and Annex I and II of EU SRR.
Note: a blanket statement included generically in your procurement policy stating that hazards must be restricted is not likely to be enough to meet IMO and EU requirements for IHM ongoing maintenance.
Of course, while implementation depends on the systems already in place for managing paperwork onboard vessels, our best practice advice is to integrate your new IHM maintenance process into Safety Management Systems by:
- Designating a person responsible for maintaining and updating the Inventory (this person may be employed ashore or on board).
- Ensuring the designated person has appropriate training, qualifications, knowledge and experience to perform their respective duties.
- Ensuring the designated person establishes and supervises a system to ensure the necessary updating of the Inventory in the event of new installation for any hazards present above the defined threshold values, and maintains the Inventory including dates of changes or new deleted entries based on information provided in the supplied MD and SDoC.
Material Declarations and Supplier Declarations of Conformity:
- MDs and SDoCs are required to be collected for all items brought onboard the ship that will or could be part of the ships structure and fitted equipment – even if they contain no hazardous materials. The IHM is all about building up a chain of positive and negative statements about what is onboard your ship, to facilitate safe and environmentally sound recycling at the end of operational life.
- Unique MD and SDoC should be requested for each individual equipment type brought onboard the ship.
- Multiple units of the same piece of equipment can be covered under a single MD and SDoC.
With IHM maintenance truly mission critical, and consistency the simplest way to make it happen, taking advantage of best practices and using the best available tools really will have a positive impact. Ensuring conformity with the legislative requirements becomes a swift and straightforward task, and helps ensure a smoother process when certification is renewed every 5 years.
For more details on the issues discussed here, and to see how we can continue to support your ongoing maintenance through our optional annual survey service, contact your local office today.
Published 28 April 2020.