IHM: HONG KONG CONVENTION AND EUSRR -OVERVIEW

IHM ( Inventory of  Hazardous Materials) has been a hot topic among the owners and managers , here we are looking into various aspect of preparing your vessel IHM compliant one. but since the convention (The Hong Kong International Convention for the safe and environmentally sound recycling of ships)  is not ratified till now do a vessel need to compliant of IHM.

       Here comes another important aspect called EUSRR, basically we will look into what is this regulations are all about.

Hong Kong Convention

The Hong Kong Convention recognised that ship recycling is the most environmentally sound way to dispose of a ship at the end of its life, as most of the ship's materials can be reused. However, it sees current methods as unacceptable. The work sees many injuries and fatalities to workers, as they lack the correct safety equipment to handle the large ship correctly as it is dismantled and most vessels contain a large amount of hazardous materials such as asbestos, PCBs, TBT, and CFCs, which can also lead to highly life-threatening diseases such as mesothelioma and lung cancer.

EUSRR (European Union Ship Recycling Regulation)

The European Parliament and the Council of the European Union adopted the Ship Recycling Regulation (EU SRR) on 20 November 2013. The objective of the Regulation is to reduce the negative impacts linked to the recycling of ships.

From 31 December 2018, EU-flagged commercial vessels above 500 GT must be recycled in safe and environmentally sound ship recycling facilities that are included on the European List of approved ship recycling facilities. The List was first established on 19 December 2016 and is periodically updated to add additional compliant facilities, or, alternatively, to remove facilities which have ceased to comply. The List comprises facilities operating globally.

Broad Overview on difference

·       Whilst the Regulation brings forward the requirements of the 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, it also includes additional safety and environmental requirements. Indeed, the EU SRR sets higher standards than the IMO’s Hong Kong Convention – the beaching method is not allowed and requirements related to downstream toxic waste management as well as labour rights are included. Moreover, EU­ listed ship recycling facilities are subject to a higher level of scrutiny: there is independent third party certification and auditing, and NGOs, are allowed to submit complaints should they have concerns that a listed facility is not operating in line with the Regulation. These are important safeguards that are alarmingly absent under the Hong Kong Convention regime. EU-listing is indeed the only guarantee that a yard has been independently certified and audited up against an acceptable standard. Almost all the materials inventory listed in both regulation is same except for PFOS (Per fluoro octane sulfonic acid)  Brominated Flame Retardant (HBCDD) 

Compliance time limit

HONG KONG INTERNATIONAL CONVENTION FOR THE SAFE AND ENVIRONMENTALLY SOUND RECYCLING OF SHIPS, 2009 (HONG KONG CONVENTION)

 This Convention shall enter into force 24 months after the date on which the following conditions are met:

.1  not less than 15 States have either signed it without reservation as to ratification, acceptance or approval, or have deposited the requisite instrument of ratification, acceptance, approval or accession in accordance with Article 16;

.2  the combined merchant fleets of the States mentioned in paragraph 1.1 constitute not less than 40 per cent of the gross tonnage of the world’s merchant shipping; and

.3  the combined maximum annual ship recycling volume of the States mentioned in paragraph 1.1 during the preceding 10 years constitutes not less than 3 per cent of the gross tonnage of the combined merchant shipping of the same States.

Number of Contracting States: 15

(the combined merchant fleets of which constitute approximately 30.21% of the

gross tonnage of the world’s merchant fleet. The combined annual ship recycling volume of the Contracting States during the preceding 10 years is 13,948,274.

(The above data is as on 07^th April 2020)

EUSRR

New European ships and EU-flagged ships going for dismantling must also have on board an inventory of hazardous materials (IHM) verified by the relevant administration or authority and specifying the location and approximate quantities of those materials. This obligation will also apply from 31 December 2020 to all existing ships sailing under the flag of Member States of the Union as well as to ships flying the flag of a third country and calling at an EU port or anchorage.

Here lies the importance of Inventory of Hazardous Material or commonly called IHM 

Let’s look into the procedure of developing an IHM for a vessel.

New Built Vessel

For new building ships, the ship yard is responsible for the IHM preparation. IHM preparation for new ships is based on documentation which is provided by the suppliers in the form of Material Declarations (MDs) and Suppliers Declaration of Conformity (SDOC).

Many shipyards already have experience of IHM preparation by collecting declarations from suppliers. Regardless of the scope of the IHM, whether HKC or EU SRR, the recommendation to shipyards is that; to instruct the suppliers to fill in and submit the EU SRR material declaration forms for their products, which cover 15 substances instead of 13 as per HKC. Since EU SRR covers the HKC requirements, if the owner orders the IHM as per EU SRR, this will save the effort to collect extra declarations for the two additional substances mentioned earlier.

Existing Vessel

For ships in operation, shipowner is responsible for the IHM preparation. To comply with the HKC and EU SRR for your fleet, please follow up below procedures:

a) IHM Part I preparation

The steps for IHM preparation are as follows:

·       To collect information about the ship;

·       To assess collected information

·       To prepare visual and sampling check plan (VSCP);

·       On board visual and sampling check,( some class requires their class surveyors attendance)

·       To send samples for laboratory analysis and preparation of IHM and IHM inspection report.

For EU SRR compliance for EU/EEA flagged vessels, PFOS must be investigated and HBCDD shall be investigated as far as practicable.

The whole process requires close cooperation of several parties and at best it would need one month until the IHM inspection report is finalized, therefore an early planning is highly recommended.

Once the IHM and IHM inspection report is ready, shipowner shall submit the IHM report to CLASSIFICATION SOCIETY for approval, and verification.

The IHM preparation shall be carried out by qualified HazMat experts and expert companies approved by CLASSIFICATION SOCIETY. Equivalent qualifications may be accepted upon agreement. 

b) IHM Part I certification

·       Plan approval engineers of Class  review and approve IHM and IHM inspection report;

·       After successful approval, ship owner shall apply for an IHM initial survey on board ship done by a Class surveyor;

·       After successful completion of the IHM initial survey, IHM certificate or statement of compliance will be issued by the surveyor with maximum 5 years validity in harmonization with the ship’s main class renewal date.

Therefore, shipowner should arrange above step a) first, and contact Class to prepare a proposal for IHM certification accordingly.

If a vessel Having HKC IHM certification does the vessel require separate EUSRR certification??

If the vessel is flagged under an EU/EEA Member State, an IHM certificate per EU SRR is required.

If the vessel is flagged under a third county, but visiting EU/EEA ports or anchorages, the vessel would need an EU SRR IHM Statement of Compliance (SoC)by some class like DNV GL or ABS . But as per Class NK HKC IHM SOC is good enough for EU SRR.

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How to maintain the IHM will Discuss in the next Blog.