Main points of EU IHM inspection and maintenance

reference: https://www.xindemarinenews.com/data/haishifagui/2020/0921/23727.htm

Recently, the Singapore branch of the China Classification Society has accepted the Inventory of Hazardous Materials (IHM) inspections for hundreds of ships. The technical provisions of the EU SRR Convention have attracted much attention from the industry.

After December 31, 2020, the EU SRR requires all ships calling at ports or anchorages of EU member states to carry a list of hazardous substances and certificates that meet the requirements.

Considering that most of the ships currently applying for IHM inspection are non-EU-flag existing ships, in order to facilitate the industry to understand EU SRR, the relevant IHM inspection and maintenance points are now summarized for industry reference.

This article applies to existing non-EU flag ships that intend to sail in EU waters after December 31, 2020.

1 The difference between Hong Kong Convention and EU SRR

For existing ships with non-EU flags, apart from HBCDD, there is no essential difference in technical terms between the Hong Kong Convention and EU SRR. For details, please refer to CCS circulars and technical notices.

2 About the treatment of HBCDD

For non-EU flag existing ships, HBCDD does not need to be identified when applying for initial inspection. However, after the initial inspection, HBCDD should be tracked and maintained for newly installed equipment on board, that is, when collecting MD/SDoC of newly installed equipment, the format and version covering HBCDD should be adopted.

As shown in Figure 1, EMAS has clarified the above issues in its IHM-related guidelines.

Figure 1 EMSA's description of the applicability of HBCDD

(Source: EMSA Guidance inspections ship recycling)

3 Hold a valid Hong Kong Convention compliance statement

For ships holding a valid Hong Kong Convention IHM list and a declaration of compliance, on the premise that there is no new equipment on the ship, in principle, IHM (EU) can be issued directly, but the shipowner should be reminded of the relevant risks (such as the EU flag, which may face Traceability issues for PFOS and HBCDD).

If new or replacement equipment is installed on the ship, such as newly installed desulfurization tower and ballast water treatment equipment, MD/SDoC should be collected in accordance with EU SRR requirements.

4 Circumstances that do not hold the Hong Kong Convention compliance statement

For those who do not hold the Hong Kong Convention compliance statement, the management company can operate according to the following procedures.

Figure 2 IHM inspection process diagram

The relevant inspection points are summarized as follows:

● The shipowner should provide IHM List Part I, VSCP and related supporting materials, including MD/SDoC, etc.;

● VSCP and IHM list should be prepared by people with sufficient professional knowledge (approved supplier staff);

● VSCP and IHM List Part I are generally compiled and provided by third-party professional organizations;

● For the preparation and approval of VSCP, please refer to the CCS Guidelines or MEPC.269(68). The sampling location should cover as much as possible the requirements of "The Distribution of Common Hazardous Substances on Ships in Annex 5 of Guidelines for the Compilation and Inspection of Ship Hazardous Substances Inventory" . For example: asbestos in gaskets and insulating materials, asbestos in ceramic tiles (asbestos was found in ceramic tiles during the PSC inspection in the Netherlands);

● For the preparation and approval requirements of IHM Part I, please refer to the CCS Guidelines or MEPC.269(68);

● During boarding verification, you should check the location and quantity of IHM (consistent with IHM Part I), and the equipment is not missing. At the same time, for suspicious hazardous materials, IHM Part I should note "Potentially containing hazardous materials" (PCHM); at the same time, it should be noted that any item classified as "unknown" can be classified as "PCHM" , The premise is that there are sufficient reasonable reasons, or it can be assumed that there is almost no impact on the disassembly of the device and the subsequent shipbreaking disposal operations.

5 Treatment methods for hazardous substances detected on board

(1) When asbestos is detected (such as exceeding the threshold of 0.1%), it should be handled as follows.

Table 1. SOLAS amendment requirements regarding asbestos

If asbestos is found during the inspection, but there is not enough time to remove it in time, please refer to IMOMSC.1/Circ.1374/Article 13 for handling.

IMO MSC.1/Circ.1374, Article 13 requires the following:

"When asbestos is found on a ship, if it does not meet the requirements of SOLAS Regulation II-1/3-5, measures should be taken to remove it. The asbestos removal should be assigned to a professional company within three years from the date of discovery, and the ship’s flag States in close consultations, and when necessary, will be conducted under the supervision of the relevant flag state. In this case, the flag state should issue an exemption certificate."

If asbestos is detected on the ship, it may affect the validity of the ship's construction safety certificate. The shipowner should notify the flag state as soon as possible. Generally speaking, the flag state will issue a certificate of exemption according to the requirements of MSC/Circ.1045, and give the owner a timetable for asbestos removal.

Note: The above discussion refers to cases where the asbestos threshold is exceeded. For the judgment of asbestos threshold, refer to the CCS Guidelines.

(2) Disposal of other hazardous materials

The treatment of other hazardous substances is logically the same as the treatment method of asbestos, but the specific requirements under different convention systems are different, and attention should be paid to distinguish them one by one. First, determine whether the content exceeds the threshold and whether it meets the requirements of the Hong Kong Convention and EU SRR. Generally speaking, both the Hong Kong Convention and EU SRR apply to newly installed equipment. If it is not a newly installed device, it generally does not need to be dismantled, it only needs to be recorded in the IHM. Nevertheless, it is still necessary to cautiously judge whether the hazardous substance complies with the corresponding regulatory requirements, such as HCFC and TBT. If there is not enough time to dismantle, when it comes to the compliance of the convention, it should apply to the flag-hanging country for exemption.

6 Other IHM inspection precautions are reminded as follows:

• Pay attention to verifying the qualifications of the sampling and testing company, and the sampling and testing personnel should have training certificates;

• Asbestos sampling should be focused on: gaskets, tiles, insulation and fillers;

• The ozone-depleting substances (ODS) can be confirmed according to the drawings or IAPP certificate, and visual inspection on board is enough. During the sampling test, pay attention to the inspection of the insulation materials of the cold storage;

• TBT, generally can be determined according to the AFS certificate, if there is no certificate, it should be determined by sampling, pay special attention to the situation that contains TBT in the enclosure, which should be indicated in IHM Part I;

• It is generally difficult to sample radioactive materials. Visual inspection is sufficient, such as lightning rods on ships. The original manufacturer’s materials can be verified to confirm the information of hazardous materials, and it is not limited to MD;

• It is recommended that the shipping company establish an IHM related management system, track the new installation or replacement of equipment in time, collect MD/SDoC in time, and maintain IHM. If necessary, notify the classification society to develop additional suggestions and update IHM Part I;

• If the initial survey and final survey are carried out together, only the International Ship Recycling Certificate needs to be issued.