To meet the EU Ship Recycling Regulations, shipowners shall implement procedures for maintenance of IHM throughout the operational life of their vessels. However, DNV has received many questions with regards to IHM renewal surveys and how to ensure maintenance. This technical news aims to clarify what needs to be done to maintain the IHM system.
According to the EU Ship Recycling Regulation (EU SRR), ships above 500 GT flying the flag of a country within the EU, EEA or UK, or third-party-flagged vessels calling at European ports or anchorages, must carry on board an IHM (Inventory Hazardous Materials) certificate or Statement of Compliance, supplemented with Part I of the IHM.
The EU SRR states that IHM surveys should be harmonized with other statutory certificates, and some flag states have issued circulars for such a harmonization requirement. The deadline for the application of the EU SRR was the end of 2020, and most vessels’ initial IHM surveys were conducted in 2019/2020.
Lately, we are seeing more and more IHM renewal surveys due together with the main class renewals, and the number of support cases has increased with questions about IHM renewal surveys and IHM maintenance requirements. Below explains what needs to be done to properly maintain the IHMs and to ensure smooth port state control (PSC) inspections and IHM renewal surveys:
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1. IHM maintenance procedure
Firstly, shipowners must establish an IHM maintenance procedure/manual, which is integrated into the shipowner’s safety management system. In parallel, shipowners must appoint a person responsible for IHM maintenance, named an IHM Designated Person(s) (IHM DP). Based on the IHM maintenance procedure, the IHM DP shall review all purchases made for each vessel within a period as defined in the IHM maintenance procedure. This review period can be monthly, bi-monthly or quarterly, which should be defined by the shipowner and identified in the IHM maintenance procedure. For purchased products which fall into the scope of IHM Part I, Material Declaration (MD) and Supplier Declaration of Conformity (SDoC) forms must be collected from the suppliers.
Even if there are no hazardous materials in a product, MD/ SDoC forms must still be collected as they are the shipowner’s evidence that the product is free of hazardous materials. The IHM Part I shall list all machinery, equipment, materials and coatings on board which are installed as fixed items. Therefore, collection of an MD/SDoC is needed for those products. For the details on the scope of IHM Part I, please refer to our topic page for IHM and ship recycling (see link under “References”). If a hazardous material is declared above the specified threshold values in a product, the IHM DP shall update the IHM and issue a new revision with date and revision number. The IHM DP should record the conducted activities in a change log.
2. IHM renewal surveys
During the IHM renewal survey, the surveyor will verify that:
- A vessel-specific, maintained and updated IHM Part I is provided on board together with a valid compliance declaration.
- The procedure for maintaining the IHM Part I is on board and integrated into the safety management system.
- The IHM Part I is consistent with the arrangement, structure and equipment of the vessel.
To do this, the surveyor has to examine the previous version of the IHM Part I and compare it with the updated IHM Part I, supplemented by the new MD and SDoC. If an item of equipment that contains a hazardous material is removed from the vessel, it must be ensured that it is removed from the IHM Part I as well. It should be noted that when the term “on board” is used, this means that having digital solutions in place is also acceptable. Therefore, during an inspection or survey, the Master can show the versions of the IHM and MD/SDoCs digitally from the computer. As the IHM maintenance procedures require the collection of many MD/SDoC documents, we strongly recommend using software solutions such as DNV’s IHM Manager software for data management, which enables users to keep a fully digital record of the IHM of the vessels in their fleet. The IHM Manager software solution is available on DNV’s Veracity marketplace.
3. PSC inspections
PSC inspections are limited to verify that there is a valid IHM compliance declaration on board, which shall be considered sufficient for approval of the inspection. A detailed inspection may be carried out if a vessel doesn’t carry a valid compliance declaration or if there are clear grounds for the PSC officer to believe that
- The condition of the ship or its equipment does not correspond substantially with the particulars of that certificate/SoC and/or IHM Part I.
- There is no IHM maintenance procedure implemented.
Not having a valid IHM certificate/SoC may be a reason for detention. However, failure to update the IHM is not a detainable deficiency. Such inconsistencies shall be rectified at the time of the next survey.