Convention Definitions
Accredited laboratory is a laboratory accredited in accordance with ISO 17025 or an equivalent standard for the purpose of conducting specific tests for hazardous materials included in the Hong Kong Convention including additional materials required under the EU SRR and capable of providing a written report that can be relied upon by all parties.
Hazardous Material means any material or substance which is liable to create hazards to human health and/or the environment.
Hazardous Material survey is an investigation to trace and identify the presence or absence of Hazardous Materials contained in the equipment, systems, and/or areas on board a ship and may include a review of any relevant documents, visual inspections and sampling. IHM process is the whole process of development and maintenance of an IHM throughout the operational life- cycle of the ship. It involves all the steps of developing an IHM including issuing/checking of any relevant documentation (e.g. Material Declarations), sampling and analysis, verification and life-cycle management.
Individual IHM Expert is a person who has the appropriate training, qualifications and knowledge to conduct hazardous material surveys for the development and maintenance of an IHM. He or she should have experience on ship structure and on handling of HM and sufficient knowledge of how to compile an IHM and of all the relevant international legislation.
IHM Expert Company is an entity employing or contracting individual IHM experts to conduct any relevant work or task in relation to the IHM process for the purpose of compiling or updating Inventories of Hazardous Materials. The IHM expert company should use a documented management system and should work on suitable standards, covering the relevant activities of the company.
Sampling check is the taking of samples to identify the presence or absence of HM contained in the equipment, systems, and/or areas on board a ship, by suitable and generally accepted methods such as laboratory analysis.
Operational
Guidance The IHM consists of:
Part I: Hazardous materials contained in ship structure or equipment, their location and approximate quantities and referred to in Appendices 1 and 2 of the Hong Kong Convention and clarify that the ship complies with the controls of ships hazardous materials:
Prior to recycling - Part II: Operationally generated wastes;
and Part III: Stores.
In general, the guidelines in Resolution MEPC.269(68) provide sufficient information for the development of the IHM in relation to the hazardous material included in Appendices 1 and 2 of the Hong Kong Convention as well as an indicative list of these hazardous materials with CAS numbers and respective specific test methods. Therefore, for information on the hazardous materials included in appendices 1 and 2 of the Hong Kong Convention and in annexes 1 and 2 of the EU SRR, reference should be made to the IMO guidelines.
Part I of the IHM shall remain with a vessel throughout its operational life and be updated as all new installations enter the ship, as these may potentially contain hazards. The presence of the inventory will then ensure the safety of crewmembers during the vessel’s operational life, and the safety of workers during the recycling process.
The shipowner is responsible for developing Part I of the IHM and should draw upon expert assistance. This is strongly recommended for safety and health protection reasons and in order to have a minimum assurance that the work is carried out by competent personnel, under a quality management system and in accordance with IMO guidelines in Resolution MEPC.269(68). However, such IHM Expert Company should not be the same as the Recognized Organization authorized by the Flag Administration to approve the IHM. The development and maintenance of the IHM should be subject to the principles of independence, quality and accountability.
The following procedure should be followed for the determination of Part I of the IHM:
- Collection of the necessary information - Assessment of collected information - Preparation of Visual/Sampling Check Plan (VSCP); - Onboard Visual/Sampling Check; and - Preparation of Part I of the IHM and related documentation
- Maintaining and updating Part I of the IHM during operations
The Hong Kong Convention requires that the shipowner maintain the IHM throughout the operational life of the ship.
If any machinery or equipment is added, removed or replaced or the hull coating is renewed, Part I of the IHM should be updated. Updating is not required if identical parts or coatings are installed or applied.
72 | ISSUE 106 | DEC 2023 | THE REPORT
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