According to regulation (EU) 1257/2013 of the European Parliament and the Council on Ship Recycling (hereinafter referred to as “EUSRR”), Part I of the IHM should be properly maintained and updated throughout the operational life of a ship. It should reflect new installations containing any hazardous materials that has been referred to in Annex II of the regulation, and relevant changes in the structure and equipment of the ship.
Therefore, shipowners should establish the necessary procedures on-board the ship and within their companies to fulfil their long-term environmental responsibilities.
The IHM must be properly maintained and updated throughout the operational life of the ship and it will supplement any Inventory Certificate or Statement of Compliance issued by a member state, third country, RO or any authorized organization.
The shipowner is responsible in maintaining Part I of the IHM over the lifetime of the ship. Part I of the IHM should belong to the ship and the continuity and conformity of the information it contains should be confirmed. This is especially important if the flag, owner or operator of the ship changes. Shipowners should designate a person who would be responsible for maintaining and updating the inventory. This person should manage the IHM inventory in accordance with the IMO guidelines. The duties of the designated person should be incorporated into the shipowner’s quality management system. The lifetime quality management system should include specific provisions to safeguard the quality and continuity of the IHM during the building, buying or selling of a ship. This would also come in handy when changing the ship’s registry or designated personnel and would secure shipowners a credible document when the decision to recycle a ship is made. The quality management system should highlight the procedures implemented to ensure the proper updating of the IHM during scheduled or unscheduled works involving changes, replacements or repairs to the structure, equipment, systems, fittings, arrangements or material, as this may have an impact on the inventory. The proper maintenance of an archive of all the associated documentations should also be included in the lifetime quality management system and should ensure that new installations of equipment, repairs, and refitting’s are accompanied by a MD and a SDoC, which are to be provided by the suppliers of the parts and equipment delivered. As part of the lifetime quality management system, shipowners may include a random sampling policy for new or existing ships and there should be assurances that the IHM development and maintenance shall be undertaken by competent entities (i.e., IHM experts) in accordance with recommended guidance (i.e., the EMSA’s best practice guidance document and the relevant IMO guidelines). A software tool may be used to support the IHM upkeeping process and the management of all the relevant documents, information and data.
|Vessel Account Set Up
Upload initial IHM Part I
|Secure cloud platform with easy access of well documented & filed IHM Maintenance records.|
|Check Purchase Order Line items
Identify PO line items presumed to contain hazmat
|Hazmat team with years of experience
Extensive hazmat items library from IHM project experience
|Follow up with Suppliers for MD & SDoC||Regular follow-up and reminders to Suppliers
Awareness support to assist Suppliers
|Review MD & SDoC
Identify or Clear PO line items for hazmat presence
|Reference to In-house MD,SDoC database if suppliers unable to provide In-house lab testing option if MD,SDoC unavailable|
|Quarterly Updates on IHM Maintenance works||Listing of PO line items confirmed to contain hazmat
Details of PO line items pending for MD,SDoC
|Update IHM Part I
( Based on Client notification of fitment on-board of PO line items with Hazmat)
|Annual IHM Maintenance report as support document
Free Lab testing & reporting for Asbestos upto 20 samples per year
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