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Monday, February 3, 2020 

Compliance with mounting environmental and safety legislation is the new normal for shipping. While attention has rightly focused on the much-anticipated 1 January 2020 global sulphur cap, at the end of this year, a lesser understood regulation will come into force.

By 31 December 2020, all ships over 500gt and above entering a European Union port or anchorage will require a valid and certificated Inventory of Hazardous Materials (IHM) on board, alongside a Certificate of Compliance (if EU flagged) or Statement of Compliance (if non-EU flagged) according to the requirements of the 2013 EU Ship Recycling Regulation (EU SRR).

Both the Hong Kong International Convention and the EU SRR aim to regulate the ship-recycling industry to ensure that end-of-life vessels are dismantled safely, minimising the impact to human health and the environment.

The EU SRR prohibits or restricts the installation and use of hazardous materials - like asbestos or ozone-depleting substances - on board ships, as well as making it mandatory for ships to carry on board a certified IHM specifying the location and approximate quantities of those materials.

There is an increasing acceptance of the importance of this legislation, in terms of both environmental protection and improving the often-appalling health and safety standards endured by workers at recycling facilities, particularly in South Asia where 90% of the world’s vessels are scrapped.

The IHM provides ship-specific information on the actual hazardous materials present on board in order to protect health and safety for workers and to prevent environmental pollution at ship-recycling facilities. The purpose of IHM is not just to have a document onboard, but at the end of the vessel’s life, the ship recycler has this document and understands that before touching a particular segment of the vessel, precautions should be taken before handling those hazardous materials. This is why it is so essential that surveys are carried out independently and to the highest standards.

Covering fifteen substances, the IHM is aimed at controlling and documenting hazardous materials on board ships and requires expert knowledge to compile. Based in Europe, Chandigarh, Singapore, Panama, the US, Australia, Hong Kong and China, Verifavia employs a team of qualified hazmat experts who prepare a Visual Ship Check Plan (VSCP) before being dispatched onboard the vessel to take samples of potentially hazardous materials.

Working across the globe to ensure availability at short notice, the majority of these hazmat experts are former seafarers. This ensures they have clear procedural understanding, enabling them to adapt to the ship’s schedule. A fundamental understanding of vessel operations, coupled with extensive training and mentoring, enables Verifavia to ensure quality and consistency worldwide.

Once the samples have been taken, they are then submitted to an independent accredited laboratory for analysis, and the results are developed into a report that is shared with a class society for final onboard cross-checking and certification. Verifavia is an approved IHM supplier for DNV GL, Lloyds Register, IRS, ABS, the Korean Register, and RINA, which also makes the process as simple as possible for vessel owners and managers.

This thorough process enables identification of any hazardous material that needs to be removed and the location of these materials, with the purpose of preparing the ship for recycling. This ensures a safe workplace for ship recycling yard employees and any dangerous substances on a ship, such as asbestos, mercury, lead-containing paints or polychlorinated biphenyls (PCBs) can be removed in a safe and environmentally sound process.

If vessels are found to contain certain hazardous materials, which measure above the determined threshold, they must be removed, although ultimately this decision rests with the vessel’s flag state. For example, if asbestos is found, SOLAS regulations dictate that it must be removed within three years during a drydock, and this can only be carried out by a specialist asbestos removal company.

From 31 December 2020, in the EU, for new and existing EU Flag Ships and non-EU Flag vessels, port state control officers will enquire about the existence, approval, correctness and maintenance of the IHM Certificate and related documentation. It is essential that vessels are prepared ahead of this deadline. As a new legislation deadline, it is likely to be front of mind.

Without an accurate and up to date IHM, vessels may encounter delays to voyages, and safety issues when modifying vessels with new technology and equipment. Throughout the operational life of a vessel, it is essential for the IHM to be maintained. This means that if any new or different machinery or equipment is added to, removed or replaced, the IHM must be updated by collection of suppliers’ declarations. To support owners and operators, Verifavia Shipping, offers a digital solution to ensure the IHM is constantly up to date, as well as facilitating the renewal survey after five years.

Throughout the entire IHM process, independence is key. This will enhance the credibility of the IHM as the independent laboratories ensure impartial results, and this prevents conflicts of interest between the entity (individual, company or organisation) developing or updating the IHM, and those verifying the IHM on behalf of the flag state. Professional and progressive shipowners, operators and managers are increasingly recognising the potential conflict of interest if the company taking the samples is also testing those samples in its own laboratories.

The deadline for acquiring a certified IHM for all ships is approaching fast. The key benefit of outsourcing the IHM process is that ship owners and operators need not worry about the specifics of the IHM requirements as the surveying company and certifying body (class society) guide them carefully through the process.

The industry’s commitment to safe and environmentally sound practices is coming under increasing scrutiny. While the industry has yet another regulation to contend with, finding the right IHM supplier will ensure that shipowners have complete piece of mind when it comes to safeguarding not only the environment, but also its people.

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