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Last Call for IHM Compliance – (Inventory of Hazardous Materials)

JMS Yachting Fleet Manager, Rob Pijper asks, whether you have submitted the Inventory of Hazardous Materials list to your Classification Society?

If you are reading this and have never heard of Inventory of Hazardous Materials (IHM) and your yacht is over 500GT and commercial; you are very late and perhaps even too late. IHM compliance will take some time achieve and the regulations are coming into force on 31 December 2020.

Everyone has seen the big ships being scrapped on the beaches in India, an environmental disaster happening before our eyes. The EU and IMO regulations are designed to prevent this in the future.

The Inventory of Hazardous Materials is a ship (yacht) specific list of hazardous materials to protect the health and safety, and the environment at ship recycling facilities. Funnily enough the IMO International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the so-called “Hong Kong” Convention) – is not yet into force. As always IMO resolutions take ages because the prerequisite minimum number of signatory Member States and tonnage percentage needs to be reached. However the EU regulation (*1) is in force.

It says that:

1. By 31 December 2020, existing EU-flagged vessels will need to maintain a certified Inventory of Hazardous Materials (IHM) list on board (i.e. the list and an accompanying Certificate issued by the yacht’s Classification Society or Flag State)

2. By 31 December 2020, existing non-EU flagged vessels calling at a port or anchorage of a EU member state must have on board the IHM list and a valid Statement of Compliance (issued by the yacht’s Classification Society or Flag State).

3. New EU-flagged vessels (built after 31 December 2018) need an IHM and Certificate issued by the yacht’s Classification Society or Flag State upon entry into service.

As soon as the Hong Kong Convention will enter into force, all Statements of Compliance issued for non-EU-flagged vessels will have to be converted into Certificates issued by Class or Flag State. While the EU and IMO are mostly aligned, there are slight differences between the EU and IMO requirements for the Inventory of Hazardous Materials.

So what needs to be done?
An expert needs to be appointed by the vessel in order to compile the IHM list. (2*) The final IHM list as issued by the expert will have to be submitted to the Classification Society. The Classification Society will review the provided documentation and, once approved, a Class Surveyor will attend the vessel in order to verify the approved list and issue the required Certificate (EU flagged vessels) or Statement (non EU flagged vessels).

“Obtaining certification will likely be a matter of weeks if not months”

So far this is the work of the expert. However, in order to maintain compliance, the crew on board needs do the maintenance on the IHM. Every compliant yacht should formally designate a person on board responsible for maintaining and updating the inventory. If any items recorded in the IHM are added to, removed or replaced, or the hull coating is renewed, the IHM should be updated using information obtained from Material Declarations (MD) and Supplier Declarations of Conformity (SDoC) forms. The requirement for MD and SDoC forms should therefore be included in the yacht’s internal procurement policy at the time of the initial IHM compilation. These MD and SDoC must be collected for every item brought on board the yacht. The work will be audited during surveys and the sale of the yacht.

As you can imagine, the implementation process will take time. Obtaining certification will likely be a matter of weeks if not months.

Furthermore, now the deadline is approaching, Experts and Class approval will become increasingly unavailable.

1* The EU Regulation No. 1257/2013 on Ship Recycling (EU SRR) – entered into force in 2013.
2* A complete list of experts is available on the LR website, Approvals (at the bottom of the page) and then indicating “Visual/sampling checks and testing for hazardous materials” in the search tab.

If you are interested in learning more about certification
for the Inventory of Hazardous Materials or any other compliance issues, please complete the form below

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