Inventory of Hazardous Materials: Regulations and Best Practices

INVENTORY OF
HAZARDOUS
MATERIALS:
REGULATIONS AND
BEST PRACTICES
30-Sept-2020
IHM- REGULATION
Inventory of Hazardous Materials (IHM)

 Purpose of IHM
 Regulate waste management at recycling phase of vessel
 Prevent exposure to Hazardous Materials for crew and recycling yard workers
 2 different types of IHM:

 New build vessels
 Existing vessels  biggest impact for Ship owners
 2 “different” types of Regulations/Guidelines

 Hong Kong Convention (adopted in 2009), to be ratified yet
 EU Regulation (entered into force in 2013) with deadlines set
© Copyright MSC Mediterranean Shipping Company S.A. 2

IHM- REGULATION
Inventory of Hazardous Materials (IHM)

 Different deadlines set:
 Newbuild vessels 30-12-2018
 Existing vessels  30-12-2020

 IHM (EU Regulation) requirements valid for:
 All EU flagged vessels,
 All third party vessels doing EU port calls and
 All third party vessels dropping anchor at EU anchorages

 Failing to obtain a valid IHM report after the deadline could result in
penalties and bans of entering EU ports!

IHM- REGULATION
Extend of IHM – new build vessels

 Starts at developing stage of construction
 Collecting Material Declarations (MD) from suppliers
 Collecting Supplier Documents of Compliance (SDoC)
 Class involvement required to verify IHM survey report
 Class (or Flag State) will issue “Statement of Compliance”
 Responsibility of shipyard
 To be updated every 5 year

IHM- REGULATION
Extend of IHM – existing vessels

 Should be done immdiately if vessel does not have IHM part 1 inventory
 Desk research existing vessel data
 Survey on board to take samples
 Class involvement required to verify IHM survey
 Class (or Flag State) will issue “Statement of Compliance”
 Responsibility of owner
 To be updated every 5 year

IHM- REGULATION
IHM Survey details

 Split up into 3 different parts (I and II/III)
 Only Part I is required to comply to EU Regulations (Table A/B)
 Part II and III required at recycling phase of vessel (Table B, C and D)
 Substances to be surveyed for Part I

 Asbestos (ACM)
 Polychlorinated Byphenyls (PCB)
 Ozone Depleting Substances (ODS)

 Antifouling (TBT)
 Additional for EU Regulation: PFOS and HBCDD (flame retardants)

(Perfluorooctane sulfonic acid & Brominated Flame Retardant)

HAZARDOUS AND POTENTIALLY HAZARDOUS
MATERIALS
• Asbestos
• Paint
• Plastic and Rubber materials
• Materials containing PCBs, PCTs, PBBb
• Refrigerants, fire-fighting media, blowing agents and other gases
• Chemicals in ship’s equipment/ machinery
• Electrical & electronic equipment
• Constructional materials

IHM- REGULATION
IHM Part I Survey details

 Visual/Sampling Check Plan (VSCP) as guiding document
 Based on vessel information available
 Witnessing by Class (not mandatory for all surveys)
 Both VSCP and on board
 If no data available  verification via sampling required!

IHM SAMPLES EXAMPLES
ACM Sample Gasket PCB Sample door frame
ACM Sample Brake Lining
ACM Sample Putty PFOS Sample Aluminimum paint
9
IHM- OVERVIEW
• IHM surveys as per HK & EU requirement completed for all fleet vessels.
• New Building vessels (9000TEU class) IHM survey performed as per EU
requirement since during delivery only HK requirement was met
• For new takeover – second hand vessels IHM surveys is completed
immediately on takeover
• Important first steps have been in taken for the asbestos management.
• Asbestos safety kit supplied to all vessels and will be delivered to all new
takeover vessels immediately on takeover.

IHM- OVERVIEW
• Material Declarations and statement of compliance from Vendors for IHM

compliance
• Removal of lose asbestos and cleaning after IHM part 1 surveys on existing
vessels in progress and prioritized basis quantity and risk involved.
• For existing vessels new statement of compliance are issued from RINA
basis IHM surveys and all our vessels are now in full compliance with EU
requirement in force from 31st Dec 2020. All NB vessels are already in
compliance since delivery from NB yards.

IHM MAINTENANCE

• IHM maintenance is important part of this regulations and for this it is
essential that all supplies to our ships are monitored for hazardous
material. The IHM inventory will be updated accordingly.
• All suppliers are required to sign material declaration and confirmation for
document of compliance so that this is being done at the source.
• Non-compliance if any should be promptly reported to office and liability is
placed on the supplier.

IHM- MAINTENANCE
• It is company policy that all materials including gaskets as delivered on-

board are asbestos free and clause has been added in our purchase orders
accordingly.
• This is also part of our agreement with various shipyards and all major
vendors are audited to confirm same.
• Material declaration and suppliers declaration of conformity for material
declaration management will be signed by each of the vendor ensuring
data of material delivered on board is recorded.

IHM- MAINTENANCE
IHM survey of all main vendors was performed to eliminate any possibility
of delivery of asbestos based product to our vessels
• IHM survey was carried out for EDR and MSC Global facilities in Sept -18.
Observations were dealt with.
• IHM survey of MSC Tech Durban facilities in Dec 2018 and observations
were dealt with.
• Repeat IHM survey on vessels where new scrubber and BWTS was
installed, one ship from each of the shipyards involved in the project.

IHM – ASBESTOS SAFETY KIT
Safety Kit-
• In order to improve the safety onboard while dealing with potential
asbestos containing gaskets vessels are being provided with an Asbestos
Safety Kit.
• This kit is arranged from vendor Kiwa Oesterbaai who is also performing
IHM surveys on board all MSC vessels.
• The kit will be stored in safety locker under custody of C/O and used for
the purpose it is provided.
• Second engineer is appointed as the designated person for asbestos
related issues with the supplies to vessel if any.
Content of the safety kit are detailed as follows

• HEPA filter equipped vacuum cleaner
• 10 spare dust bags for vacuum cleaner
• Semi full face masks with P3 Filter
• Tyvec disposable coveralls (size XXL)
• Blue disposable shoe covers
• Asbestos waste bags with printed warning labels
• Asbestos waste bags, unlabeled
• Work gloves
• Duct tape
• Asbestos warning stickers
• Gloria hand pump (3 liter) filled with impregnation fluid



ASBESTOS MANAGEMENT -IHM
• Asbestos finding on board of vessels have a been registered and

categorized based on potential risk.
• High risk applications are being actively removed and cleaned via Kiwa
Oesterbaai and third party contractors.
• All vessels have received an Asbestos Safety Kit.
• Superintendents are being trained about the risks of Asbestos and the
proper usage of the Safety Kit.
• Changes in procurement requirements in order to ensure the vessels
remain compliant and to avoid the risk of new asbestos applications being
broad on board.
ASBESTOS MANAGEMENT AND REMOVAL
Safety kit contents
Asbestos Kit in use
Removal by contractor with active airsampling
2
1
PSC READINESS- THE REGULATION COMES INTO
FORCE FROM 31ST DEC 2020 FOR EU PORTS
Basic information on IHM matter from PSC point of view.
• Port State Control inspectors will ask the crew if a certified IHM report and Statement of
Compliance (SoC) issued by Class is available on board.
• Presence of an Asbestos Safety Kit (ASK) for incidental gasket removal
• Proof of training for the dedicated crew who will use the asbestos safety kit. The
familirization and training should be performed on regular basis.
• IHM maintenance – Copy of Material declaration and supplier’s declaration of conformity

for material declaration management
BEST PRACTICES FOR CREW ONBOARD WITH
REGARDS TO HANDLING AND REPORTING OF
HAZARDOUS MATERIALS.
• Asbestos containing spares, commonly found on ships, cannot be used as

per MSC.Circ.1374 and 1379 prohibits the use of asbestos since 01-01-
2011. When asbestos containing spares are present, removal by certified
asbestos removal contractors will be required in order to comply to SOLAS.
• Depending on the age of the vessel, some ACM can remain onboard in
fixed installations but should be managed properly and has been clearly
marked after initial survey.

In-situ ACM, such as gaskets/joints/packings, can remain when properly

managed (and depending on age of vessel).
Only urgent repairs/maintenance works on these ACM should be done by a

dedicated and trained crew, using the contents of the Asbestos safety kit.
Waste from these works is to be packed and disposed off properly and a
waste disposal document should be available and kept onboard as proof of
proper waste management and for IHM maintenance.

Heavy Metals
• Batteries or paints/coatings containing heavy metals do not cause a direct risk
to the crew when kept intact. Maintenance works on paints such as using a
flame cutter, grinding or chipping off paint with a needle hammer will cause
fumes or dust and can lead to exposure. It is highly recommended to use
proper PPE whenever working on such paint layers. Batteries with Lead are to
be disposed properly when changed.
• With regards to reporting, crew will register all changes made to materials
that contain HazMats (according to the IHM survey report) in a central
logbook on board. This log should also be used for the annual IHM
maintenance- a software is being developed to make it easy.
BEST PRACTICES FOR CREW ONBOARD FOR
MAINTENANCE OF IHM, MONITORING OF STORES AND
SPARES WHILE RECEIVING.
As described all changes to materials that contain HazMats are to be registered.
There are many materials that might contain a HazMat and supplies should be
closely monitorred.
• Gaskets / joints / packings / seals

• Insulation materials (e.g. fabrics / textile / pipe insulation)
• Fire / welding blankets
• Friction materials (e.g. brake linings/pads, clutch pads)
• Fuses
THE INVENTORY OF HAZARDOUS MATERIALS:
CONCLUSION
IHM -31st Dec implementation Date
• It records hazards rather than prohibits them– removal of

asbestos from fixed installations is not required for older
vessels.
• It is designed to protect people and the environment - safety
• IHM Part 1 survey report which is the inventory and statement of
compliance important documents for PSC readiness
• Online training for asbestos awareness is being developed in
collaboration with company which has done IHM surveys and
we will arrange this in future.

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What are the purposes of the Inventory of Hazardous Materials (IHM)?

What are the purposes of the Inventory of Hazardous Materials (IHM)?

What are the different types of IHM and regulations?

What are the different types of IHM and regulations?

INVENTORY OF

Inventory of Hazardous Materials (IHM)

 2 different types of IHM:

 Existing vessels  biggest impact for Ship owners

 2 “different” types of Regulations/Guidelines

 EU Regulation (entered into force in 2013) with deadlines set

© Copyright MSC Mediterranean Shipping Company S.A. 2

Inventory of Hazardous Materials (IHM)

 Existing vessels  30-12-2020

 All third party vessels doing EU port calls and

 All third party vessels dropping anchor at EU anchorages

penalties and bans of entering EU ports!

© Copyright MSC Mediterranean Shipping Company S.A. 3

Extend of IHM – new build vessels

© Copyright MSC Mediterranean Shipping Company S.A. 4

Extend of IHM – existing vessels

© Copyright MSC Mediterranean Shipping Company S.A. 5

IHM Survey details

 Part II and III required at recycling phase of vessel (Table B, C and D)

 Substances to be surveyed for Part I

 Polychlorinated Byphenyls (PCB)

 Ozone Depleting Substances (ODS)

 Additional for EU Regulation: PFOS and HBCDD (flame retardants)

© Copyright MSC Mediterranean Shipping Company S.A. 6

© Copyright MSC Mediterranean Shipping Company S.A. 7

IHM Part I Survey details

 Both VSCP and on board

 If no data available  verification via sampling required!

© Copyright MSC Mediterranean Shipping Company S.A. 8

ACM Sample Gasket PCB Sample door frame

ACM Sample Brake Lining

ACM Sample Putty PFOS Sample Aluminimum paint

© Copyright MSC Mediterranean Shipping Company S.A. 10

• Material Declarations and statement of compliance from Vendors for IHM

© Copyright MSC Mediterranean Shipping Company S.A. 11

© Copyright MSC Mediterranean Shipping Company S.A. 12

• It is company policy that all materials including gaskets as delivered on-

© Copyright MSC Mediterranean Shipping Company S.A. 13

© Copyright MSC Mediterranean Shipping Company S.A. 14

Content of the safety kit are detailed as follows

© Copyright MSC Mediterranean Shipping Company S.A. 17

© Copyright MSC Mediterranean Shipping Company S.A. 18

© Copyright MSC Mediterranean Shipping Company S.A. 19

• Asbestos finding on board of vessels have a been registered and

Safety kit contents

Asbestos Kit in use

Removal by contractor with active airsampling

Basic information on IHM matter from PSC point of view.

• Presence of an Asbestos Safety Kit (ASK) for incidental gasket removal

• IHM maintenance – Copy of Material declaration and supplier’s declaration of conformity

• Asbestos containing spares, commonly found on ships, cannot be used as

© Copyright MSC Mediterranean Shipping Company S.A. 23

In-situ ACM, such as gaskets/joints/packings, can remain when properly

Only urgent repairs/maintenance works on these ACM should be done by a

© Copyright MSC Mediterranean Shipping Company S.A. 24