Emissions, ballast water and other regulations were recent challenges for shipping. Now three important letters appear on the radar – IHM. Due to COVID-19, the Korean Register is offering remote surveys to help shipowners to comply with new regulations
The European Ship Recycling Regulation (EU-SRR) for Inventory of Hazardous Materials is now in force. As of 31 December[ds_preview] 2020, ships larger than 500 GT and flying the flag of an EU member state must have an IHM Certificate on board. The same deadline applies to vessels flying non-EU flags but visiting EU ports, they must provide an IHM Statement of Compliance (SoC). To enforce this requirement, EU/EEA member states’ port authorities are now authorized to control ships in order to verify whether they have a valid IHM Certificate or Statement of Compliance (SoC), or a Ready for Recycling Certificate (RfRC), on board.
45 companies with more than 800 vessels operated from Germany have chosen the South Korean classification society, Korean Register (KR), as their trusted partner for IHM certification. »Feedback from our customers has been overwhelmingly positive with many applauding our speed and efficiency of service,« says Michael Suhr, Regional Director North Europe of KR. Other ship owners, however, who initially put the issue on the back burner, were then unprepared for the challenges brought about by the Covid-19 pandemic, he says.
As a result of the global disruptions, ships in ports around the world were delayed or inaccessible, sampling appointments with IHM expert companies (Hazmat experts / service supplier) could not take place and the necessary IHM Initial Survey by the classification society could not be ordered. However, KR was able to coordinate and offer remote surveys for its customers working in close cooperation with several flag state authorities. In addition, KR issued an official letter to all its customers to certify to any Port State Control officer that the shipping company is under contract with KR and that the IHM certification is in progress.
So far, KR’s customers vessels have not experienced any problems with inspections in Europe. Following successful certification, KR’s vessels always have a Statement of Compliance for the IMO Hong Kong Convention (HKC) on board, in addition to the EU-SRR IHM certificate. The HKC has not yet been come into force, but many in the industry expect the HKC to be ratified soon, and its scope is very close to that of the EU-SRR. Under the EU-SRR, additional hazardous materials need to be investigated, e.g. (Perfluorooctanoic acid (PFOS) and Hexabromocyclododecane (HBCDD). In most cases, KR can issue the certificates for a full five years of validity.
Different flag states treat the issue differently. For the German flag for example, IACS classification societies are only authorized to issue an interim certificate for five months and the final certificate comes later from German Flag Authority (BG-Verkehr). Some flag states also insist that the certificate should be adapted to the class run of the ship or shortened in duration.
Hazardous materials have often been found on board ships as part of the IHM process. Asbestos in particular poses a challenge for a shipping company. Depending on the age of the ship and the flag state, the shipping company must dispose of these materials properly within three years. In the case of valve gaskets, proper disposal is quite easy and the professional proof of disposal must always be added to the IHM documentation (IHM Part I).
In cases of more extensive asbestos findings, dialogue should be sought with the responsible flag state and a coordinated risk assessment may lead under certain circumstances, to the disposal being postponed until a later date or even until ship recycling. The solution will of course always be based on ensuring that the ship’s crew is in no way endangered by the asbestos findings.
Every ship that has received an IHM certification must also maintain the IHM system. If any machinery or equipment has been newly installed, removed or replaced or the hull structure including its coating is renewed, it should be reflected with the entry in »Records of Change«. In addition, the Material Declaration (MD) and Supplier’s Declaration of Conformity (SDOC) for newly installed or renewed products should be attached to the IHM Record. The IHM Part I with Record of Change including main data and attached MD´s and SDOC needs to be accessible (and regularly updated) on board for PSC and Class Inspection and IHM Class Renewal.
At the moment, many IHM expert companies offer IHM Maintenance as a software solution, and in fact most of the shipping companies supported by KR have opted for a service package from an IHM expert company. The software is automatically sorting and requesting the necessary MD’s and SDOC’s for inclusion in the IHM report by controlling the purchasing process in the shipping company. Only a few shipping companies maintain the Record of Change independently and designate a responsible person to manage it within the shipping company.
After a maximum timeframe of five years, an IHM Renewal Survey is requested by the classification society. A few even request an annual survey to verify the Records of Change.
Before a ship can be scrapped at the end of its lifetime the Convention requires that all possible residual pollutants on board in the form of waste (IHM Part II Wastes generated in operation) and any residual stockpiles (IHM Part III Stores) should also be included in the IHM documentation.
This IHM Part II and Part III must be prepared no more than three months prior to the scrapping date. When all three parts are available, the classification society issues the final IHM Ready for Recycling Certificate (RfRC), which the scrapper yard requires for proper disposal.
Michael Suhr comments: »KR’s Hamburg branch office is currently carrying out the first IHM Part II and Part III inspection for a German ship owner with the corresponding documentation for the EU-SRR being handled by the nominated IHM expert company.« The first ship maintained by KR IHM Certification is to be scrapped in Turkey before March 2021 in accordance with EU-SRR requirements and Ready for Recycling Certificate (RfRC).
