INVENTORY OF HAZARDOUS MATERIALS ONBOARD SHIPS

-ANSWERS TO THE TEN MOST ASKED “W” QUESTIONS-

1. WHAT are Hazardous Materials as related to ships and how could they affect the ship
crew’s safety and health or cause damage to the Environment?
2. WHERE are Hazardous Materials generally found onboard?
3. WHY do we have to start inventorying them now – can we have a listing of the
regulations/requirements/guidelines that now apply and to what craft?
4. WHEN do the regulations/requirements enter into force?
5. WHO will carry out the IHM and can the manner and process flow, also the time line
be described?
6. WONT the IHM process cause some disruption to the ship’s operations?
7. WHICH sort of Certificate will be received by us to state that we comply with the
requirements?
8. WILL the IHM process be an ongoing issue or is it a ‘one off’ procedure?
9. WHILE any Port State Control Inspection is underway, can we expect an Official to
ask questions or conduct checks regarding our IHM compliance?
10.WAIT a minute – we will have to budget for this – what are the items to be budgeted
for?
 INVENTORY OF HAZARDOUS MATERIALS Page 1 of 11
THE “10Ws”

1. What are Hazardous Materials as related to ships and how could they affect the ship
crew’s safety and health, or cause damage to the environment?
A hazardous material is any item or agent (biological, chemical, radiological, and/or physical), which has
the potential to cause harm to humans, animals, or the environment, either by itself or through interaction
with other factors.

Hazardous Materials, generally found onboard ships (as part of their fixed structure or assemblies), are
identified within the Hong Kong Convention and its associated MEPC 269(68) and within the Annexes of
the Regulation (EU) 1257/2013 of the European Parliament and the Council on ship recycling. There are
many hazardous materials identified, which are segregated into Tables and Annexes; also specified are
their threshold value which is defined as the concentration value in homogeneous materials that make
the material hazardous.

To name a few of the materials –

Material Harmful Effects

Asbestos
Polychlorinated Biphenyls
Ozone Depleting Substances
Antifouling paints containing organotin
Perfluorooctane sulfonic Acid
Cadmium and Cadmium Compounds
Hexavalent Chromium and Hexavalent
Chromium Compounds
Lead and Lead Compounds
Mercury and Mercury Compounds
Polybrominated Biphenyl (PBBs)
Polybrominated Diphenyl Ethers (PBDEs)
Polychlorinated Naphthalenes (more than 3
chlorine atoms)
Radioactive substances
Certain Shortchain Chlorinated Paraffins
(Alkanes, C10-C13, chloro)
Brominated Flame Retardant (HBCDD)
Lung Cancer and other lung disorders etc.
Skin and Liver disorders etc.
Depletion of the protective atmospheric Ozone Layer
Damages the immune & hormone system of marine life
Contamination of water that may be used for drinking
Kidney damage and bone demineralization etc.
Workers who are exposed to hexavalent chromium are
at increased risk of developing lung cancer, asthma, or
damage to the nasal epithelia and skin
Damage to brain and central nervous systems etc.
Damage to digestive system, kidneys etc.
Cause immunotoxicity and disorders related to the
central nervous system
Reduce fertility in humans at levels found in households.
Exposed to PCNs may cause chloracne, severe skin
rashes and liver disease
DNA damage, nausea, vomiting etc., even hair loss
SCCPs are classified as toxic to aquatic organisms, and
carcinogenic to rats and mice
Identified as persistent, bioaccumulative, and toxic to
both humans and the environment and were suspected
of causing neurobehavioral effects and endocrine
disruption.
 INVENTORY OF HAZARDOUS MATERIALS Page 2 of 11
THE “10Ws”

2. Where are Hazardous Materials generally found onboard?

Depending on the type of vessel, hazardous materials can be found at various locations. Using the IMO
indicative list, we list a few selected locations of the selected materials in Point 1 above
Asbestos • Propeller shafting packings or synthetic stern tubes
• Lagging material for piping flanges, fuel pipes,
exhaust pipes of diesel or steam turbine engines
• Boiler insulation and manhole packings
• Incinerator door and lagging/packing
• Fuel tank lagging
• Fire door insulation, accommodation insulation
• Sealing putty
• Brake linings
• Etc..
Polychlorinated Biphenyls • Transformer Oils
• Electric Cable Sheathing
• Fuel Heaters
• Rubber Isolation Mounts
• Fluorescent light ballast
• Etc..
Ozone Depleting Substances • Refrigerant for refrigerators and Air conditioning
units
• Blowing agent for insulation of LNG tanks
• Extinguishing agents
• Etc..
Organotin compounds • Anti-fouling paints on ship’s bottoms – although
this is not allowed anymore some ships may have
the original tin-based antifouling overcoated with
permitted paints.
Cadmium • Plating films
• Bearings
• Etc..
Lead • Batteries
• Certain primers
• Insulation
• Solder
• Etc..
Mercury • Liquid level indicators
• Thermometers
• Mercury lamps
• Fire detectors
• Gyro compasses
• Etc..
Radioactive substances • Smoke detectors
• Radioactive paints -radionuclides
• Level gauges
• Etc..
 INVENTORY OF HAZARDOUS MATERIALS Page 3 of 11
THE “10Ws”

3. Why do we have to start inventorying them now – can we have a listing of the
regulations/requirements/guidelines that apply and to what craft do they apply.
For years, the world tolerated the use and improper disposal of hazardous materials until SOLAS
recognized Asbestos as one of the most dangerous substances and banned it several years ago. This ban
was followed by: -

The Hong Kong Convention (HKC) 2009 an international convention for the Safe and Environmentally
Sound Recycling of Ships, was adopted. The requirement for ships to carry an Inventory of Hazardous
Materials (IHM) became a part of the HKC requirements to provide a meaningful system of workable and
enforceable regulations with the ultimate goal of placing clear obligations on all parties concerned –
shipowners, recycling facilities, flag states as well as recycling states – to ensure that ships in service, and
end-of-life ships when being recycled, do not pose any unnecessary risks to human health, safety and the
environment.

The EU Ship Recycling Regulation 1257/2013

Further to the HKC, and not wanting to wait for its ratification, the EU Ship Recycling Regulation
1257/2013 was adopted on 20 November 2013.
The Regulation brings forward the requirements of the 2009 Hong Kong Convention for the Safe and
Environmentally sound Recycling of Ships, including the Inventory of Hazardous Material requirements
for all ships calling EU or EU controlled ports and included two more hazardous materials - PFOS and
HBCDD

Other Guidelines such as –

MEPC 269(68) – Guidelines for the development of the IHM
MEPC 222(64) – Guidelines for the Survey and Certification of Ships under the HKC
MEPC 223(64) – Guidelines for the Inspection of Ships under the HKC
EMSA Guidelines on IHM 2017
EMSA-- Guidance on inspections of ships by the port States in accordance with Regulation (EU) 1257/2013
on ship recycling also explain the requirements in detail.

It may be noted that the regulations shall not apply to warships, ships less than 500 GRT and ships trading
solely in inland waters of one country.

Ship generally includes any vessel of any type operating in the marine environment including craft in the
oil and gas industry.
 INVENTORY OF HAZARDOUS MATERIALS Page 4 of 11
THE “10Ws”

4. When do the regulations/requirements enter into force?

The Hong Kong Convention will enter into force 24 months after the date on which the following
conditions are met:
• Ratification by 15 States
• Representation by at least 40% of world merchant shipping by gross tonnage, and
• A maximum annual ship recycling volume not less than 3 per cent of the combined tonnage of the
ratifying States (based on the last 10 years performance)

EU Regulations will enter into force

• 31 Dec 2018 for “New EU flagged ship”: that means a ship flagged with an EU Member State for
which either: (a) the building contract is placed on or after the date of application of this
Regulation; (b) in the absence of a building contract, the keel is laid or the ship is at a similar stage
of construction six months after the date of application of this Regulation or thereafter; or (c) the
delivery takes place thirty months after the date of application of this Regulation or thereafter.

• 31 December 2020 for an “Existing EU flagged ship” that is - A ship flagged with an EU Member
State which is not a “New EU flagged ship”: or prior to the ship going for recycling, if recycled
on/after 31 December 2018
• 31 December 2020 for a “Non-EU flagged ship”: a ship flagged by a State which is not an EU
Member State calling at a port or anchorage of an EU Member State

Note: Corporate Social Responsibility

Many responsible shipping companies have started to comply with the requirements of the Hong Kong
Convention even before ratification, due to a sense of social responsibility.

Other organizations such as Banks and Investment Fund Companies have also made requirements for
ships to have proper Inventories of Hazardous Materials that are used for drawing up Ship Recycling Plans
to ensure proper preparation for Responsible Recycling as part of their pre-loan qualifications to ship
owners seeking loans for the ordering of new tonnage.

5. Who will carry out the IHM and can the manner and process flow, also the time line
be described?
The IHM (Part I) process for a vessel is as follows –

a) The Owner/Operator selects a certified (preferably by an IACS Class or major Flag State) IHM
service provider to perform the IHM
b) The service provider will ask for (amongst other things) the following documents - General
Arrangement Plan, Capacity Plan, Accommodation Plan, Machinery Arrangement Plan,
Manufacturers Manuals for selected machinery, Fire and Life Saving Plan, Insulation Plan; Material
Specification for deck-heads, side panels, deck flooring, doors, insulation material used, joiner
material; Piping Insulation, AFS Certificate, Ozone depleting Substances Log, Spare Parts and Tools
List, Repair and modification history, Asbestos Free Declarations from builders or shipyards (it may
be noted though that in several cases asbestos has been found on ships with an Asbestos Free
Declaration , etc..
 INVENTORY OF HAZARDOUS MATERIALS Page 5 of 11
THE “10Ws”

c) Based on a study of the above the service provider will draw up a Visual / Sampling Check Plan
(VSCP) and a ‘Location Diagram’ (LD) for use by the IHM certified onboard surveyor(s), who will be
performing the survey.

d) The surveyor(s) will go through the VSCP and LD and perform an onboard survey during which they
will examine the areas that may contain hazardous materials, and/or take physical samples from
such locations as deemed necessary. About 80 samples are generally taken on an average.

e) The surveyor or survey team will then carefully mark and label the samples and courier or hand
carry the samples to a certified laboratory

f) The laboratory will analyse the samples according to the regulatory specifications and issue its
report
 INVENTORY OF HAZARDOUS MATERIALS Page 6 of 11
THE “10Ws”

g) The laboratory results will be taken into account by the service provider when drawing up their
report
h) The service provider will issue their Final Report on the presence and location of any HMs onboard
i) The Final Report will be sent for approval to the vessel’s Class or Flag.

Time Generally Taken -

The above processes may take up to 19 days to complete, not counting the days taken by Class or Flag to
examine the report, perform their own inspection if necessary and issue the Statement of Certificate. The
19 days include
• About 3 days to study the ship’s documentation and draw up a VSCP (It may need more days if pre-
approval required by Class)
• About 3 days to perform the onboard survey
• About 5 days for the samples to reach the laboratory
• About 5 days for the laboratory analysis to be completed
• About 3 days for the Final Report to be completed after lab results obtained
The days do not include a period of waiting for the ship to arrive at a suitable port where the surveyor(s)
can board after the VSCP are ready

Note: A ship holding an IHM Statement of Compliance issued before the EU IHM Regulations were released
will have to be re-surveyed to include an examination for the presence of PFOS and HBCDD. This will take
about half a day.

If a vessel is proceeding for Recycling, then a further IHM -

• Part II (Operationally generated wastes such as sludge which are potentially hazardous to the
environment) and
• Part III (Stores or consumable goods such as spare batteries potentially containing hazardous
material)
shall be carried out and the reports submitted to the concerned authority accordingly. These may take a
day or so to complete.

6. Wont the IHM process cause some disruption to the ship’s operations?
No. Generally the surveyors are careful to liaise with ship’s crew to perform any sampling and inspections
in a manner that will not require any disruption to the ship’s schedule. If the inspection cannot be
completed in port the surveyor may undertake a short voyage with the vessel.

Ideally though, it is preferable to perform such inspections when the ship is in dry dock or undergoing
repairs afloat for a significant period of time.

However, if asbestos is found on a trading ship it will have to be removed within a period of 3 years and
the removal process may cause some disruption to the ship, especially if found in the accommodation
insulation, unless done in dry dock, or during other lay-up, or significantly long repair period.
 INVENTORY OF HAZARDOUS MATERIALS Page 7 of 11
THE “10Ws”

7. Which sort of Certificate will be received by us to state that we comply with the
requirements?
If the IHM & report is acceptable, the Vessel will receive a ‘Statement of Compliance’ or ‘Certificate’
based on whether the vessel is a non-EU Flag or existing EU Flag vessel; or is a new vessel under the EU
Flag; valid for 5 years.

Once the Hong Kong Convention has been ratified and enters into force all ships will have a “Certificate”
and the “Statements” will no longer be valid.

8. Will the IHM process be an ongoing issue or is it a ‘one off’ procedure?

The IHM process will be an ongoing process, in that any changes made to structure or material
connected thereto, that may cause a change to the condition found during the original IHM survey, shall
be duly recorded.

Replacement parts or material will need to have their MD (Material Declaration) and SDOC (Supplier’s
Declaration of Conformance) carefully read to determine if any part supplied contains material defined
as hazardous and the IHM documentation and records maintained (IHM Maintenance process) and
updated accordingly.

9. While any Port State Control Inspection is underway, can we expect an Inspector to
ask questions regarding our IHM compliance?
As long as the Hong Kong Convention is not ratified, Port State Inspectors world-wide should not be
expected to ask about or inspect IHM related issues.

HOWEVER: -
In the EU, for new EU Flag Ships, from 31 Dec 2018 onwards, PSC Officers are expected to enquire about
the existence, approval, correctness and maintenance of the IHM Certificate and related documentation

In the EU, for existing EU Flag Ships, from 31 Dec 2018 onwards, PSC Officers are expected to enquire
about the existence, approval, correctness and maintenance of the IHM Statement of Compliance and
related documentation – and from 31 Dec 2020 onwards, to enquire about the existence, approval,
correctness and maintenance of the IHM Certificate and documentation.

In the EU ports, for non-EU Flag vessels, from 31 Dec 2020 onwards, PSC Officers are expected to enquire
about the existence, approval, correctness and maintenance of the IHM Statement of Compliance and
related documentation.

If during the Inspection an EU Port State Officer find non compliances that give “clear grounds” for a more
detailed inspection, or even sampling verification, he may do so. Clear grounds include: -

a) The IHM certificate or Statement of Compliance is out of date.

b) The IHM Certificate or Statement of Compliance has not been issued by an Organization authorised
by the Flag State.
 INVENTORY OF HAZARDOUS MATERIALS Page 8 of 11
THE “10Ws”

c) The Inventory of Hazardous Materials appended to the certificate or statement is missing.

d) The Inventory of Hazardous Materials appended to the certificate or statement is not specific to
that ship or is inadequate in content.
e) Differences between the Inventory of Hazardous Material details and the actual ship’s structure or
equipment are found.
f) The absence of mention of Hazardous Materials in structure or equipment that the Inspector
strongly suspects does actually contain them.
g) In EU ships going for recycling, the IHM is not properly reflected in the Ship Recycling Plan.
h) The Certificate or Statement is not in English, French or Spanish.

A ship may be detained if the detected non-compliances are sufficiently serious to merit a PSC Officer

asking for further tests to be done or returning to the ship to be satisfied that they have been rectified or Deleted:
that the necessary actions to be rectified have been undertaken before the ship sails. Regarding items (d),
(e) and (f) above there are real dangers of them being experienced if the IHM Service Company used is
inexperienced, has improper procedures to follow, has inspectors that are not properly trained or
professionally certificated, or has used labs that are not fully certified for analysis of materials mentioned
in MEPC 269(68) or the EU 1257/2013

Alternatively, to detention, the ship may be warned, or penalised, or have its Flag State called to attend,
or dismissed from port or other punitive actions taken.
**
However, if it is found that the IHM related documentation has not been maintained up to date as per
Section 8, then the ship may be warned or otherwise penalised, but not detained.
 INVENTORY OF HAZARDOUS MATERIALS Page 9 of 11
THE “10Ws”

10.Wait a minute – we will have to budget for this – what are the items to be budgeted
for?
A ship owner or operator will have to budget for IHM related expenses.
These include –

• The fixed charge by the IHM service provider (which should include lab charges).
• Travel Expenses for IHM Inspector(s) to ports where the Service Provider may not have
representatives.
• Charges by Class or Flag for review of the IHM report
• Issuance of a Statement of Compliance or Certificate after verification of the IHM.
• If you are going to outsource the IHM maintenance process, then the service provider’s fee.
• Eventual removal of asbestos on ships in service, if discovered during the IHM process.

About CTI Marine Services

CTl marine services goes back to 1970's when POLY NDT Pte Ltd , a member of CTI group, first opened their marine
service centre in Singapore.

CTI group is world top 20 Testing, Inspection and Certification Company employing over 10,000 people with over half
billion USD annual revenue.
 INVENTORY OF HAZARDOUS MATERIALS Page 10 of 11
THE “10Ws”

CTI marine department is Consisted by:

• A group of senior marine specialists consisted by former senior class surveyors, former vessel managers,
Captain and Chief Engineers from Reputable Ship Owning and Ship Management Companies
• Fully certified by most IACS members (as shown below) to conduct an Inventory of Hazardous Materials (Part
I, II and III) that can be done during service (Part I) and prior recycling (Part II and III)
• Global Inhouse Technical Team with Extensive Experience in IHM Preparation and Ship Recycling Supervision
• Inhouse IHM lab with Full Capability of Testing EU/IMO 15 Hazardous Materials

CTI offer a global presence with cost-effective services from below network
 INVENTORY OF HAZARDOUS MATERIALS Page 11 of 11
THE “10Ws”

Netherlands
Seattle Greece
Turkey Shanghai/Ningbo

Suzhou/Guangzhou
Hong Kong
India
Singapore

Malaysia