member of

Tarih/Date : 20 / 10 / 2020
Konu/Subject : IHM FQA-r1
Hazırlayan/by : BM-

FREQUENTLY ASKING QUESTION

Q.1 What is the meaning of IHM?

Inventory of Hazardous Materials is an abbreviation of initials and its technical translation is the
Inventory of Hazardous Materials (IHM).

Q.2 What is the meaning of HazMat?

Hazardous Material is an international abbreviation with technical translation of Hazardous Materials,
created by combining the first syllables.

Q.3 Why is IHM Part.I required?

The new European Ship Recycling Directive (EU SSR.1257/2013) has made it mandatory to have a
IHM for ships with EU flags, as well as ships from non-EU countries above 500 GT, which will either
loading/unloading or anchor at EU ports.

Q.4 Is the implementation date clear for IHM Part.I?

Yes, an approved IHM Part.I and Certificate/Declaration of Conformity are mandatory from 31
December 2020.

Q.5 Will IHM Certificate or Declaration of Conformity be requested outside the European Union
Ports?
It is not required unless the announcement of the Called Port Authority has been.

Q.6 Does the Regulation of the European Union have a basis?

The main source is the Hong Kong Convention, approved by IMO in 2009.
The contract aims to ensure the safe dismantling of ships and to minimize risks to people and the
environment.
Hong Kong Convention, already signed by the signature sufficiently ready in 7 countries and is
expected to enter into force,
The Hong Kong Convention is the main contract such as Load Line, Marpol, Solas, which will
enforce mandatory implementation for all countries that are parties to IMO upon its entry into force.

Q.7 Is Turkey going to be requested in the port?

Although it is a party to the Hong Kong Convention, it is not required since it is not a member state of
the European Union and no announcements have been made yet. In any case, it should not be
forgotten that the decision belongs to the port authority.

Q.8 Are there guidelines, rules for the preparation of IHM Part.I?
IMO.MEPC.269 (68), Hong Kong Convention, EU.SRR.1257 / 2013, IACS Rec.113

Q.9 What should we do for IHM Part.I?

a.The Flag Authorized Organization to be certified should be determined. Certification can be any
Organization authorized by Flag Authority.
b. HazMat Expert to perform sampling process on the ship and Laboratory to conduct analysis should
be selected.
c. IHM Part.I should be compiled after completion of the sampling and analysis procedures
d. IHM Part.I, received by HazMat Expert, must be submitted to the Organization to certify.
e. After the approval of the inventory, the verification survey on the ship should be organized and the
certification process should be completed.

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Q.10 What are the criteria for HazMat Expert and Laboratory selection?
HazMat Expert must meet the criteria specified in IACS.Rec.113 and IMO.MEPC.269 (68).
a.HazMat Expert should have knowledge about the preparation. The training must be based on a
document.
b.HazMat Expert company must have quality documents on IHM preparation and sampling
c.The laboratory for sample analysis should be accredited according to the ISO.17025 standard. It
should be noted that for each analysis to be accredited separately and the documents must be verified
from the website of the accreditation body.

Q.11 Should the selected HazMat Expert Company be an IHM Service Provider of the Authorized
Organization?
Some IACS organizations (BV, KR, TL, RINA) require it to be an Authorized Service Provider.

Q.12 What are you checking on board as GMS?

A total of 15 hazardous substances, which are collected in two groups as Table.A and Table.B
regarding to IMO.MEPC.269(68), are examined. Some of them are checked based on documentation,
marking on the equipment and some of them as Sampling.
As GMS INSPEKTOR, we are compiling the inventory containing all HM’s even if the ship’s flag is non-
EU.

Q.13 Why do you consider all ships as EU-Flag ships?

Because of IMO states "As fas as practible should be examined’’ for Table.B HM and Unified
Interperation is not made by IACS, there are different applications by IACS members. For example,
DNVGL, NKK, LR is requesting full scope inventory reflecting all materials in Table.A & B. Since the
Paris MOU PSC attitude is not known, we as GMS INSPEKTOR examine all the items and compile
IHM in order to protect the Ship Owner/Operator against PSC possible risks.

Q.14 What is the sample number you collected?

Although it does not seem possible to give very significant numbers for the sampling number to be
taken (due to the ship construction year, type, equipment/material, etc.), the number of sampling to be
taken, determined especially in our ships after 1992, has been decreased. Requests above these
numbers (except asbestos inspection) are billed at the unit price. Due to the ship type and age, one or
more of the specified analyzes may or may not be done.
Although it does not seem possible to give very significant numbers for the sampling number to be
taken (due to the ship construction year, type, equipment/material etc.), the number of sampling to be
taken, determined especially in our ships after 1992, has been given below. Additional requests
below,if any, these numbers (except asbestos inspection) are billed at the unit price. Due to the type
and age of the ship, one or more of the specified analyzes may not be performed, and the number of
analyzes to be performed instead of the number of analyzes that do not need to be performed. It can
be increased/decreased by GMS.

80/100 ad. Asbestos + 2 pcs. PFOs + 1 pc. HBCDD + 2 pcs. PCBs + 1 pc. PCN + 1 pc. PBBs + 1 pc.
PBDEs + 1 pc. CSCP + 1 pc. Cadmium + 1 pc. Lead + 1 pc. I hex.chromium

Q.15 Is there any preparation to be done before on-board the vessel?

The following documents, plans and projects should be provided:
a. AFS Certificate, Paint Application File, Paint Documents
b. Existing Asbestos Free Documents, MSDS, SD, SDoC, Green Ship Certificate etc.
c. IAPP Certificate, ODS Record Book
d. Ship’s spare parts (Paint, Gases etc.)
e. Ship's specification
f. General Arrangement
g. Machinery Arrangement
h. Piping Arrangement
i. Accommodation Plan
j. Fire Control Plan
k. Fire Protection Plan
l. Insulation Plan (Hull and Machinery)

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Q.16 How long does it take to sample on board?

The process on the ship is completed within a total of 8-12 hours.

Q.17 As GMS INSPEKTOR, do you have an international expert network?

We also provide sampling operations in the countries given below.
Bulgaria-Romania-Lithuania-Netherlands-America-China-United Arab Emirates-India-Singapore-
South Korea-England

Q.18 Are there any extra fees such as travel and waiting?
Travel expenses, accommodation, etc. expenses are invoiced or covered by the Ship Owner /
Operator.

Q.19 Do you have Service Provider Certificates approved by any Class Society?
Yes. Already certified by BV, KR, TL, RINA

Q.20 How long is the IHM compile?

After the laboratory analysis results, IHM is compiled and delivered within 15-20 days.
Although the results of the analysis are completed in approximately 7-10 days, the period may be
extended in busy periods.

Q.21 Why does the laboratory analysis review take longer?

Especially for asbestos inspection, laboratory asbestos specialist can examine 40 samples/day
according to ISO.17025 standard. In our laboratory, 6 specialists can analyze and report asbestos for
approximately 2.5 / 3 ships per day.

Q.22 Is there any standard for laboratory analysis?

Analysis method selection is made in accordance with IMO.MEPC.269(68)-Appendix.9.
Asbestos analyse is performed with PLM (Polarized light microscope), which is the fastest and most
worldwide accepted economical method for asbestos inspection. With this method, the existence of 6
type asbestos species which are giving qualification result are determined with reasonable cost. Since
other defined methods (XRD) even if gives quantification result additionally, it is more expensive
method and made by rectricted number of accredited laboratories in the World as stated in the IMO
MEPC. Therefore, a cost-effective and result-oriented method is sufficient.
Asbestos detection with the PLM method is based on the examination of the sample under the
microscope with the naked eye.

Q.23 Does your laboratory meet the qualification demands?

We work with two laboratories for analysis.
a.ISTANBUL Laboratory whose activites completely leased by GMS INSPEKTOR is accrediated by
TURKAK (solely Accreditation Body in Turkey) acc.to ISO.17025 for analysing of asbestor in solid form
and in the air.
b.MALASIA Laboratory is accredited by SAMM (Maleyza Accreditation Bodyy) for the determination
of asbestos type in solid sample, in air and more according to ISO.17025 standard. It is also an
approved IHM laboratory by DNVGL, LR.

Q.24 Does the Ship Owner/operator have a duty after the IHM compilation and certification?
Yes. According to IMO.MEPC.269(68), IHM Part.I should be kept up to date after certification.
In order to achieve this, a designated person must be on board or shore.
Upon request (in cases such as PSC, Survey, etc.), updated and related documents (such as the
manufacturer's declaration) must be provided.

Q.25 Do you have any maintenance service for IHM Part.I?

Yes. External service is not compulsory regarding to IMO Guidelines. However, we are planning to
provide services with our software, HazMatINSPEKTOR in the basis of monthly/yearly payment with
different alternatives.

Q.26 Do you have any membership as GMS INSPEKTOR?

Yes. We are a member of International HazMat Association (IHMA).

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Q.27 Is there a delay in the implementation date of the EU SRR?

There is no specific postponement.
The condition of vessels that will enter anchorage and/or port at European Ports witjout valid IHM
DoC/CoC after January 1, 2021 will be evaluated by PCS on the basis of two scenarios in line with the
annexed circular, and if deemed appropriate, a maximum of 4 months can be granted on a ship basis.
We recommend that the company that will make such a request should prepare the following
documents as it will be useful to ensure PSC compliance:
1. In all circumstances, PRE-IHM PART.I should be ready onboard whether sampling not perfomed
2. Expert company agreement
3. Service invoice and payment receipt issued
4. For sampling (in cases where sampling does not take place) and / or survey request (only in cases
where the first inspection does not take place) correspondence in chronological order.
5. Process planning for completion

Q.27 What should I do if asbestos is found on board?

only asbestos has been controled under the SOLAS II-1,3.5
It was restricted as of 2001 and as of 2011 it was completely banned.
If asbestos detected on the ship after 2011, the Flag State is fully authorized for allowance in
accordance with MSC.1045.
The Flag State may permit asbestos removal/disposal until the appropriate repair-maintenance-repair
date, as well as decide on immediate removal. In any case allowance of removal process time does
not exceed 3 years from the date of detection.
We strongly recommend to the ship owner/manager company, they should apply to flag state when
any acm detected on board the vessel. They should follow up flag2s instruction even if class society
issue IHM DoC/CoC or approve IHM Part.1

Q.27 Are you doing asbestos dismantling and disposal work as GMS?
Yes, Asbestos removal and disposal service is provided by our company MARINE INSPEKTOR LTD.-
Marshall Island.

Q.27 What is the cost of asbestos removal and disposal?

Pricing for asbestos removal and disposal from ships is not fixed-standard. The pricing is subject to
it’s location, asbestos type, amount of asbestos It may be start from 3,000 USD and up to 1 million
USD depending on the conditions.
But we can say that asbestos management implementaion may be more expensive then removal
facility in some cases.

Q.28 Can you change the report after the asbestos is found?
Our laboratories work independently. Every analysing process is under the strict control by accredited
organizations and they are our solution partners working with the awareness of their responsibilities.
After the samples are examined and reported, even partial correction cannot be done.

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