IHM maintenance is a must!
All ships of 500 GT and above must and shall have an Inventory of Hazardous Materials (IHM) Certificate and Statement of Compliance on board.
However, shipowners and managers shall also have a procedure for proper IHM Part I maintenance during the service life of the ship.
Faroe Maritime Services offers maintenance services as an externally designated person for IHM maintenance, using an approved IHM Manager system that meets the ship owners’ needs for sustainable IHM maintenance.
This IHM Manager system can be used for the entire fleet, regardless of class.
We can store all product data, including the Material Declaration (MD) and Suppliers’ Declaration of Conformity (SDoC), that declares a hazardous material and the products that are not. Scanned copies or images of MD/SDoC can also be stored.
Hazardous material information on purchased products can be listed in the IHM for each location. Even if the product is not yet installed on board but is stored in the workshop, this can be indicated when adding the product to the location.
We help generate new IHM versions and keep track of changes.
Whenever an IHM is changed, a new version of it can be generated. All the generated versions are stored in the system and thus give a lifetime historical overview of the vessel’s IHM data.
Even if a product is removed from a vessel and thus deleted from IHM, e.g. asbestos-containing materials, the product is not deleted from the database. A deleted item can always be restored, and a working draft of the IHM that includes the deleted items can be printed.
Last but not least, the audit log records all the changes made to a vessel’s IHM by specific users, including the date and time, thus providing a transparent maintenance history.
Easy access by everyone with approval and smooth transfer of IHM data
Scope of the service
We can make an IHM maintenance procedure and manuals.
As informed, firstly, shipowners must establish an IHM maintenance procedure & manual that is integrated into the shipowner’s safety management system.
In parallel, shipowners must appoint a person responsible for IHM maintenance, named an IHM Designated Person(s) (IHM DP).
Faroe Maritime Services offers to take on this role as IHM Designated Person(s) (IHM DP)
Based on the IHM maintenance procedure, the IHM DP shall review all purchases made for each vessel within a period as defined in the IHM maintenance procedure.
This review period can be bimonthly or quarterly, which should be defined by the shipowner and identified in the IHM maintenance procedure.
For purchased products that fall into the scope of IHM Part I, Material Declaration (MD) and Supplier Declaration of Conformity (SDoC) forms must be collected from the suppliers.
Even if there are no hazardous materials in a product, MD/ SDoC forms must still be collected, as they are the shipowner’s evidence that the product is free of hazardous materials.
The IHM Part I shall list all machinery, equipment, materials, and coatings on board that are installed as fixed items. Therefore, the collection of an MD/SDoC is needed for those products. For details on the scope of IHM Part I, If a hazardous material is declared to be above the specified threshold values in a product, then we, as the IHM DP, will or shall update the IHM, and we will issue a new revision with a date and revision number. We, as IHM DP, will record the activities conducted in a change log.
The IHM Part-1 is a dynamic document. Therefore, constant effort is required from ship staff, the purchasing department, and the technical department.
IHM maintenance
Shipowners must see to it that each vessel maintains an IHM maintenance manual. Even though this document is not an RO-approved one, PSC can and will inspect the record to check how well-defined and organized the vessel is in maintaining IHM Part-1 the Maintenance Plan.
- Describe the responsibilities of related personnel.
Designated Person (DP)
(The person has the overall authority to oversee all hazardous materials (regulated in HKC and EU SRR)-related activities on the ship.)
- Ship Manager
- Purchase department.
Vessel Master and Chief Engineer
- IHM life cycle
- Procedures to maintain the IHM
- Work Permit and Authorization
- Hazardous material or substance management.
Let’s go into the details of the procedural aspects.
First of all, a sound knowledge of the items to be maintained and the details of items whose MD (material declaration) and SDoC (supplier’s declaration of conformity) are possessed by the DP
As the DP need to
- Review the RO-verified inventory of hazardous materials.
- Gather details about the materials input streams ( this should be done in the operation of the technical department, the purchasing department, and by the vessel crew.)
- Filter out the relevant details. Here, sound knowledge of DP comes into play.
The biggest question is which items need MD and SDoC.
Machinery and equipment that is fixed (i.e., securely fitted with the ship, such as by welding or with bolts, riveted or cemented, and used at their position, including electric cables and gaskets) and applied to coating need an IHM declaration.
Items that are not fixed, such as portable fire extinguishers, distress flares, lifebuoys, etc., are not required to be listed in part I of IHM.
Batteries containing lead acid or other hazardous materials that are fixed in place should be listed in part I of IHM, but those not fixed, such as consumer batteries and batteries in stores, are not required to be listed in part I (but general emergency battery, VDR battery, and emergency generator battery need to be updated)
Materials that are inherent in solid metals or metal alloys, such as steels, aluminum, brasses, bronzes, plating, and solders, provided they are used in general construction, such as hull, superstructures, pipes, or housings for equipment and machinery, are not required to be listed in the inventory.
Although electrical and electronic equipment is required to be listed in the inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the inventory.
- Whose MD and SDoC need not be collected again: If the supplied item is a genuine spare part, whose MD and SDoC are available onboard, then the IHM Part-1 need not be collected again
Hence, practically, it is much easier for the maintenance of IHM in terms of spare supply, but the more difficult part is in terms of store supply. As the suppliers are not aware of the requirement, some of the items’ origins are not known, and some of the component’s contents are not known, like gaskets and packings.
PSC will be checking the data more thoroughly, especially where new installation, modification, repair, exchange, removal, or alteration of location, structure, machinery, and/or equipment, renewal of coating, change of flag, owner, or operator is undertaken. Therefore, thorough attention should be paid so that a proper revision of the inventory may be made.
Usually, IHM renews all the certificates, and either the owner or vessel name is changed. But in IHM, if the manager changes, the SoC needs to be renewed.
Sample sheets MD and SDoC.
IHM renewal surveys
During the IHM renewal survey, the surveyor will verify that:
- A vessel-specific, maintained, and updated IHM Part I is provided on board together with a valid compliance declaration.
- The procedure for maintaining IHM Part I is on board and integrated into the safety management system.
- The IHM Part I is consistent with the arrangement, structure, and equipment of the vessel
To do this, the surveyor has to examine the previous version of the IHM Part I and compare it with the updated IHM Part I, supplemented by the new MD and SDoC. If an item of equipment that contains hazardous material is removed from the vessel, it must be ensured that it is removed from IHM Part I as well. It should be noted that when the term “on board” is used, this means that having digital solutions in place is also acceptable. Therefore, during an inspection or survey, the master can show the versions of the IHM and MD/SDoCs digitally from the computer. As the IHM maintenance procedures require the collection of many MD/SDoC documents, we strongly recommend using software solutions such as DNV’s IHM Manager software for data management, which enables users to keep a fully digital record of the IHM of the vessels in their fleet. The IHM Manager software solution is available on DNV’s Veracity marketplace. 3. PSC inspections
PSC inspections are limited to verifying that there is a valid IHM compliance declaration on board, which shall be considered sufficient for approval of the inspection. A detailed inspection may be carried out if a vessel doesn’t carry a valid compliance declaration or if there are clear grounds for the PSC officer to believe that
- The condition of the ship or its equipment does not correspond substantially with the particulars of that certificate, SOC, and/or IHM Part I.
- There is no IHM maintenance procedure implemented.
Not having a valid IHM certificate or SOC may be a reason for detention. However, failure to update the IHM is not a detainable deficiency. Such inconsistencies shall be rectified at the time of the next survey.