WEBINAR on IHM The EU Ship Recycling Regulation and IHM – what you have to know to become compliant Presenters: Gerhard Aulbert, Beyza Doyduk, 2020-01-23 1 DNV GL © SAFER, SMARTER, GREENER AGENDA What are the requirements? How to go ahead on IHM? IHM Maintenance How to recycle a vessel in compliance? Where to get support? Q&A session 2 DNV GL © The experts from DNV GL Maritime 3 DNV GL © Gerhard Aulbert Beyza Doyduk Head of Section EU Certification and Ship Recycling Senior Ship Recycling Engineer and Deputy Head of Section Ship Recycling What are the requirements? 4 DNV GL © Legal Framework – Hong Kong Convention (HKC) HKC was adopted in 2009. It shall enter into force 24 months after the following conditions are met: At least 15 States (current status: 15 States Norway, Congo, France, Belgium, Panama, Denmark, Turkey, the Netherlands, Japan, Serbia, Estonia, Malta, Germany, Ghana and India) The combined merchant fleets of the States in [1] should account to at least 552 mGT (1400 mGT * 40 % = 560 mGT ), (current status: 30.21 %) The combined maximum annual ship recycling volume of the States in [1] should be at least 16.80 mGT (560 mGT * 3 % = 16.8 mGT ), (current status: 2.5 %) Hong Kong Convention is applicable to: All new and existing vessels ≥ 500GT Ship recycling facilities (SRF) Note: Existing vessels have to comply with the Convention 5 years after entry into force. Key issues of the Hong Kong Convention are: Inventory of Hazardous Materials, and Authorization of SRFs Excluded: Government vessels, domestic vessels are excluded from the scope of the Hong Kong Convention; however, equal measures are proposed for these vessels. 5 DNV GL © Legal Framework – EU Ship Recycling Regulation (EU SRR) EU SRR (No 1257/2013) started application on 31 December 2018. EU SRR is aapplicable to: Ships ≥ 500 GT flying flag of a EU/EEA Member State Third party ships calling at a port or anchorage of a EU/EEA Member State Ship Recycling Facilities in the EU List EU SRR shall not apply to: Any warships, naval auxiliary, or other ships owned or operated by a Party and used, for the time being, only on government non-commercial service; Ships of less than 500 GT; or Ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly. Article 3 – Ship definiton: Ship means a vessel of any type whatsoever operating or having operated in the marine environment, and includes submersibles, floating craft, floating platforms, self-elevating platforms, Floating Storage Units (FSUs), and Floating Production Storage and Offloading Units (FPSOs), as well as a vessel stripped of equipment or being towed 6 DNV GL © 16,000 vessels are likely to be affected by the EU SRR Legal Framework – EU Ship Recycling Regulation (EU SRR) 31 December 2018 New ships of 500 GT and above, flying a flag of an EU/EEA, shall carry a valid and certified IHM onboard 2016 2017 2018 2019 31 December 2018 Ships to be recycled, that are flying EU/EEA flag, shall have a RfR certificate on board and be sent to a ship recycling facility, which is in the EU List 7 DNV GL © 2020 2021 31 December 2020 Ships flying a flag of an EU/EEA and third party ships visiting EU/EEA ports and anchorages shall have a valid and certified IHM on board 2022 Comparison of the Regulations EU SRR vs IMO HKC 8 EU SRR IMO HKC Entry into Force 31 December 2013 Not yet ratified Application 31 Dec 2018 For EU/EEA flagged new* vessels; and For EU/EEA flagged vessels going for recycling 31 Dec 2020 for all EU/EEA flagged vessels and third party vessels visiting EU/EEA ports and anchorages New vessels: EiF Existing vessels: EiF + 5 years Applicability Seagoing vessels ≥ 500 gross tonnage EU/EEA flagged vessels and third party flagged vessels calling any EU/EEA ports/anchorages European List of Ship Recycling Facilities (SRFs) Seagoing vessels ≥ 500 gross tonnage Ship Recycling Facilities IHM Part I Investigates 15 hazardous materials listed in Annex I & II Investigates 13 hazardous materials listed in Appendix I & II No of ships affected (appr.): 16,000 60,000 IHM Certification done by Flag states or ROs IC (IHM Certificate) for EU/EEA flagged vessels SoC (Staement of compliance) for third party flagged vessels Flag states or ROs ICIHM – International Certificate on IHM DNV GL © What is the Inventory of Hazardous Materials (IHM)? “IHM” is a list of hazardous materials that are contained in ship’s structure, equipment or systems, together with their location and approximate quantities. IHM is prepared according to the EU SRR and Resolution MEPC.269(68) Guidelines for the development of the IHM. There are different approaches identified for new and existing ships’ IHM preparation, and IHM shall be maintained throughout the life of the ship. Scope of the IHM EU SRR Shipbuilding & Operation Part I Structure & Equipment Preparation prior to Recycling Part II Operationally generated Wastes Part III Stores Annex I Mandatory for new / existing ships & new installations Annex II Mandatory for new ships / installations; as far as practicable for existing ships Table C Materials Potentially hazardous items Table D Materials Regular consumable goods potentially containing hazardous materials 9 DNV GL © Annex I: (5) • Asbestos • PCB • ODS • Antifouling • PFOS Annex II: (10) • Annex I • Lead, Cadmium, Mercury, Chromium VI • PBB • PBDE • PCN • SCCP • Radioactive substances • HBCDD What are the final documents required on board? 10 DNV GL © How to go ahead on IHM? 11 DNV GL © Who prepares the IHM? New buildings: Vessels in operation: Shipyard Ship owner HazMat Expert Note: MEPC 269(68) Ch.4.2 Development of part I of the Inventory for existing ships The procedures described in this section should be carried out by the shipowner, who may draw upon expert assistance. Such an expert or expert party should not be the same as the person or organization authorized by the Administration to approve the Inventory). 12 DNV GL © IHM preparation by ship owner / hazmat expert Step 1 Collection of ship specific information Step 2 Evaluation and definition of scope of assessment min 4 13 Step 3 Preparation of Visual Sampling Check Plan (VSCP) Step 4 On board visual and sampling investigation Step 5 IHM Part I report preparation DNV GL © weeks RO approval and certification Admin, preparation: HazMat Expert Shipowner DNV GL Approval (by DNV GL) Survey (by DNV GL surveyor) 14 DNV GL © IHM work, preliminary approval: On-board, final approval: Prepares the IHM Contact your local DNV GL office for IHM offer Signs offer Sends IHM for approval Receives approval letter Requests IHM initial survey DNV GL prepares offer Conducts approval IHM initial survey Certificate / SoC Time needed to get your certified IHM Up to 3 months Min 4 weeks Min 2 week RO Approval IHM Preparation On board verification of IHM Follows survey checklist Document review Time on board ca. 2 hours Preparation of IHM & report Comments clarification, if any Submission to ship owner Approval and approval letter submission to ship owner Certificate / Statement of Compliance On board inspection Work with approved service suppliers 15 IHM initial survey Agreement for the IHM plan approval Agreement for the IHM preparation Min 1 week DNV GL © Submit IHM for approval asap IHM survey to be combined with annual IHM maintenance 16 DNV GL © The shipowner is responsible for the IHM maintenance The ship-owner is responsible for the maintenance of IHM (Part I) during the entire life-time of the ship. The ship-owner shall nominate a Designated Person to ensure compliance with the EU SRR. Role of designated person Works on behalf of the ship owner Responsible for maintaining and updating IHM May be employed ashore (with contact partner on board) or on board In case of conversion, repair or sale of a ship, appropriately maintains and updates IHM Part I by recording all changes relevant; Establishes, implements and supervises a system to ensure updating of IHM Part I 17 DNV GL © IGS – IHM preparation & maintenance tool IGS is a web based software application which enables shipowners to manage their IHMs for the fleet during the life cycle of the ships. ViO Hazmat Expert NB NB Yard VSCP & MD/SDoC MD/SDoC IGS provides integrated and transparent IHM processing for shipyards and hazmat experts. • MD: Materials Declaration IGS in Veracity Component Manufacturer MD/SDoC Owner IHM Corrections & Maintenance DNVGL Approval DNVGL Surveyor Initial Survey & Report Initial Survey & Report IHM Certificate • SDoC: Suppliers Declaration of Conformity • VSCP: Visual/Sampling Check Plan (Inspection report (Excel) incl. sampling & lab testing) 18 DNV GL © Renewal survey < 5 yrs. IGS & IHM Maintenance 19 DNV GL © Port state control measures for EU SRR PSC inspections are limited to verifying that there is on board either an IHM Certificate / SoC or a RfR Certificate. (EU SRR Art.11) If a vessel does not carry a valid IHM C/SoC or RfR C, or; If there are clear grounds for believing that: – the condition of the vessel or its equipment does not correspond substantially with the particulars of the certificate, and/or Part I of the IHM; or – there is no procedure implemented on board the vessel for the maintenance of Part I of the IHM; a detailed inspection may be carried out taking into account relevant IMO guidelines. Vessel may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of a Member State in the event that it fails to submit to the relevant authorities of that Member State a copy of the IHM or the ready for recycling certificate, as appropriate and on request of those authorities, without prejudice to Article 9.(EU SRR Article 11) 20 DNV GL © How to recycle a vessel in compliance? 21 DNV GL © Recycling is governed by different regulations EU/EEA Flag EU Ship Recycling Regulation EU List of SRFs EU /EEA ports EU Waste Shipment Regulation State Party to Basel 3rd party flagged EU,OECD, Liechtenstein 22 DNV GL © Basel Ban Amendment EU, OECD Liechten stein EU, OECD Liechten stein Where to get support? 23 DNV GL © More content and support available on our digital sources IHM theme page: www.dnvgl.com/shiprecycling Recycling, hazmat page: Techical and Regulatory News: www.dnvgl.com/tecreg For customers: DATE – Direct Access to Technical Experts via Veracity data platform 24 DNV GL © Why DNV GL on IHM? (summary) Efficient and integrated process by using the IHM App ...saving time, efforts, costs 25 DNV GL © 2500+ DNV GL has verified hundreds of vessels to IHM – experience counts! Lifecycle ... where we follow your vessel from birth to recycling Quality ...always pays off - just ask a local PSC officer Training ...of your own hazmat experts ...in your back. WEBINAR on IHM The EU Ship Recycling Regulation and IHM – what you have to know to become compliant www.dnvgl.com SAFER, SMARTER, GREENER 26 DNV GL © The trademarks DNV GL®, DNV®, the Horizon Graphic and Det Norske Veritas® are the properties of companies in the Det Norske Veritas group. All rights reserved.
