10 compliance tips for ship recycling and IHM

 

The International Maritime Organization’s (IMO) 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships and the European Union’s 2013 Ship Recycling Regulation (EU SRR) provide strict guidelines for ship recycling and developing an inventory of hazardous materials (IHM).

Ships are required to carry a regularly updated IHM manual, while ship recycling yards will need a thorough Ship Recycling Plan specifying how each ship will be recycled. 

While the Hong Kong Convention has yet to be ratified, the EU SRR will require all ships sailing in EU waters to carry an IHM by the end of 2020. This gives shipowners slightly more than a year to prepare their vessels – and BV Solutions M&O is here to help.

Below we offer a ten-step plan to help ship owners and managers prepare their fleets:

1. Seek expert advice
   From design to dismantling, BV Solutions M&O experts have an in-depth understanding of both the Hong Kong Convention and the EU SRR. Before making plans, shipowners must identify the right maritime organization to work with, and consult their marine professionals.
    
2. Plan for your fleet
   Owners should determine when regulations will affect them, keeping track of key deadlines for EU and non-EU flagged ships. Additionally, owners should learn which waters will be subject to IHM requirements.
    
3. Prepare for regulatory changes
   Owners must be aware of how regulations will affect their ships, taking into account the relevant conventions, their operational aspects and end-of-life requirements, and compliance with Port State Control (PSC).
    
4. Understand IHM
   IHM preparation is not an overnight process – shipowners must understand what compliance with IHM entails, and begin preparing well in advance of the 2020 deadline.
    
5. Make a pre-planning checklist
   IHM requirements can differ between newbuilds and in-service ships, as well as for EU and non-EU flagged vessels. Additionally, once an IHM has been produced, an initial survey, renewal surveys and a final survey will be required to ensure ongoing compliance.
    
6. Budget for sampling
   Both the Convention and the EU SRR require proof of analysis, and this means allocating budget for sampling. Depending on ship type and expert pre-planning, shipowners can limit sampling costs.
    
7. Develop your IHM
   With BV Solutions M&O’s proprietary technology, Praxis IHM, our hazardous materials experts can produce a thorough IHM manual that includes a completed visual and sampling check plan, results of any laboratory analysis, and photographic evidence of the survey. Praxis IHM also keeps track of what’s been added onboard over the life of a ship, ensuring information about hazardous materials remains up-to-date.
    
8. Identify benefits and risks for ship recycling facilities
   Owners will need to choose among numerous ship recycling facilities when selling their vessels. BV Solutions M&O experts can provide key advice about which facility best fits a particular owner’s needs, budget and associated legislative requirements.
    
9. Make decisions about recycling
   To ensure that ships are being dismantled in line with regulations and industry best practice, owners should consider auditing their chosen recycling facility before and during their process of vessel recycling.
    
10. Create a ship recycling policy
    Owners should develop a ship recycling policy that includes: IHM, final survey work, recycling facility selection criteria, requirements for new owners when selling ships and additional compliance measures.  

Developing an IHM requires time and in-depth understanding of marine regulations. BV Solutions M&O has over 100 marine surveyors worldwide specifically trained in assessing hazardous materials and developing IHM. Our experts offer crucial insight into compliance with the Hong Kong Convention and EU SRR requirements, and the digital tools to help shipowners prepare well in advance.