Known at Lloyd's Register as the 'Green Passport', the Inventory of Hazardous Materials (IHM) is a key requirement of the Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships.
It records materials present in the ship's structure, systems and equipment which may be hazardous to the health and the environment.Due to complicated entry-into-force criteria, it is difficult to anticipate when the Convention will be ratified, although it is expected sometime between 2013 and 2015. Once in force, all ships will be required to maintain an Inventory. Yet almost 1,000 ships have already signed up for Lloyd's Register's Green Passport services. So why have so many clients asked for assistance in achieving early compliance with the Hong Kong Convention? Here are the top ten reasons for getting an Inventory ahead of time.
Press reports reveal that asbestos-containing materials have been detected on a number of recent newbuilds, despite the SOLAS Convention's total asbestos ban. In one case so much asbestos was found in thousands of gaskets and seals that the removal operation cost an estimated 10% of the purchase price. The problem is not just confined to newbuilds, either - as new supplies are purchased during operation there is still a risk of bringing asbestos-containing materials on board. Controlling subcontractor supply through an IHM based on Declaration of Conformity forms* is yet another way
of showing due diligence and helping ensure a robust asbestos-free procurement plan is in place.
Maintaining an IHM can also improve the health and safety of your ships' crews; not only does the IHM control the installation of hazardous materials on ships, it also promotes better hazard management and ensures crews are aware of any potential risks on board.
3-The right time
Ensuring that the requirement for an IHM is included in the specification for current new-build projects makes sense for a number of reasons.
Theconstruction of a ship is the best time to compile a comprehensive Inventory as there is complete information available on the materials being used. Also, the majority of ships under construction today will be existing ships by the time the Convention enters into force, at which stage they will have to develop an IHM. Compliance now could save you time, effort and additional expenditure at a later date.
Cargo owners, ports and environmental rating schemes are increasingly supportive of early compliance when assessing ships. The Clean Shipping Project and Business for Social Responsibility include the IHM in their model for increasing environmental awareness. Maintaining an Inventory also assists with meeting a number of required Tanker Management Self Assessment (TMSA) elements, potentially leading to commercial and cost benefits.
5-Beat the competition
Early compliance with the Convention requirements can put you one step ahead of your competitors, helping you demonstrate your company's commitment to best environmental practice and boost your reputation in the marketplace
The requirement for all ships to develop and maintain an IHM could be brought in as a voluntary requirement, possibly at short notice and ahead of other regulations in the Convention. Throughout 2010, the Senior Implementation Officer at IMO,a number of NGOs, and international shipowners' associations such as ICS, BIMCO and INTERTANKO all supported such a move, particularly for ships going for recycling.
An Inventory not only assists with in-house environmental management systems but provides measurable and achievable objectives for ISO14001 certified companies; maintaining an IHM demonstrates continual improvement.
When it comes to selling your ship, either to a new owner or a cash buyer,important documentation regarding potential hazards can be hard to find and in some cases can even be misleading.Holding an independently approved and verified IHM may, in certain circumstances, increase sale value;the Inventory not only records the presence,location andapproximate quantities of hazardous materials on board, but can equally prove that certain materials are absent, saving the need for last minute purchaser surveys at extra cost.
As well as aiding financial planning by promoting better awareness of the changing value of assets due to increasingly stringent dismantling requirements, the IHM can provide additional in-service benefits. Maintaining a record of all potential onboard hazards enables fleet-wide long-term liability planning, allowing you to identify all ships on which a hazard is present and your potential total liability for its removal or replacement.
And last but not least, maintaining an IHM is the first step towards safer
and more environmentally sound decommissioning of your ship at the end of her life, helping your chosen facility to formulate a Ship Recycling Plan.
This article is an extract from Lloyd's ''Shipping And The Environment'' issue 02/Spring 2011