RESOLUTION MEPC.379(80)

(adopted on 7 July 2023)

 

2023 GUIDELINES FOR THE DEVELOPMENT OF THE INVENTORY OF HAZARDOUS MATERIALS

 

THE MARINE ENVIRONMENT PROTECTION COMMITTEE,

 

RECALLING Article 38(a) of the Convention on the International Maritime Organization concerning the functions of the Marine Environment Protection Committee conferred upon it by international conventions for the prevention and control of marine pollution from ships,

 

RECALLING ALSO that the International Conference on the Safe and Environmentally Sound Recycling of Ships held in May 2009 adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the Hong Kong Convention) together with six Conference resolutions,

 

NOTING that regulations 5.1 and 5.2 of the annex to the Hong Kong Convention require that ships shall have on board an Inventory of Hazardous Materials which shall be prepared and verified taking into account guidelines, including any threshold values and exemptions contained in those guidelines, developed by the Organization,

 

NOTING ALSO that, at its sixty-second session, it adopted, by resolution MEPC.197(62), the Guidelines for the development of the Inventory of Hazardous Materials,

 

NOTING FURTHER that, at its sixty-eighth session, it adopted, by resolution MEPC.269(68), the 2015 Guidelines for the development of the Inventory of Hazardous Materials, which superseded the Guidelines adopted through resolution MEPC.197(62), to improve the guidance on threshold values and exemptions,

 

RECOGNIZING the need for a consequential revision of the Guidelines associated with amendments to Annex 1 to the International Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001 (AFS Convention) (resolution MEPC.331(76)), which introduced controls on cybutryne and entered into force on 1 January 2023,

 

HAVING CONSIDERED, at its eightieth session, the recommendation made by the Sub-Committee on Pollution Prevention and Response at its tenth session,

 

1          ADOPTS the 2023 Guidelines for the development of the Inventory of Hazardous Materials as set out in the annex to this resolution;

 

2          INVITES Member Governments to apply the 2023 Guidelines as soon as possible, or at the latest when the Convention enters into force;

 

3          AGREES to keep the 2023 Guidelines under review in the light of experience gained with their application;

 

4          AGREES ALSO that the 2023 Guidelines supersede the guidelines adopted by resolution MEPC.269(68).

 

ANNEX

 

2023 GUIDELINES FOR THE DEVELOPMENT OF THE INVENTORY OF HAZARDOUS MATERIALS

 

1          INTRODUCTION

 

1.1       Objectives

 

These guidelines provide recommendations for developing the Inventory of Hazardous Materials (hereinafter referred to as "the Inventory" or "the IHM") to assist compliance with regulation 5 (Inventory of Hazardous Materials) of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (hereinafter referred to as "the Convention").

 

1.2       Application

 

These guidelines have been developed to provide relevant stakeholders (e.g. shipbuilders, equipment suppliers, repairers, shipowners and ship management companies) with the essential requirements for the practical and logical development of the Inventory.

 

1.3       Objectives

 

The objectives of the Inventory are to provide ship-specific information on the actual hazardous materials present on board, in order to protect health and safety and to prevent environmental pollution at ship recycling facilities. This information will be used by the ship recycling facilities to decide how to manage the types and amounts of materials identified in the Inventory of Hazardous Materials (regulation 9 of the Convention).

 

2          DEFINITIONS

 

The terms used in these guidelines have the same meaning as those defined in the Convention, with the following additional definitions which apply to these guidelines only.

 

2.1       Exemption (as referred to in regulation 5 of the Convention) means materials specified in paragraph 3.3 in these guidelines that do not need to be listed on the IHM, even if such materials or items exceed the IHM threshold values.

 

2.2       Fixed means the conditions that equipment or materials are securely fitted with the ship, such as by welding or with bolts, riveted or cemented, and used at their position, including electrical cables and gaskets.

 

2.3       Homogeneous material means a material of uniform composition throughout that cannot be mechanically disjointed into different materials, meaning that the materials cannot, in principle, be separated by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.

 

2.4       Loosely fitted equipment means equipment or materials present on board the ship by the conditions other than "fixed", such as fire extinguishers, distress flares and lifebuoys.

 

2.5       Product means machinery, equipment, materials and applied coatings on board a ship.

 

2.6       Supplier means a company which provides products; it may be a manufacturer, trader or agency.

 

2.7       Supply chain means the series of entities involved in the supply and purchase of materials and goods, from raw materials to final product.

 

2.8       Threshold value is defined as the concentration value in homogeneous materials.

 

3          REQUIREMENTS FOR THE INVENTORY

 

3.1       Scope of the Inventory

 

The Inventory consists of:

 

Part I: Materials contained in ship structure or equipment;

 

Part II: Operationally generated wastes; and

 

Part III: Stores.

 

3.2       Materials to be listed in the Inventory

 

3.2.1    Appendix 1 of these guidelines (Items to be listed in the Inventory of Hazardous Materials), provides information on the hazardous materials that may be found on board a ship. Materials set out in appendix 1 should be listed in the Inventory. Each item in appendix 1 of these guidelines is classified under tables A, B, C or D, according to its properties:

 

.1       table A comprises the materials listed in appendix 1 of the Convention;

 

.2       table B comprises the materials listed in appendix 2 of the Convention;

 

.3       table C (Potentially hazardous items) comprises items which are potentially hazardous to the environment and human health at ship recycling facilities; and

 

.4       table D (Regular consumable goods potentially containing hazardous materials) comprises goods which are not integral to a ship and are unlikely to be dismantled or treated at a ship recycling facility.

 

3.2.2    Tables A and B correspond to part I of the Inventory. Table C corresponds to parts II and III and table D corresponds to part III.

 

3.2.3    For loosely fitted equipment, there is no need to list this in part I of the Inventory. Such equipment which remains on board when the ship is recycled should be listed in part III.

 

3.2.4    Those batteries containing lead acid or other hazardous materials that are fixed in place should be listed in part I of the Inventory. Batteries that are loosely fitted, which include consumer batteries and batteries in stores, should be listed in part III of the Inventory.

 

3.2.5    Similar materials or items that contain hazardous materials that potentially exceed the threshold value can be listed together (not individually) on the IHM with their general location and approximate amount specified there (hereinafter referred to as "bulk listing"). An example of how to list those materials and items is shown in row 3 of table 1 of appendix 3.

 

3.3       Exemptions – Materials not required to be listed in the Inventory

 

3.3.1    Materials listed in table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.

 

3.3.2    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.

 

3.4       Standard format of the Inventory of Hazardous Materials

 

The Inventory should be developed on the basis of the standard format set out in appendix 2 of these guidelines: Standard format of the Inventory of Hazardous Materials. Examples of how to complete the Inventory are provided for guidance purposes only.

 

3.5       Revision of threshold values

 

Revised threshold values in tables A and B of appendix 1 should be used for IHMs developed or updated after the adoption of the revised values and need not be applied to existing IHMs and IHMs under development. However, when materials are added to the IHM, such as during maintenance, the revised threshold values should be applied and recorded in the IHM.

 

4          REQUIREMENTS FOR DEVELOPMENT OF THE INVENTORY

 

4.1       Development of part I of the Inventory for new ships¹

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¹     In ascertaining whether a ship is a "new ship" or an "existing ship" according to the Convention, the term "a similar stage of construction" in regulation 1.4.2 of the annex to the Convention means the stage at which:

.1   construction identifiable with a specific ship begins; and

.2   assembly of that ship has commenced comprising at least 50 tonnes or 1% of the estimated mass of all structural material, whichever is less.

 

4.1.1    Part I of the Inventory for new ships should be developed at the design and construction stage.

 

4.1.2    Checking of materials listed in table A

 

During the development of the Inventory (part I), the presence of materials listed in table A of appendix 1 should be checked and confirmed; the quantity and location of table A materials should be listed in part I of the Inventory. If such materials are used in compliance with the Convention, they should be listed in part I of the Inventory. Any spare parts containing materials listed in table A are required to be listed in part III of the Inventory.

 

4.1.3    Checking of materials listed in table B

 

If materials listed in table B of appendix 1 are present in products above the threshold values provided in table B, the quantity and location of the products and the contents of the materials present in them should be listed in part I of the Inventory. Any spare parts containing materials listed in table B are required to be listed in part III of the Inventory.

 

4.1.4    Process for checking of materials

 

The checking of materials as provided in paragraphs 4.1.2 and 4.1.3 above should be based on the Material Declaration furnished by the suppliers in the shipbuilding supply chain (e.g. equipment suppliers, parts suppliers, material suppliers).

 

4.2       Development of part I of the Inventory for existing ships

 

4.2.1    In order to achieve comparable results for existing ships with respect to part I of the Inventory, the following procedure should be followed:

 

 .1      collection of necessary information;

 .2      assessment of collected information;

 .3      preparation of visual/sampling check plan;

 .4      onboard visual check and sampling check; and

 .5      preparation of part I of the Inventory and related documentation.

 

4.2.2    The determination of hazardous materials present on board existing ships should, as far as practicable, be conducted as prescribed for new ships, including the procedures described in sections 6 and 7 of these guidelines. Alternatively, the procedures described in this section may be applied for existing ships, but these procedures should not be used for any new installation resulting from the conversion or repair of existing ships after the initial preparation of the Inventory.

 

4.2.3    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).

 

4.2.4    Reference is made to appendix 4 (Flow diagram for developing part I of the Inventory for existing ships) and appendix 5 (Example of development process for part I of the Inventory for existing ships).

 

4.2.5    Collection of necessary information (step 1)

 

The shipowner should identify, research, request and procure all reasonably available documentation regarding the ship. Information that will be useful includes maintenance, conversion and repair documents; certificates, manuals, ship's plans, drawings and technical specifications; product information data sheets (such as Material Declarations); and hazardous material inventories or recycling information from sister ships. Potential sources of information could include previous shipowners, the shipbuilder, historical societies, classification society records and ship recycling facilities with experience working with similar ships.

 

4.2.6    Assessment of collected information (step 2)

 

The information collected in step 1 above should be assessed. The assessment should cover all materials listed in table A of appendix 1; materials listed in table B should be assessed as far as practicable. The results of the assessment should be reflected in the visual/sampling check plan.

 

4.2.7    Preparation of visual/sampling check plan (step 3)

 

4.2.7.1  To specify the materials listed in appendix 1 of these guidelines, a visual/sampling check plan should be prepared taking into account the collated information and any appropriate expertise. The visual/sampling check plan should be based on the following three lists:

 

.1       List of equipment, system and/or area for visual check (any equipment, system and/or area specified regarding the presence of the materials listed in appendix 1 by document analysis should be entered in the List of equipment, system and/or area for visual check);

 

.2       List of equipment, system and/or area for sampling check (any equipment, system and/or area which cannot be specified regarding the presence of the materials listed in appendix 1 by document or visual analysis should be entered in the List of equipment, system and/or area as requiring sampling check. A sampling check is the taking of samples to identify the presence or absence of hazardous material contained in the equipment, systems and/or areas, by suitable and generally accepted methods such as laboratory analysis); and

 

.3       List of equipment, system and/or area classed as "potentially containing hazardous material" (any equipment, system and/or area which cannot be specified regarding the presence of the materials listed in appendix 1 by document analysis may be entered in the List of equipment, system and/or area classed as "potentially containing hazardous material" without the sampling check. The prerequisite for this classification is a comprehensible justification such as the impossibility of conducting sampling without compromising the safety of the ship and its operational efficiency).

 

4.2.7.2  Visual/sampling checkpoints should be all points where:

 

.1       the presence of materials to be considered for the Inventory part I as listed in appendix 1 is likely;

 

.2       the documentation is not specific; or

 

.3       materials of uncertain composition were used.

 

4.2.8    Onboard visual/sampling check (step 4)

 

4.2.8.1  The onboard visual/sampling check should be carried out in accordance with the visual/sampling check plan. When a sampling check is carried out, samples should be taken and the sample points should be clearly marked on the ship plan and the sample results should be referenced. Materials of the same kind may be sampled in a representative manner. Such materials are to be checked to ensure that they are of the same kind. The sampling check should be carried out drawing upon expert assistance.

 

4.2.8.2  Any uncertainty regarding the presence of hazardous materials should be clarified by a visual/sampling check. Checkpoints should be documented in the ship's plan and may be supported by photographs.

 

4.2.8.3  If the equipment, system and/or area of the ship are not accessible for a visual check or sampling check, they should be classified as "potentially containing hazardous material". The prerequisite for such classification should be the same prerequisite as in section 4.2.7. Any equipment, system and/or area classed as "potentially containing Hazardous Material" may be investigated or subjected to a sampling check at the request of the shipowner during a later survey (e.g. during repair, refit or conversion).

 

4.2.9    Preparation of part I of the Inventory and related documentation (step 5)

 

If any equipment, system and/or area is classed as either "containing hazardous material" or "potentially containing hazardous material", their approximate quantity and location should be listed in part I of the Inventory. These two categories should be indicated separately in the "Remarks" column of the Inventory.

 

4.2.10 Testing methods

 

4.2.10.1  Samples may be tested by a variety of methods. "Indicative" or "field tests" may be used when:

 

.1       the likelihood of a hazard is high;

 

.2       the test is expected to indicate that the hazard exists; and

 

.3       the sample is being tested by "specific testing" to show that the hazard is present.

 

4.2.10.2  Indicative or field tests are quick, inexpensive and useful on board the ship or on-site, but they cannot be accurately reproduced or repeated, and cannot identify the hazard specifically, and therefore cannot be relied upon except as "indicators".

 

4.2.10.3  In all other cases, and in order to avoid dispute, "specific testing" should be used. Specific tests are repeatable, reliable and can demonstrate definitively whether a hazard exists or not. They will also provide a known type of the hazard. The methods indicated are found qualitative and quantitative appropriate and only testing methods to the same effect can be used. Specific tests are to be carried out by a suitably accredited laboratory, working to international standards² or equivalent, which will provide a written report that can be relied upon by all parties.

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²     For example ISO 17025

 

4.2.10.4  Specific test methods for appendix 1 materials are provided in appendix 9.

 

4.2.11 Diagram of the location of hazardous materials on board a ship

 

Preparation of a diagram showing the location of the materials listed in table A is recommended in order to help ship recycling facilities gain a visual understanding of the Inventory.

 

4.3       Maintaining and updating part I of the Inventory during operations

 

4.3.1    Part I of the Inventory should be appropriately maintained and updated, especially after any repair or conversion or sale of a ship.

 

4.3.2    Updating of part I of the Inventory in the event of new installation

 

If any machinery or equipment is added to, removed or replaced or the hull coating is renewed, part I of the Inventory should be updated according to the requirements for new ships as stipulated in paragraphs 4.1.2 to 4.1.4. Updating is not required if identical parts or coatings are installed or applied.

 

4.3.3    Continuity of part I of the Inventory

 

Part I of the Inventory should belong to the ship and the continuity and conformity of the information it contains should be confirmed, especially if the flag, owner or operator of the ship changes.

 

4.4       Development of part II of the Inventory (operationally generated waste)

 

4.4.1    Once the decision to recycle a ship has been taken, part II of the Inventory should be developed before the final survey, taking into account that a ship destined to be recycled shall conduct operations in the period prior to entering the ship recycling facility in a manner that minimizes the amount of cargo residues, fuel oil and wastes remaining on board (regulation 8.2 of the Convention).

 

4.4.2    Operationally generated wastes to be listed in the Inventory

 

If the wastes listed in part II of the Inventory provided in table C (Potentially hazardous items) of appendix 1 are intended for delivery with the ship to a ship recycling facility, the quantity of the operationally generated wastes should be estimated and their approximate quantities and locations should be listed in part II of the Inventory.

 

4.5       Development of part III of the Inventory (stores)

 

4.5.1    Once the decision to recycle has been taken, part III of the Inventory should be developed before the final survey, taking into account the fact that a ship destined to be recycled shall minimize the wastes remaining on board (regulation 8.2 of the Convention). Each item listed in part III should correspond to the ship's operations during its last voyage.

 

4.5.2    Stores to be listed in the Inventory

 

If the stores to be listed in part III of the Inventory provided in table C of appendix 1 are to be delivered with the ship to a ship recycling facility, the unit (e.g. capacity of cans and cylinders), quantity and location of the stores should be listed in part III of the Inventory.

 

4.5.3    Liquids and gases sealed in ship's machinery and equipment to be listed in the Inventory

 

If any liquids and gases listed in table C of appendix 1 are integral in machinery and equipment on board a ship, their approximate quantity and location should be listed in part III of the Inventory. However, small amounts of lubricating oil, anti-seize compounds and grease which are applied to or injected into machinery and equipment to maintain normal performance do not fall within the scope of this provision. For subsequent completion of part III of the Inventory during the recycling preparation processes, the quantity of liquids and gases listed in table C of appendix 1 required for normal operation, including the related pipe system volumes, should be prepared and documented at the design and construction stage. This information belongs to the ship, and continuity of this information should be maintained if the flag, owner or operator of the ship changes.

 

4.5.4    Regular consumable goods to be listed in the Inventory

 

Regular consumable goods, as provided in table D of appendix 1 should not be listed in part I or part II but should be listed in part III of the Inventory if they are to be delivered with the ship to a ship recycling facility. A general description including the name of item (e.g. TV set), manufacturer, quantity and location should be entered in part III of the Inventory. The check on materials provided for in paragraphs 4.1.2 and 4.1.3 of these guidelines does not apply to regular consumable goods.

 

4.6       Description of location of hazardous materials on board

 

The locations of hazardous materials on board should be described and identified using the name of location (e.g. second floor of engine-room, bridge DK, APT, No.1 cargo tank, frame number) given in the plans (e.g. general arrangement, fire and safety plan, machinery arrangement or tank arrangement).

 

4.7       Description of approximate quantity of hazardous materials

 

In order to identify the approximate quantity of hazardous materials, the standard unit used for hazardous materials should be kg, unless other units (e.g. m³ for materials of liquid or gases, m² for materials used in floors or walls) are considered more appropriate. An approximate quantity should be rounded up to at least two significant figures.

 

5          REQUIREMENTS FOR ASCERTAINING THE CONFORMITY OF THE INVENTORY

 

5.1       Design and construction stage

 

The conformity of part I of the Inventory at the design and construction stage should be ascertained by reference to the collected Supplier's Declaration of Conformity described in section 7 and the related Material Declarations collected from suppliers.

 

5.2       Operational stage

 

Shipowners should implement the following measures in order to ensure the conformity of part I of the Inventory:

 

.1       to designate a person as responsible for maintaining and updating the Inventory (the designated person may be employed ashore or on board);

 

.2       the designated person, in order to implement paragraph 4.3.2, should establish and supervise a system to ensure the necessary updating of the Inventory in the event of new installation;

 

.3       to maintain the Inventory including dates of changes or new deleted entries and the signature of the designated person; and

 

.4       to provide related documents as required for the survey or sale of the ship.

 

6          MATERIAL DECLARATION

 

6.1       General

 

Suppliers to the shipbuilding industry should identify and declare whether or not the materials listed in table A or table B are present above the threshold value specified in appendix 1 of these guidelines. However, this provision does not apply to chemicals which do not constitute a part of the finished product.

 

6.2       Information required in the declaration

 

6.2.1    At a minimum the following information is required in the Material Declaration:

 

.1       date of declaration;

 

.2       Material Declaration identification number;

 

.3       supplier's name;

 

.4       product name (common product name or name used by manufacturer);

 

.5       product number (for identification by manufacturer);

 

.6       declaration of whether or not the materials listed in table A and table B of appendix 1 of these guidelines are present in the product above the threshold value stipulated in appendix 1 of these guidelines; and

 

.7       mass of each constituent material listed in table A and/or table B of appendix 1 of these guidelines if present above threshold value.

 

6.2.2    An example of the Material Declaration is shown in appendix 6.

 

7          SUPPLIER'S DECLARATION OF CONFORMITY

 

7.1       Purpose and scope

 

7.1.1    The purpose of the Supplier's Declaration of Conformity is to provide assurance that the