By: Basujit Chakravarty - Product Director - Procurement
With an increased focus on environment and sustainability, there are currently two regulations that govern the requirements for safe and environmentally sound ship recycling:
Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC), which will enter into force in June 2025.
The EU Regulation on Ship Recycling (EU) No. 1257/2013 (EU SRR), which has been in force since 31 December 2020.
Both regulations aim to ensure that when ships are recycled, they do not pose any risk to health, safety, and the environment. These regulations are aimed at the fact that ships contain hazardous materials such as asbestos, ozone-depleting substances, heavy metals, etc. which may pose as a threat to the crews’ health, safety and to the environment during a ship recycling operation.
HKC is applicable to ships operating in the marine environment, which are equal to and above 500 GT and focuses on two vital points Inventory of hazardous materials (IHM, 13 items) and Authorization of ship recycling facilities.
EU SRR is applicable to ships, operating in the marine environment, which are EU/EEA/UK flagged and 3rd party flagged vessels, visiting European ports or anchorages, equal to and above 500 GT. The EU SRR focus area is also Inventory of hazardous materials (IHM, 15 items) but specifically for a European list of approved ship recycling facilities.
As part of the above, it is mandatory for the vessels that fall under the above regulations to maintain a list of hazardous materials which we know of as ‘Inventory of Hazardous Materials’ or ‘IHM.’ The IHM quantifies and locates hazardous materials onboard ships as per the defined lists in the regulations.
Understanding the IHM regulation:
Part I: Hazardous materials contained in the ship’s structure or equipment
Part II: Operationally generated wastes
Part III: Stores
The IHM Part I is prepared during the ship's construction or while the vessel is in operation. For most ships already in operation before the regulation's enforcement came into force, hazmat experts must be contracted to analyze the materials in the structure. The IHM Part II and III are only required to be prepared once the ship is sent for recycling based on the generated waste and stores onboard the ship at the time of recycling.
The IHM Part I report is not a one-time thing. As part of the vessel’s operation, this needs to be maintained all the time with the latest information that is a part of day-to-day operations.
Such updates include being able to identify new IHM relevant items that are being supplied to the vessels, replacement of spare parts that get installed on ship’s machinery or rotation of components as part of the maintenance activities carried out onboard and part of the procurement process for such items and services to get the necessary Supplier Declaration of Conformity and Material Declarations
Many in the industry have tried to solve this by either having dedicated teams to work on maintaining IHM or by outsourcing it to dedicated companies in the industry. This leads to additional resources, costs and huge manual overhead.
Even with additional resources and outsourcing seafarers still face the task of having to maintain this information manually, have correspondence with other parties and then as part of the maintenance program ensure they have updated and moved the certificates required correctly into different files or folders.
The IHM maintenance needs to consider the consumption of spare parts for maintenance, the procurement process for obtaining the necessary declarations from suppliers along and at its very core it is about being able to maintain the master data of items in a centralized and standardized manner.
Implementation of that across the entire workflow is paramount to be able to successfully maintain this information in an updated manner without needing manual updates, and for the seafarers to be able to continue their actual work and yet be able to maintain such regulatory requirements in place. At JiBe, these are the kind of problems we create solutions for. At the root of it, this starts with having a completely interconnected ERP along with standardization of data across the installed vessel set across multiple customers, through our UpWind platform. Along UpWind, our Yamba.ai delivers recommendations related to which items should be IHM, or be able to get the relevant certificates and hazardous material content directly from suppliers as part of the procurement process and most importantly keep track of all spare part changes on machinery as part of maintenance in a seamless process are some examples where JiBe approaches how to solve this problem.
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