Guidance on the Inventory of Hazardous Materials
Background
The principle that ships sold for recycling should carry an inventory of potentially hazardous materials contained in their structure, equipment and stores was first debated during the development of the Industry Code of Practice on Ship Recycling, and a list of potentially hazardous materials as well as a model inventory detailing type of material, location and approximate quantity was included in the published document.
This inventory and list developed by industry was further developed in the IMO Guidelines on Ship Recycling. Since then it has become an important principle in the draft International Convention for the Safe and Environmentally Sound Recycling of Ships currently being developed by IMO.
The Industry Working Group on Ship Recycling has identified the completion of Inventories as an action Shipowners could fulfil in the interim period prior to entry into force of the IMO Convention, and it is therefore included it in the Interim Measures for Shipowners Intending to Sell Ships for Recycling.
At present draft regulations and guidance exist for the Inventory within the draft Convention, though this material has not yet been finalised and will most likely be subject to amendment in the future.
However, this is not felt to be an impediment to the completion of inventories and many owners have already undertaken such action for ships in their fleets. Therefore, to facilitate further development of inventories in line with the likely provisions of the Convention, relevant sections of the draft IMO text along with explanatory notes have been included on this website as guidance material for interested shipowners. The site will be updated in light of further work at IMO as well as relevant industry experience.
The material liked to the notes below has been selected from documents submitted to the Marine Environment Protection Committee of IMO either on grounds that it is unlikely to significantly change, thereby reflecting the eventual provisions of the Convention in respect of Inventories, or that the material is felt to indicate a level of detail necessary for the production of accurate and useful inventories.
Classification Societies
It should be noted that Classification Societies already offer services to owners with respect to “Green Passports” and Inventories of Hazardous Materials and it is recommended that these options be fully considered by owners seeking to complete Inventories for their vessels, taking into account the guidance on this website.
Regulation 5 [1]
Regulation 5 of the draft convention establishes requirements for the Inventory of Hazardous Materials. It is unlikely that the text of this regulation will change before adoption of the Convention in April 2009, and therefore the three-part Inventory described in its provisions is that which owners should seek to complete prior to delivery to a recycling facility.
Part one of the Inventory should be completed and maintained for ships throughout their operational life and prior to delivery, parts two and three should only be completed prior to delivery to the recycling facility.
With regard to the provision concerning new and existing ships, members are advised that since the industry measures are recommended for the interim period prior to entry into force of the convention, only the existing ships provisions should be taken into account as all newly built ships in the interim period will, by default, be existing ships under the regulatory regime.
Tables A and B refer to this Regulation and further notes are provided in the appropriate place.
Table A [2]
This table is taken from draft guidance developed by Japan and Germany presently under consideration by the group. It details materials controlled under a number of international regulations that should be detailed in part one of the Inventory of Hazardous Materials.
Table B [3]
This table is also taken from the draft guidance referred to in the notes to Table A. The list serves as a guide to those materials that should be detailed in parts two and three of the inventory on the ships final voyage for delivery to the recycling facility.
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[1] Source: MEPC 56/3 – Report of the Intersessional Meeting of the Working Group on Ship Recycling
[2] Source: MEPC56/3/2 – Draft Guidelines for the development of the Inventory of Hazardous Materials, Annex Table A
[3] Source: MEPC56/3/2 – Draft Guidelines for the development of the Inventory of Hazardous Materials, Annex Table C
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