Clasification Society Rulefinder 2016 - Version 9.25
Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee - Resolution MEPC.197(62) – 2011 Guidelines for the Development of the Inventory of Hazardous Materials – (Adopted on 15 July 2011) - Annex – 2011 Guidelines for the Development of the Inventory of Hazardous Materials - 4 Requirements for development of the Inventory - 4.2 Development of Part I of the Inventory for existing ships

4.2 Development of Part I of the Inventory for existing ships

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

The procedure is based on the following steps:

  • .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.

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 section 6 and 7 of these Guidelines. Alternatively the procedures described in subsection 4.2 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.

The procedures described in subsection 4.2 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.

Please refer to appendix 4: "Flow diagram for developing Part I of the Inventory for existing ships"; and appendix 5: "Typical example of development process for Part I of the Inventory for existing ships".

  4.2.1 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 ship builder, historical societies, classification society records, and ship recycling facilities with experience working with similar ships.

  4.2.2 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 listed as far as practicable. The results of the assessment should be reflected in the visual/sampling check plan.

  4.2.3 Preparation of visual/sampling check plan (Step 3)

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 based on the following three lists:

  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);
  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
  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).

Visual/sampling checkpoints should be all points where:

  the presence of materials to be considered for the Inventory Part I as listed in appendix 1 is likely;
  the documentation is not specific; or
  materials of uncertain composition were used.

  4.2.4 Onboard visual/sampling check (Step 4)

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 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.

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.

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 4.2.3. 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).

  4.2.5 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 of Hazardous Materials.

  4.2.6 Testing methods

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

  • the likelihood of a hazard is high;
  • the test is expected to indicate that the hazard exists; and
  • the sample is being tested by "specific testing" to show that the hazard is present.

Indicative or field tests are quick, inexpensive and useful onboard 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".

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 standardsfootnote or equivalent, which will provide a written report that can be relied upon by all parties.

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

  4.2.7 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.


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