Rogge inventory of hazardous materials the hazmat expert criteria and acceptance

Inventory of Hazardous Materials The HazMat Expert – Criteria and Acceptance 2013-04-09

Introduction International Law IMO Hong Kong Convention (HKC), SOLAS, MARPOL, EU Increasing risk concerns Material Declaration and Suppliers Declaration of Conformity Maintenance of Inventory of Hazardous Materials (IHM) Ship Recycling Facility standards Description: IMO developed “International Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships”. Adopted in 2009; addressed Hazardous Materials have to be documented in IHM. Although prohibited in SOLAS and MARPOL, asbestos and ozone depleting substances are still in use during ship’s operation and even for new buildings.

Legal Framework Hong Kong Convention (SR/CONF/45) Regulation 5 – Inventory of Hazardous Materials 1. Each new ship shall have on board an Inventory of Hazardous Materials [...]

2. Existing ships shall comply as far as practicable [...] For existing ships a plan shall be prepared describing the visual/sampling check by which the Inventory of Hazardous Materials is developed, taking into account the guidelines developed by the Organization [...]

3. Part I of the Inventory of Hazardous Materials shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing Hazardous Materials listed in Appendix 2 and relevant changes in ship structure and equipment, taking into account the guidelines developed by the Organization

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Legal Framework IHM Guidelines (Res. MEPC 197(62)) 4.2 Development of Part I of the Inventory for existing ships [...] 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.

APPENDIX 5 – EXAMPLE OF THE DEVELOPMENT PROCESS FOR PART I OF THE INVENTORY FOR EXISTING SHIPS 1. Introduction In order to develop Part I of the Inventory of Hazardous Materials for existing ships, documents of the individual ship as well as the knowledge and experience of specialist personnel (experts) is required.

HazMat Experts | 2013-04-15 | No. 4

IHM Business – HazMat Report Analysis HazMat Analysis of 81 Certified Reports Number of samples per HazMat

97

405

92

1232

5638

Total sample number: 2826 Asbestos

PCB

ODS

Organotin

Heavy metal

IHM Business – HazMat Report Analysis

Number of Samples

HazMat Analysis of 81 Certified Reports average sample number per HazMat Expert *) 200 Heavy Metals Organotin ODS PCB Asbestos

150 100 50 0 G(5)

E(27)

D(9)

F(12)

C(9)

HazMat Experts *) more than 3 reports per expert

B(12)

O(3)

IHM Business – HazMat Report Analysis HazMat Analysis of 81 Certified Reports comparison of positive sample results between new buildings and ships in operation

8,0 7,0 6,0 5,0 4,0 3,0 2,0 1,0 0,0 NB Asbestos

PCB

SiO ODS

Orgaotin

Heavy Metal

IHM Business – HazMat Report Analysis Different HazMat Reports in Quality Main reasons?

 Different expertise level  some are not much experienced  some work in their own way

 Different knowledge and training backgrounds on IHM preparations  not all experts got an IHM preparation training  not capable of taking representative number of samples

 Different laboratory methods  some experts are working with non-accredited labs  some labs do not perform analysis in comparable methods to the ones in the Guidelines

GL HazMat Training and Approval Scheme Experts (Personal)

4 day course

Legal Entity (Org.)

Approval Audit or

Laboratory (Org.)

Approval Audit

extension of existing ISO 9001 certificate Witnessing In style of ISO 17024

In style of ISO 9001/ ISO 17020

In style of ISO 17025/ MEPC 197(62)

GL HazMat Training and Approval Scheme Continuous Improvement

20 or 200 samples ?

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Newsletter (GL)

Refresher Course (GL)

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GL HazMat Training and Approval Scheme IHM Green Server – a Web Based Software Application Web page title http://GreenServer/GS

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GL HazMat Training and Approval Scheme 4 Day Seminar for GL Approved HazMat Experts Aim:       

Familiarisation with IMO Hong Kong Convention Studying of the comprehensive preparation process of IHM Demonstrating practical work to help preparation of IHM Verification of gained expertise ( test and a certificate) Sharing knowledge and experiences Provision of best practice methods Establishing a global Hazmat Expert Network

Suitable professions:

Chemical, Environmental, Mech. Engineers, Naval Architects, HazMat Experts, Technical Experts of Shipping companies, consultants or local authorities dealing with the shipping industry

GL HazMat Training and Approval Scheme On Board Project Witnessing of the GL-Approved HazMat Experts: • • • • • • • • •

Check of the preparatory work (VSCP, structuring of ship, Assumptions, selection of type of sampling (visual/physical) Witnessing of onboard work (Safety precautions, tools used, documentation ….)

Finalization of IHM (Interpretation of samples, calculations, documentation / filing of documents, preparation and content of report) Upon order of certification no additional costs are incurred as additional time for witnessing onboard is included in seminar fees.

Without IHM certification order additional fees applies, as all related working steps conducted for IHM preparation are to be checked

GL HazMat Training and Approval Scheme HazMat Company Approval for examination of provision of “appropriate management system” incl.: • Documented Management System (Policy, Manual, Procedures) • Audit carried out in the style of ISO 9001 • Contracted parties/ laboratories • Roles & responsibilities • Infrastructure • Personal Protective Equipment (PPE) • Reporting / network • Certificate for ISO 9001 advantageous but not mandatory – audit focusses on HazMat related items *) The Hazmat company approval: as a pre condition that at least one fully GL approved Hazmat Expert is available.

GL HazMat Training and Approval Scheme HazMat Laboratory Approval for examination of provision of “appropriate management system” incl.: • Requirements in style of ISO/IEC 17025 • Testing methods and equipment (acc. MEPC 197 (62) • Validation of testing methods • Qualification of personnel • Infrastructure and equipment • Calibration of testing equipment • Sampling Management • Reporting *) The HazMat Laboratory Approval is independent of the HazMat Company Approval.

Quality Criteria for HazMat Experts Today: • Shipowners use their own personnel or • third-party experts on the Inventory projects.

• Potential Conflict: • The Inventories of Hazardous Materials may differ in quality and quantity • State-of-the-art is not considered in a systematical way Need: • Requirements for - Persons - HazMat Expert Companies (Organisations) - Laboratories (Accreditation) on an international level. This to prevent cases of conflict and gives certainty for the parties to be prepared for compliance with upcoming Hong Kong Convention.

Quality Criteria for HazMat Experts Proposal for Minimum Knowledge of HazMat Experts: Laws and regulations related to Hong Kong Convention and the Inventory • Knowledge of ship structure and equipments • Details on the requirements for the Inventory preparation of Existing Ships • Information on the hazardous materials mentioned in Table A and Table B • Theoretical and practical knowledge on how to take samples on board ships • Health and Safety – Rules for safe sampling/ risk based preparation • Role of the stakeholders with following tasks • • • • •

How to prepare a VSCP Practical exercise on board the ship for sample taking How to get samples analyzed How to calculate the hazardous material amounts based on the analyzed results How to prepare IHM in its standard format.

•

How to report the results

*) Recommended: Hazardous Materials Removal Management

Quality Criteria for HazMat Experts Hazmat Report – Standard Structure

Quality Criteria for HazMat Experts Certification and Reporting Following Successful Completion of Initial Survey  HazMat Expert prepares IHM and HazMat Report  GL checks the IHM and content of the HazMat Report based on some criteria Following Successful Completion of IHM and HazMat Report Check  Issuance of the International Certificate on Inventory of Hazardous Materials – ICIHM – (Statement of compliance)  Preparation of the GL Report  Certificate is valid for 5 years.  Certificate is sent to the Technical Ship Manager / Owner

Quality Criteria for HazMat Experts Hazmat Report – Checklist

Thank you for the attention!

Contact Details: GL SO-QH Global Practice Ship Recycling Brooktorkai 18 D-20457 Hamburg Phone: +49 40 36 149 7786 Fax.: +49 40 36 149 2900 shiprecycling@gl-group.com http://www.gl-group.com/shiprecycling