The maritime industry has seen dramatic changes in recent years due to new legislation and regulations concerned with reducing the industry’s environmental impact. This is set to continue as it develops its 'green credentials' and due to the ongoing marine environmental crisis which is increasing pressure upon maritime companies and global organisations to act.
The IMO adopted the Hong Kong International Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships in 2009. Its purpose is to ensure that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risk to the environment or human health and safety. In addition, the HKC was also aimed at providing guidance on the proper management of hazardous materials on board ships. Around the same time as these regulations were adopted, a series of new requirements focusing on the workers’ occupational health & safety and the environmental impact of the recycling industry were introduced. The EU also published its own ship recycling regulation in December 2013.
Under these regulations, there are a total of 15 types of regulated hazardous materials (HazMat). These regulations clarified that it is the responsibility of the supplier to provide Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) certifications.
As a result of this new and enhanced set of regulations, the following organizations and/or persons will need to engage with a Hazardous Material Testing service provider:
What you need to know about hazardous material testing
Sample testing may be subject to a variety of testing methods with different Limits of Detection (LoD). It is quite possible that an approved test result of the same material sample may be rejected by another certification body, classification society, or in worst cases, the client, simply because of a difference in the LoD's.
In order to avoid any potential disputes and a significant waste of time and money, "specific testing" should be used. These tests are repeatable, reliable and can demonstrate definitively whether a hazard exists or not. For instance, specific test methods for “Table A” materials (Asbestos/PCBs/ODS/Organotin) in the HKC should adopt the testing methods mentioned in Appendix 9 of IMO Guidelines for the Development of Inventory of Hazardous Materials (MEPC.269(68)). The tests should be carried out by a suitably qualified and accredited laboratory with reference to ISO/IEC 17025:2005. Additionally, the testing service provider must be recognized by the related class society.
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Whether you are a shipyard or supplier within the marine environment industry or alternatively, a Hazmat consultant/expert working on IHM we can help you navigate this legislation and together ensure the future prosperity and sustainability of the marine environment.
If you have any questions or comments please don't hesitate to contact us