Ihm Presentation

INVENTORY OF HAZARDOUS MATERIALS: REGULATIONS AND BEST PRACTICES 30-Sept-2020

IHM- REGULATION

Inventory of Hazardous Materials (IHM)  Purpose of IHM  Regulate waste management at recycling phase of vessel  Prevent exposure to Hazardous Materials for crew and recycling yard workers

 2 different types of IHM:  New build vessels  Existing vessels  biggest impact for Ship owners

 2 “different” types of Regulations/Guidelines  Hong Kong Convention (adopted in 2009), to be ratified yet  EU Regulation (entered into force in 2013) with deadlines set

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IHM- REGULATION

Inventory of Hazardous Materials (IHM)  Different deadlines set:  Newbuild vessels 30-12-2018  Existing vessels

 30-12-2020

 IHM (EU Regulation) requirements valid for:  All EU flagged vessels,  All third party vessels doing EU port calls and  All third party vessels dropping anchor at EU anchorages  Failing to obtain a valid IHM report after the deadline could result in

penalties and bans of entering EU ports!

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IHM- REGULATION

Extend of IHM – new build vessels  Starts at developing stage of construction  Collecting Material Declarations (MD) from suppliers  Collecting Supplier Documents of Compliance (SDoC)  Class involvement required to verify IHM survey report  Class (or Flag State) will issue “Statement of Compliance”  Responsibility of shipyard  To be updated every 5 year

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IHM- REGULATION

Extend of IHM – existing vessels  Should be done immdiately if vessel does not have IHM part 1 inventory  Desk research existing vessel data  Survey on board to take samples  Class involvement required to verify IHM survey  Class (or Flag State) will issue “Statement of Compliance”  Responsibility of owner  To be updated every 5 year

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IHM- REGULATION

IHM Survey details  Split up into 3 different parts (I and II/III)  Only Part I is required to comply to EU Regulations (Table A/B)  Part II and III required at recycling phase of vessel (Table B, C and D)

 Substances to be surveyed for Part I  Asbestos (ACM)  Polychlorinated Byphenyls (PCB)  Ozone Depleting Substances (ODS)  Antifouling (TBT)  Additional for EU Regulation: PFOS and HBCDD (flame retardants) (Perfluorooctane sulfonic acid & Brominated Flame Retardant) © Copyright MSC Mediterranean Shipping Company S.A.

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HAZARDOUS AND POTENTIALLY HAZARDOUS MATERIALS

• • • • • • • •

Asbestos Paint Plastic and Rubber materials Materials containing PCBs, PCTs, PBBb Refrigerants, fire-fighting media, blowing agents and other gases Chemicals in ship’s equipment/ machinery Electrical & electronic equipment Constructional materials

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IHM- REGULATION

IHM Part I Survey details  Visual/Sampling Check Plan (VSCP) as guiding document  Based on vessel information available  Witnessing by Class (not mandatory for all surveys)  Both VSCP and on board

 If no data available  verification via sampling required!

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IHM SAMPLES EXAMPLES

ACM Sample Gasket

PCB Sample door frame

ACM Sample Putty

PFOS Sample Aluminimum paint

ACM Sample Brake Lining

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IHM- OVERVIEW

• IHM surveys as per HK & EU requirement completed for all fleet vessels. • New Building vessels (9000TEU class) IHM survey performed as per EU

requirement since during delivery only HK requirement was met • For new takeover – second hand vessels IHM surveys is completed immediately on takeover • Important first steps have been in taken for the asbestos management. • Asbestos safety kit supplied to all vessels and will be delivered to all new takeover vessels immediately on takeover.

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IHM- OVERVIEW

• Material Declarations and statement of compliance from Vendors for IHM

compliance • Removal of lose asbestos and cleaning after IHM part 1 surveys on existing vessels in progress and prioritized basis quantity and risk involved. • For existing vessels new statement of compliance are issued from RINA basis IHM surveys and all our vessels are now in full compliance with EU requirement in force from 31st Dec 2020. All NB vessels are already in compliance since delivery from NB yards.

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IHM MAINTENANCE

  • IHM maintenance is important part of this regulations and for this it is

essential that all supplies to our ships are monitored for hazardous material. The IHM inventory will be updated accordingly. • All suppliers are required to sign material declaration and confirmation for document of compliance so that this is being done at the source. • Non-compliance if any should be promptly reported to office and liability is placed on the supplier.

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IHM- MAINTENANCE

• It is company policy that all materials including gaskets as delivered on-

board are asbestos free and clause has been added in our purchase orders accordingly. • This is also part of our agreement with various shipyards and all major vendors are audited to confirm same. • Material declaration and suppliers declaration of conformity for material declaration management will be signed by each of the vendor ensuring data of material delivered on board is recorded.

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IHM- MAINTENANCE

IHM survey of all main vendors was performed to eliminate any possibility of delivery of asbestos based product to our vessels • IHM survey was carried out for EDR and MSC Global facilities in Sept -18. Observations were dealt with. • IHM survey of MSC Tech Durban facilities in Dec 2018 and observations were dealt with. • Repeat IHM survey on vessels where new scrubber and BWTS was installed, one ship from each of the shipyards involved in the project.

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IHM – ASBESTOS SAFETY KIT

Safety Kit• In order to improve the safety onboard while dealing with potential asbestos containing gaskets vessels are being provided with an Asbestos Safety Kit. • This kit is arranged from vendor Kiwa Oesterbaai who is also performing IHM surveys on board all MSC vessels. • The kit will be stored in safety locker under custody of C/O and used for the purpose it is provided. • Second engineer is appointed as the designated person for asbestos related issues with the supplies to vessel if any. © Copyright MSC Mediterranean Shipping Company S.A.

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IHM – ASBESTOS SAFETY KIT

Content of the safety kit are detailed as follows   • HEPA filter equipped vacuum cleaner • 10 spare dust bags for vacuum cleaner • Semi full face masks with P3 Filter • Tyvec disposable coveralls (size XXL) • Blue disposable shoe covers • Asbestos waste bags with printed warning labels • Asbestos waste bags, unlabeled • Work gloves • Duct tape • Asbestos warning stickers • Gloria hand pump (3 liter) filled with impregnation fluid © Copyright MSC Mediterranean Shipping Company S.A.

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IHM – ASBESTOS SAFETY KIT

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IHM – ASBESTOS SAFETY KIT

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IHM – ASBESTOS SAFETY KIT

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ASBESTOS MANAGEMENT -IHM

• Asbestos finding on board of vessels have a been registered and • • • •

categorized based on potential risk. High risk applications are being actively removed and cleaned via Kiwa Oesterbaai and third party contractors. All vessels have received an Asbestos Safety Kit. Superintendents are being trained about the risks of Asbestos and the proper usage of the Safety Kit. Changes in procurement requirements in order to ensure the vessels remain compliant and to avoid the risk of new asbestos applications being broad on board.

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ASBESTOS MANAGEMENT AND REMOVAL

Safety kit contents

Asbestos Kit in use Removal by contractor with active airsampling

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PSC READINESS- THE REGULATION COMES INTO FORCE FROM 31ST DEC 2020 FOR EU PORTS Basic information on IHM matter from PSC point of view. • Port State Control inspectors will ask the crew if a certified IHM report and Statement of

Compliance (SoC) issued by Class is available on board.  • Presence of an Asbestos Safety Kit (ASK) for incidental gasket removal • Proof of training for the dedicated crew who will use the asbestos safety kit. The

familirization and training should be performed on regular basis. • IHM maintenance – Copy of Material declaration and supplier’s declaration of conformity

for material declaration management © Copyright MSC Mediterranean Shipping Company S.A.

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BEST PRACTICES FOR CREW ONBOARD WITH REGARDS TO HANDLING AND REPORTING OF HAZARDOUS MATERIALS.

• Asbestos containing spares, commonly found on ships, cannot be used as

per MSC.Circ.1374 and 1379 prohibits the use of asbestos since 01-012011. When asbestos containing spares are present, removal by certified asbestos removal contractors will be required in order to comply to SOLAS. • Depending on the age of the vessel, some ACM can remain onboard in fixed installations but should be managed properly and has been clearly marked after initial survey.

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BEST PRACTICES FOR CREW ONBOARD WITH REGARDS TO HANDLING AND REPORTING OF HAZARDOUS MATERIALS.

 In-situ ACM, such as gaskets/joints/packings, can remain when properly managed (and depending on age of vessel). Only urgent repairs/maintenance works on these ACM should be done by a dedicated and trained crew, using the contents of the Asbestos safety kit. Waste from these works is to be packed and disposed off properly and a waste disposal document should be available and kept onboard as proof of proper waste management and for IHM maintenance.

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BEST PRACTICES FOR CREW ONBOARD WITH REGARDS TO HANDLING AND REPORTING OF HAZARDOUS MATERIALS.

Heavy Metals • Batteries or paints/coatings containing heavy metals do not cause a direct risk to the crew when kept intact. Maintenance works on paints such as using a flame cutter, grinding or chipping off paint with a needle hammer will cause fumes or dust and can lead to exposure. It is highly recommended to use proper PPE whenever working on such paint layers. Batteries with Lead are to be disposed properly when changed. • With regards to reporting, crew will register all changes made to materials that contain HazMats (according to the IHM survey report) in a central logbook on board. This log should also be used for the annual IHM maintenance- a software is being developed to make it easy. © Copyright MSC Mediterranean Shipping Company S.A.

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BEST PRACTICES FOR CREW ONBOARD FOR MAINTENANCE OF IHM, MONITORING OF STORES AND SPARES WHILE RECEIVING.

As described all changes to materials that contain HazMats are to be registered. There are many materials that might contain a HazMat and supplies should be closely monitorred. • Gaskets / joints / packings / seals • Insulation materials (e.g. fabrics / textile / pipe insulation) • Fire / welding blankets • Friction materials (e.g. brake linings/pads, clutch pads) • Fuses © Copyright MSC Mediterranean Shipping Company S.A.

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THE INVENTORY OF HAZARDOUS MATERIALS: CONCLUSION

IHM -31st Dec implementation Date • It records hazards rather than prohibits them– removal of

asbestos from fixed installations is not required for older vessels. • It is designed to protect people and the environment - safety • IHM Part 1 survey report which is the inventory and statement of compliance important documents for PSC readiness • Online training for asbestos awareness is being developed in collaboration with company which has done IHM surveys and we will arrange this in future. © Copyright MSC Mediterranean Shipping Company S.A.

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