How to maintain the IHM Part I?
After the initial IHM Part I certification, it is the shipowner’s responsibility to maintain the IHM and keep it up to date. To be in compliance
- Your company must have an IHM Maintenance procedure/manual, which is implemented and integrated into your safety management system.
- Your company is required to designate an individual responsible for IHM Maintenance, known as the IHM Designated Person (IHM DP), see our training titled "IHM Maintenance Implementation for Designated Persons."
- Based on your company’s IHM Maintenance procedure, IHM must be updated;
- when the particulars of the vessel changes (e.g.: change of Name, Flag, owner, manager, etc.)
- when the hazardous material situation of the vessel changes (e.g.: a new product is installed on board with hazmats, an existing product in the IHM is removed from the vessel, the quantity of the hazmat in a product in the IHM changes)
To keep the IHM up to date, IHM DP should review all purchases done for each vessel in a period as defined in IHM Maintenance Procedure (e.g.: monthly, bi-monthly, etc.). For the purchased products, that fall into the scope of IHM Part I, Material Declarations (MD) and Supplier Declaration of Conformity (SDoCs) forms must be collected from the suppliers.
All collected MD/SDoC files must be stored/recorded in a designated folder/software. To have an overview on the IHM maintenance activities, we recommend that IHM DP keeps an “Audit Log”, with description on what has been changed in the IHM, when and by whom. That audit log form should also be part of your IHM Maintenance procedure and will help you to demonstrate that your procedure is implemented.
Supplier is defined as an agency, trader or manufacturer according to the MEPC 379(80) IHM Guidelines. MD/SDoC forms must be prepared by the supplier, who sells the product to the shipowner/shipmanage/shipyard. To do that, the supplier must contact to their sub-suppliers and get the information, based on the homogenous material criteria as defined in MEPC 379(80) Appendix 3.
There are 15 hazmats in the scope of the EU SRR. Suppliers have to declare in the MDs, whether those hazmats are above the specific threshold levels in the product. Even if there are no hazmats in a product, still MD/SDoC forms must be prepared by the suppliers and collected by the shipowners.
To be in compliance, Shipowner has to inform their suppliers properly in advance. It is recommended to insert MD/SDoC delivery requirement in Purchase Order (PO) terms & conditions (T&C), so that legally suppliers agree to provide the forms, when they sign the PO T&C. Some Flags proposes alternative solutions for collection of MDs & SDoCs by using PO T&Cs. If this is what your company is doing, make sure that it is properly described in your IHM Maintenance procedure.
Scope of IHM Part I Maintenance
Collection of MDs is not only for significant parts, it is about all the machinery and equipment installed on board as a fixed item, and used in order the ship to operate. In this regard, we are talking about but not limited to: any machinery and their sub-parts, valves, pumps, pipes, gaskets, insulation material, brake linings, paints, cables, batteries, navigation equipment installed as fixed items.
All those MD and SDoCs shall be recorded properly. As the number of documentation can exceed hundreds, DNV offers the IHM Manager, which is self-service data management tool in Fleet status to support IHM maintenance.