Introduction of IHM Gap Analysis Service by GMS RSRP

GMS’ Responsible Ship Recycling Program (GMS RSRP) has introduced a new service of fulfilling gaps in the Inventory of Hazardous Material (IHM) reports submitted by shipowners for their end-of-life vessels at the time of recycling.

Why IHM Gap Analysis?

An IHM is the soul of safe and environmentally friendly ship recycling. Unfortunately, a majority of IHM reports being prepared are done when a vessel is in operation and hazardous materials experts are not always permitted access to samples of insulation on running machinery, control panels, and equipment, as well as in many operational / occupied / confined spaces onboard. Therefore, inaccessible locations get reported as the location with “Potentially Containing Hazardous Materials (PCHM)” in the IHM. PCHM locations do not confirm the existence or even the type(s) and quantity of wastes onboard, which eventually creates a gap in the IHM report.

Under GMS RSRP, we have recycled over 100 ships so far and have seen this potentially hazardous gap in various IHM reports generated by third parties. More dangerously, we have noticed that a few IHM reports do not even cover sampling of areas that were accessible to the hazmat experts. An argument on the number of samples for generating the IHM report certainly exists and few experts claim that the volume of sampling does not define the accuracy of the IHM report, but the experience of hazmat expert that matters the most. However, we have realized that the end-users of the IHM report come to realize the gaps in the IHM only after the vessel is delivered to their yard.

What will GMS’s IHM Gap Analysis Cover?

The objective of GMS IHM gap analysis report is to analyze and address the gaps in an IHM Report submitted by ship owners when committing their ships for recycling. The IHM Gap Analysis includes:

1. Visual/sampling checks of PCHM locations identified in the IHM report submitted by shipowners
2. Sampling of locations and components which were not covered in the IHM report
3. Re-sampling of locations which were already covered in the IHM report, in order to ensure correctness of results in the IHM
4. Re-sampling of locations already covered in the IHM report in order to test for identification of hazardous wastes other than those already tested.

This four-prong approach will ensure all potential gaps are accurately addressed.

Advantages of GMS’s IHM Gap Analysis?

• Cost effective (fraction of cost)
• Comprehensive (see below)
• Simple and Seamless (no need to pay extra. Cost of IHM can be deducted from the purchase price)

IHM Gap Analysis will ensure that any IHM report provided by shipowners covers all types of wastes and its respective quantities, with no PCHM locations onboard as per MEPC 269 (68). Gap Analysis through our four-prong approach will strive to confirm that the results generated in the IHM submitted by ship owners are accurate - which further ensures that workers are not exposed to unidentified hazardous wastes during the recycling of end-of-life ships. GMS’s IHM Gap Analysis further endorses the effective management of hazardous wastes and tracking of wastes onboard.

GMS is proud to introduce this first-of-a-kind service to shipowners and owners of recycling yards to ensure the effective implementation of Safe and Environmentally Sound Recycling of Ships.