Inventory of Hazardous Materials (IHM)- Asbestos

In keeping with SOLAS II-1/3-5, depending on the date on which keel was laid or at a similar stage of construction, the following correct course of action is needed to be taken to “Asbestos Containing Materials (ACMs)” being installed onboard a ship, in principle. (MSC.1/Circ.1374)

  • For ships constructed before 1 July 2002:
    The ships are permitted to continue having existing ACMs installations anywhere unless they pose a risk to crew health.
  • For ships constructed between 1 July 2002 and 31 December 2010:
    The ships are only permitted to have new installation of ACMs for specified purposes, such as vales, joints, and insulations.
  • From 1 January 2011:
    For all ships, new installation onboard of ACMs has been prohibited.

If ACMs installations which is not followed by the above-mentioned regulations are found, the measurement below should be taken.

  • Notify the flag authority of the contravention, together with an action plan to manage/remove the ACMs installations
  • When the action plan is found to be satisfactory by the flag authority, the flag exemption will be issued to the vessel
  • The removal of the ACMs installations should be undertaken by professional asbestos removal companies within a period of 3 years from the date when the contravention is found

The updated information about the special requirements of the flag authority can be checked on each flag’s special instruction given below.

Flag authority Flag’s special instruction
Antigua and Barbuda SOLAS Circular No. 2020 – 006 (Rev 1)
Bermuda BGN 2020-12
Cayman Islands GN 02/2019 (Rev 3)
Isle of Man TAN 005-20 (Rev 2.)
Norway Actions required to be taken when asbestos containing materials (ACM) are identified and found to be present onboard Norwegian flagged ships are shown below:

  • The company issued with the Document of Compliance (DOC) shall ensure that risk assessments are performed and documented;
  • ACM which causes an onboard exposure of 0.1 or more asbestos fiber per cubic centimeter air, shall be removed by a professional asbestos removal company;
  • The plan for the removal of ACM shall be documented;
  • Verification by NK that relevant risk assessments have been carried out onboard; and
  • When the onboard exposure of 0.1 or more asbestos fiber per cubic centimeter air exceeded, verification by NK that the asbestos removal plan (AMP) is documented and present onboard.
Portugal (EU) DGRM CIRCULAR NO 67
U.S.A. When the asbestos containing materials (ACMs) are identified onboard during the IHM survey (IHM survey) for U.S. flagged vessels to which the issuance of the IHM Statement of Compliance (IHM SOC) for the European Union Ship Recycling Regulation (EU SRR) is needed, Procedures vary depending on the factors below.

> Date of contract
> Recognized Organization (RO) which carries out the IHM survey
> Recognized Organization (RO) which issue the certificate below
  • SOLAS Safety Construction Certificate (SC Cert)
  • Document of Compliance (DOC)
  • Safety Management Certificate (SMC)
> Case 1
[Date of construction: After July 1, 2002,
RO responsible for SC Cert and IHM Survey: NK]
  • If the ACM is to be removed, NK needs to rewrite SC Certificate, and issues the IHM SOC valid for three years.
  • In this instance, the Flag State Control Division (CG-CVC-4) will issue a Flag State Dispensation valid for three years, so as to harmonize with the IHM SOC.
> Case 2
[Date of construction: Before July 1, 2002,
RO responsible for SC Cert and IHM Survey: NK]
  • If measures are being taken against the ACM in line with MSC Circular 1374, the ACMs can remain onboard. In this instance, NK needs to issue the IHM SOC valid for five years.
  • If the ACM needs to be removed, NK needs to rewrite SC Certificate, and issue the IHM SOC valid for three years.
> Case 3
[Date of construction: After July 1, 2002,
RO responsible for IHM Survey: NK, RO responsible for SC Cert: Other than NK]
  • NK needs to issue the IHM SOC valid for three years.
  • In this instance, NK is to provide the owner/operator and CG-CVC-4 with specific notice of details about ACMs, and advise them to forward the details to RO responsible for SC Cert.
> Case 4
[Date of construction: Before July 1, 2002,
RO responsible for IHM Survey: NK, RO responsible for SC Cert: Other than NK]
  • NK needs to assess whether the ACMs will pose a risk to the crew.
  • If the assessment shows the ACMs do not pose a risk to the crew, NK needs to issue the IHM SOC valid for five years, and to advise the owner/operator to forward the relevant documentation to RO responsible for SC Cert.
  • RO responsible for SC Certificate will notify CG-CVC-4 of the details.
> Case 5
[RO responsible for IHM Survey, DOC and SMC: NK]
  • DOC and/or SMC need to be updated with procedures to monitor the ACMs in line with MSC Circular 1045, and then NK shall review the updated DOC and/or SMC so as to verify mitigation plans and procedures of ACMs are in place prior to the coming vessel/company audit which is followed by the IHM survey.