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Hazardous Materials Testing

Compliance Regulation Requirement

The maritime industry has seen dramatic changes in recent years due to legislations and regulations concerned with reducing the industry’s environmental impact. This is set to continue as it develops its 'green credentials' and as environmental impact pressure is heightened.

The IMO adopted the Hong Kong International Convention 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 convention seeks to clinch the proper management of hazardous materials on board ships.

At the same time, 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). The regulation also clarified that it is the supplier’s responsibility to provide Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) certifications.

The following organizations and/or persons will need to engage with a Hazardous Material Testing service provider:

• Any shipyard or supplier related with the marine industry who are concerned with the HazMat condition on their premises.  The service provider can assist in the development of the MD and SDoC certifications and verify that all regulated substances are within regulatory thresholds.
• HazMat consultants/experts working on the development of the Inventory of Hazardous Materials (IHM) for an existing ship whorequire sample testing by a competent and accredited 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 the worst case,the final 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 Hong Kong Convention 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 referenceto ISO/IEC 17025:2005. Additionally, the testing service provider must be recognized by the related class society.

Regulation

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