IHM: Common Observed Fallacies
It is observed that approved IHM survey reports of various vessels have zero inventory points, which is practically impossible. At a minimum, lead-acid batteries containing hazmat – lead and lead compounds will be present in equipment like Emergency Generator Starting Batteries, GMDSS Batteries, Lifeboat Starting Batteries, Fire Alarm System Batteries, etc.
Such vessels shall work on the battery log and update the inventory or have them updated by their IHM Maintenance service provider.
Some approved IHM Reports mention a single inventory point for all the batteries, for. E.g. “Fixed Batteries all over the vessel”. In such cases too, the inventory shall be updated with the help of the battery log.
“Updating is not required if identical parts or coatings are installed or applied” – a common reason given by the spare part suppliers like engine manufacturers to not provide the declarations.
During the initial IHM Survey, sampling of engine parts such as some gaskets, packing and Insulation is done but it is not practically possible to check the complete engine for complete scope of all hazmat.
Hazmats like chromium, cadmium and lead can be present in heavy metal spares like plating film or bearings. To cover for this, MD & SDoC for these spares are requested from the supplier. Hence, at least the first MD & SDoC is required for such engines and components. In cases where such spares are provided by OEMs or third-party suppliers (Replacement spares) and not by the manufacturers, MD & SDOC will be required as the item getting replaced will not be identical.
It is a common misconception that all consumer products do not require MD & SDoC.
As per the IMO Guidelines, MD & SDoC will be required for consumer products like Ionization smoke detectors, instruments/signs containing radioactive substances, fluorescent lamps, light fittings, etc.
An essential step of the IHM Maintenance process is the filtering of items from the procurement data of the vessel. This filtering should be done in total compliance with the regulation and guidelines to ensure that all IHM relevant items are processed. Priority should be the quality and not the quantity.
- K Harshal, IHM Manager
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