The Inventory of Hazardous Materials (IHM) is a vital document required for compliance with international regulations like the EU Ship Recycling Regulation and the Hong Kong Convention, encompassing certification for new ships, hazardous materials sampling processes, and ongoing maintenance responsibilities during a vessel’s operational life.
An Inventory of Hazardous Materials (IHM) is a comprehensive document that identifies, locates, and quantifies potentially hazardous materials onboard a vessel. It serves as a crucial tool for ship owners and recycling facilities to manage environmental and health risks throughout a ship’s lifecycle. The IHM consists of three parts:
Part I is required for all applicable ships, while Parts II and III are only prepared when a ship is destined for recycling. The IHM must be properly maintained and updated throughout the ship’s operational life, ensuring compliance with international regulations such as the EU Ship Recycling Regulation and the Hong Kong Convention.
Part I of the Inventory of Hazardous Materials (IHM) focuses on hazardous materials contained in the ship’s structure and equipment. It is divided into three subcategories:
Part I includes only items that are fixed to the ship, such as those welded, bolted, riveted, or cemented, including electrical cables and gaskets. It must list all machinery, equipment, materials, and coatings installed as fixed items. Specific items included are:
Items not required to be listed in Part I include loosely fitted equipment such as portable fire extinguishers, distress flares, and lifebuoys. The IHM must identify the location and approximate quantity of hazardous materials, ensuring consistency with the ship’s arrangements, structure, and equipment.
Part II of the Inventory of Hazardous Materials (IHM) focuses on operationally generated wastes that accumulate during a ship’s service life. This section is completed only when a decision to recycle the ship has been made and before the final survey. It includes:
The quantity of these wastes should be estimated, and their approximate quantities and locations listed in Part II of the Inventory. This information is crucial for the ship recycling facility to plan for proper handling and disposal of these materials, ensuring worker safety and environmental protection during the recycling process.
Part III of the Inventory of Hazardous Materials (IHM) focuses on stores, which are materials carried on board for the ship’s operation and maintenance, but are not permanently fixed to the vessel. This section is only prepared when a ship is destined for recycling. Key items included in Part III are:
These items are considered “regular consumable goods” that may contain hazardous materials. While they are necessary for ship operations, they are not integral to the ship’s structure and are unlikely to be dismantled at a recycling facility. The IHM Part III ensures that these potentially hazardous items are properly accounted for and managed during the ship recycling process.
The Inventory of Hazardous Materials (IHM) is required for both new and existing ships, not just older vessels. The Hong Kong Convention, which will enter into force on June 26, 2025, mandates that all new ships and existing ships of 500 GT and above must have a valid International Certificate on IHM. For EU/EEA flagged ships, this requirement has been in effect since December 31, 2018 for new ships, and December 31, 2020 for existing ships.
New ships are defined as those for which the building contract was placed on or after the regulation’s application date, or in the absence of a building contract, those with keels laid or at a similar stage of construction after that date. These vessels must have an IHM prepared during the design and construction phase, based on material declarations from suppliers.
Existing ships, on the other hand, must develop their IHM through document analysis, onboard visual inspections, and sampling. Both categories of ships are required to maintain and update their IHM throughout their operational life to ensure ongoing compliance with regulations.
For new ships of 500 GT and above, IHM certification is significantly more straightforward compared to existing vessels. Under the Hong Kong Convention, all new ships, regardless of flag, must have an International Certificate on IHM starting from June 26, 2025. For EU/EEA flagged ships, this requirement has been in effect since December 31, 2018.
The certification process for new ships involves:
By integrating IHM requirements into the shipbuilding process, new vessels can more easily achieve and maintain compliance with international regulations throughout their operational lives.
The Inventory of Hazardous Materials (IHM) must be continuously maintained and regularly reviewed throughout a ship’s operational life. While there is no specific mandated frequency, best practices suggest:
Shipowners should establish an IHM maintenance procedure integrated into their safety management system. The IHM Designated Person (IHM DP) is responsible for:
Additionally, the IHM must be verified during renewal surveys, which occur at intervals not exceeding five years. By maintaining an up-to-date IHM, shipowners ensure ongoing compliance with regulations and facilitate smooth certification renewals.
Maintaining the Inventory of Hazardous Materials (IHM) during a ship’s operational life is crucial for compliance with international regulations. Shipowners must designate an IHM Designated Person (IHM DP) responsible for keeping the IHM up to date. The IHM DP should review all purchases for each vessel periodically, as defined in the company’s IHM Maintenance Procedure, and collect Material Declarations (MDs) and Supplier Declarations of Conformity (SDoCs) for products falling within the scope of IHM Part I.Key aspects of IHM maintenance include:
By implementing these practices, shipowners can ensure ongoing compliance with regulations such as the EU Ship Recycling Regulation and the Hong Kong Convention throughout their vessels’ operational lives.
Maintaining the Inventory of Hazardous Materials (IHM) during a ship’s operational life is crucial for compliance with international regulations. Shipowners must designate an IHM Designated Person (IHM DP) responsible for keeping the IHM up to date. The IHM DP should review all purchases for each vessel periodically, as defined in the company’s IHM Maintenance Procedure, and collect Material Declarations (MDs) and Supplier Declarations of Conformity (SDoCs) for products falling within the scope of IHM Part I.Key aspects of IHM maintenance include:
By implementing these practices, shipowners can ensure ongoing compliance with regulations such as the EU Ship Recycling Regulation and the Hong Kong Convention throughout their vessels’ operational lives.
The Inventory of Hazardous Materials (IHM) primarily focuses on reporting substances that pose potential risks to human health and the environment. The main substances reported in an IHM include:
These substances are listed in Table A of Appendix 1 in the IMO guidelines. Additionally, the IHM may include other potentially hazardous materials such as kerosene, lubricating oils, paints, solvents, and various gases used onboard ships. The specific substances reported can vary depending on the ship’s construction, equipment, and applicable regulations, with EU regulations requiring additional substances to be listed compared to the Hong Kong Convention.
The latest regulatory updates regarding the Inventory of Hazardous Materials (IHM) introduce significant deadlines and requirements for shipowners and managers:
Key changes in IHM surveys and certification include:
Shipowners and managers should prepare well in advance, as the IHM compliance process can take up to three months. They should also ensure ongoing maintenance of the IHM throughout the ship’s operational life to meet these regulatory requirements.
The UAE Ship Recycling Regulation (UAE SRR), EU Ship Recycling Regulation (EU SRR), and Hong Kong Convention (HKC) share common goals but differ in key aspects:
These differences reflect each regulation’s unique approach to ensuring safe and environmentally sound ship recycling practices.
Non-compliance with Inventory of Hazardous Materials (IHM) requirements can lead to severe consequences for shipowners and operators. Vessels without a valid IHM and accompanying certificate may face:
Port State Control officers may accept evidence of compliance efforts in cases where non-compliance is due to exceptional circumstances, such as during the COVID-19 pandemic. However, the burden of proof lies with the shipowner or master to demonstrate that all possible measures were taken to obtain certification. To avoid these consequences, shipowners should prioritize IHM compliance well in advance of deadlines and establish robust maintenance procedures throughout their vessels’ operational lives.
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