INVENTORY OF HAZARDOUS MATERIAL

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The IHM is a list of hazardous materials that are present on a ship. The IHM quantifies and locates hazardous materials on board ships which are known to represent a potential hazard to people and the environment. 

The IHM consists of three parts:

Part I: Hazardous materials contained in the ship’s structure and equipment

Part II: Operationally generated wastes

Part III: Stores

The IHM Part I is prepared either during the construction of the ship or while the vessel is in operation. For latter, hazmat experts should be contracted for the preparation of the IHM.

IHM Part II and III shall be prepared by the shipowner once the decision is given to send the ship for recycling. The IHM Part II and III can be prepared by the crew or by a hazmat expert.

Hong Kong Convention and EU Ship Recycling Regulation

Presently, two regulations are governing the requirements for safe and environmentally sound ship recycling:

Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC), which will enter into force in June 2025.

The EU Regulation on Ship Recycling (EU) No. 1257/2013 (EU SRR), which is in force since 31 December 2020.

Both HKC and EU aims to ensure that ships when being recycled, do not pose any unnecessary risk to human health, safety and environment. One of the main concerns is the fact that ships may contain hazardous materials such as asbestos, ozone-depleting substances, heavy metals and others, which may have negative impacts both on workers health safety and to environment.

HKC is applicable to ships, operating in the marine environment, which are equal to and above 500 GT. The HKC has two key issues:

Inventory of hazardous materials (IHM, 13 hazmats)

Authorization of ship recycling facilities

EU SRR is applicable to ships, operating in the marine environment, which are EU/EEA/UK flagged and 3rd party flagged vessels, visiting European ports or anchorages, equal to and above 500 GT. The EU SRR has two key issues:

Inventory of hazardous materials (IHM, 15 hazmats)

European list of approved ship recycling facilities

Navy ships and domestic ships are excluded from the scope of HKC and EU SRR.

IHM Part I preparation for new ships

For new building ships, the ship yard is responsible for the IHM Part I preparation. IHM preparation for new ships is based on documentation which is provided by the suppliers in the form of Material Declarations (MDs) and Suppliers Declaration of Conformity (SDOC). MD and SDoCs should be provided for all machinery, equipment, materials and coatings installed on board a vessel. The MD and SDoC contain information on whether hazardous materials, as listed in Annexes I and II of the EU SRR and/or Appendixes 1 and 2 of the HKC, are present in the specified products.

New ships, regardless of their Flag, must have an International Certificate on IHM according to the Hong Kong Convention, starting from 26 June 2025.

After the initial IHM Part I certification, it is the shipowner’s responsibility to maintain the IHM and keep it up to date. To be in compliance

Company must have an IHM Maintenance procedure/manual, which is implemented and integrated into the safety management system.

Your company is required to designate an individual responsible for IHM Maintenance, known as the IHM Designated Person (IHM DP).

Based on your company’s IHM Maintenance procedure, IHM must be updated;
- when the particulars of the vessel changes (e.g.: change of Name, Flag, owner, manager, etc.)
- when the hazardous material situation of the vessel changes (e.g.: a new product is installed on board with hazmats, an existing product in the IHM is removed from the vessel, the quantity of the hazmat in a product in the IHM changes)

To keep the IHM up to date, IHM DP should review all purchases done for each vessel in a period as defined in IHM Maintenance Procedure (e.g.: monthly, bi-monthly, etc.). For the purchased products, that fall into the scope of IHM Part I, Material Declarations (MD) and Supplier Declaration of Conformity (SDoCs) forms must be collected from the suppliers.

All collected MD/SDoC files must be stored/recorded in a designated folder/software. To have an overview on the IHM maintenance activities, we recommend that IHM DP keeps an “Audit Log”, with description on what has been changed in the IHM, when and by whom. That audit log form should also be part of your IHM Maintenance procedure and will help you to demonstrate that your procedure is implemented.

Supplier is defined as an agency, trader or manufacturer according to the MEPC 379(80) IHM Guidelines. MD/SDoC forms must be prepared by the supplier, who sells the product to the shipowner/shipmanage/shipyard. To do that, the supplier must contact to their sub-suppliers and get the information, based on the homogenous material criteria as defined in MEPC 379(80) Appendix 3.

There are 15 hazmats in the scope of the EU SRR. Suppliers have to declare in the MDs, whether those hazmats are above the specific threshold levels in the product. Even if there are no hazmats in a product, still MD/SDoC forms must be prepared by the suppliers and collected by the shipowners. 

To be in compliance, Shipowner has to inform their suppliers properly in advance. It is recommended to insert MD/SDoC delivery requirement in Purchase Order (PO) terms & conditions (T&C), so that legally suppliers agree to provide the forms, when they sign the PO T&C. Some Flags proposes alternative solutions for collection of MDs & SDoCs by using PO T&Cs. If this is what your company is doing, make sure that it is properly described in your IHM Maintenance procedure.