Navigating the Complexities of IHM Compliance: A Guide for Ship Owners

IHM Compliance: A Strategic Imperative for Ship Owners

The Inventory of Hazardous Materials (IHM) has become a critical compliance document for ship owners and operators worldwide. Required under the EU Ship Recycling Regulation (EU SRR) and the IMO Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships, the IHM provides a comprehensive record of all hazardous materials present onboard a vessel. Navigating the complexities of IHM compliance requires a thorough understanding of regulatory requirements, a systematic approach to hazardous material identification, and ongoing maintenance throughout the vessel's operational life.

Regulatory Landscape

The EU Ship Recycling Regulation, which came into force on December 31, 2020, for existing vessels, requires all ships of 500 gross tonnage and above calling at EU ports to carry an IHM that has been surveyed and certified by a recognized organization. The Hong Kong Convention, though not yet in force internationally, has been ratified by a growing number of flag states and is expected to enter into force in the near future. Ship owners must ensure their IHM meets the requirements of both the EU SRR and the flag state administration, which may adopt the Hong Kong Convention standards.

Key Steps for IHM Compliance

• Engage a qualified IHM expert company to conduct sampling and visual/sampling checks onboard
• Compile Part I of the IHM covering materials contained in the ship's structure and equipment
• Develop Part II covering operationally generated wastes and Part III covering stores
• Submit the IHM for review and certification by a recognized organization or classification society
• Establish a maintenance system to update the IHM whenever new materials are brought onboard or structural changes are made
• Train designated personnel in IHM maintenance procedures and Material Declaration requirements

Common Compliance Pitfalls

Ship owners frequently encounter challenges including incomplete sampling during the initial IHM survey, failure to update the IHM after drydock repairs or equipment changes, inadequate Supplier Declarations of Conformity (SDoC) and Material Declarations (MD) for new materials brought onboard, and insufficient crew training on IHM maintenance procedures. Addressing these issues proactively through robust procedures and qualified personnel is far more cost-effective than remediation after a port state control deficiency or regulatory enforcement action.