Inventory of Hazardous Materials (IHM) - Know the Governing Bodies
An IHM gives insight into the presence of dangerous substances on board a ship and minimizes risks to employee health and environment.
Governing Bodies and Regulatory Framework for IHM
The Inventory of Hazardous Materials is governed by a multi-layered regulatory framework involving international organizations, regional authorities, and national administrations. Understanding the roles and requirements of these governing bodies is essential for ship owners seeking to achieve and maintain IHM compliance across all jurisdictions in which their vessels operate.
International Maritime Organization (IMO)
The IMO adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships in 2009. This convention requires ships of 500 gross tonnage and above to carry an IHM covering hazardous materials listed in its appendices. The convention also sets requirements for ship recycling facilities and establishes a framework for the survey and certification of IHMs. While the convention has not yet entered into force internationally, it has been ratified by a growing number of states and its requirements are already reflected in regional legislation such as the EU SRR.
European Union
The EU Ship Recycling Regulation (Regulation (EU) No 1257/2013) is the primary legislative instrument governing IHM within the European Union. It applies to all ships flying the flag of an EU Member State and to non-EU flagged ships calling at EU ports or anchorages. The regulation requires vessels to carry a certified IHM and to maintain it throughout the vessel's operational life. The European Maritime Safety Agency (EMSA) supports implementation and enforcement at the EU level.
Other Governing Bodies
- Flag state administrations: Responsible for surveying and certifying IHMs for vessels registered under their flag
- Classification societies: Act as Recognized Organizations authorized to conduct IHM surveys and issue certificates on behalf of flag states
- Port state control authorities: May inspect IHMs during routine port state control inspections and issue deficiencies for non-compliance
- Basel Convention: Governs transboundary movement of hazardous wastes, relevant to ship recycling operations
- International Labour Organization (ILO): Sets standards for worker safety in ship recycling, linked to IHM accuracy
Enforcement Reality
Port state control officers in EU ports are actively inspecting IHMs. Non-compliance can result in deficiency reports, detention, and financial penalties. Ensure your IHM is current, certified, and readily available for inspection at all times.
Related Articles
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Inventory of Hazardous Materials (IHM) - The Process
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Inventory of Hazardous Materials (IHM) - Importance & Benefits
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