IHM Management
Inventory of Hazardous Materials
The Inventory of Hazardous Materials (IHM) is a mandatory document listing all known hazardous materials present in a ship's structure, systems, and equipment. Required under both the Hong Kong Convention (effective June 26, 2025) and the EU Ship Recycling Regulation (No. 1257/2013), the IHM ensures safe handling of hazardous materials throughout a vessel's lifecycle and at end-of-life recycling.
What is IHM?
The Inventory of Hazardous Materials is a three-part document that identifies and quantifies hazardous materials present onboard a vessel. IHM Part I covers materials contained in the ship's structure and equipment, while Parts II and III address operationally generated wastes and stores respectively. The IHM must be developed by a qualified Expert Company through systematic visual checks and sampling surveys.
Under the EU SRR, 15 hazardous materials must be inventoried, including the 13 substances listed in the Hong Kong Convention plus PFOS (perfluorooctane sulfonic acid) and brominated flame retardants. These additional substances reflect the EU's more stringent approach to hazardous material management in ship recycling.
The IHM is a living document that must be updated whenever repairs, modifications, or equipment changes affect the hazardous material inventory. Supplier Declarations of Conformity (SDoC) and Material Declarations (MD) must be obtained for all new materials and equipment installed onboard.
IHM Requirements
HKC Entry into Force
The Hong Kong Convention enters into force on June 26, 2025. While existing ships have a 5-year transition period (until June 26, 2030), ships calling at EU ports already require IHM Part I under the EU SRR. Early compliance is strongly recommended to avoid operational disruptions and ensure recycling readiness.
Regulatory Frameworks
IHM requirements stem from two overlapping regulatory regimes. Understanding both is essential for vessels trading internationally, particularly those calling at EU ports.
Hong Kong Convention (HKC)
The IMO Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, effective June 26, 2025.
- Covers 13 hazardous materials listed in Appendix 1
- Applies to ships of 500 GT and above
- Existing ships must comply by June 26, 2030
- New ships must carry certified IHM at delivery
- Requires approved ship recycling facilities
EU Ship Recycling Regulation
EU SRR (Regulation No. 1257/2013) has been in force since December 31, 2020 for EU-flagged vessels, with stricter requirements than HKC.
- Covers 15 hazardous materials (HKC 13 + PFOS and brominated flame retardants)
- IHM Part I mandatory for EU-flagged ships since Dec 2020
- Ships calling at EU ports must carry IHM on board
- Requires use of EU-listed ship recycling facilities
- Statement of Compliance issued by flag State or RO
Expert Company Role
An Expert Company is responsible for IHM development, ensuring proper sampling methodology and accurate hazardous material identification.
- Qualified hazmat specialists conduct onboard surveys
- Visual inspection and sampling survey methodology
- Laboratory analysis per approved standards (IEC 62321, EPA methods)
- IHM document compilation and technical review
- Support for flag State or RO certification process
IHM Development Process
Developing a compliant IHM involves a structured process from initial planning through certification, executed by a qualified Expert Company.
Document Review
Review ship drawings, equipment lists, and available Material Safety Data Sheets (MSDS) to establish a preliminary inventory and identify areas requiring physical survey.
Onboard Survey
Qualified hazmat surveyors conduct visual checks and collect material samples from identified locations. Sampling follows MEPC.269(68) guidelines for systematic coverage.
Laboratory Analysis
Collected samples are analyzed at accredited laboratories using XRF, GC-MS, and FTIR methods to identify and quantify all listed hazardous materials.
IHM Compilation & Certification
Compile the IHM document in the prescribed format, submit to the flag State or Recognized Organization for review, and obtain the Statement of Compliance.
Our IHM Solutions
We provide comprehensive IHM services as a qualified Expert Company, covering initial development, laboratory analysis, lifecycle maintenance, and regulatory certification under both HKC and EU SRR.
IHM Part I Development & Certification
Complete development of IHM Part I through systematic visual and sampling surveys, laboratory analysis, and compilation of hazardous material inventories in compliance with HKC and EU SRR requirements.
- Visual check and sampling survey planning
- Onboard survey by qualified hazmat experts
- IHM document compilation to IMO/EU format
- Flag State or RO certification support
Hazardous Material Sampling & Lab Analysis
Professional collection of material samples from ship structures and equipment, followed by accredited laboratory analysis to identify and quantify all listed hazardous materials.
- Systematic sampling per MEPC.269(68) guidelines
- Accredited lab analysis (XRF, GC-MS, FTIR)
- Asbestos, PCB, heavy metals identification
- PFOS and brominated flame retardant testing
Lifecycle Maintenance & Updates
Ongoing IHM maintenance to reflect changes from repairs, modifications, equipment replacements, and dry-docking activities, ensuring continuous compliance throughout the ship’s operational life.
- IHM updates for repairs and modifications
- Dry-docking and refit documentation updates
- Material Declaration (MD) review from suppliers
- Supplier Declaration of Conformity (SDoC) tracking
Expert Company Services
Acting as your designated Expert Company under the HKC and EU SRR frameworks, providing qualified personnel for survey execution, document development, and regulatory liaison.
- Designated Expert Company appointment
- Qualified hazmat surveyor deployment
- Regulatory interpretation and advisory
- Third-party audit and review support
Green Passport Support
Preparation of the ship’s Green Passport documentation, integrating IHM data with recycling-ready information to facilitate compliant end-of-life ship recycling at approved facilities.
- Green Passport document preparation
- Ship recycling plan input documentation
- EU List facility compliance verification
- Ready for Recycling Certificate support
EU SRR Compliance Gap Analysis
Detailed gap analysis comparing your existing IHM documentation against EU SRR requirements, identifying the two additional substances (PFOS and brominated flame retardants) and any documentation shortfalls.
- HKC vs EU SRR gap identification
- PFOS and BFR supplementary testing
- Documentation completeness review
- Remediation plan and timeline development
Frequently Asked Questions
Common questions about our IHM Management services and compliance requirements.
An IHM is a certified document listing all hazardous materials present on a ship, required under the Hong Kong Convention (HKC) and EU Ship Recycling Regulation No. 1257/2013. It ensures safe ship recycling and occupational health by identifying materials like asbestos, PCBs, lead, and mercury.
Related Solutions
Services that complement IHM Management for comprehensive maritime compliance.
Asbestos Management
Asbestos surveys, safe removal by certified teams, air monitoring, compliant disposal, and IHM integration for vessels.
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Independent marine surveys including pre-purchase, P&I/H&M damage investigation, on/off-hire, draft surveys, and newbuilding supervision.
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SOLAS, MARPOL, ISM, ISPS, and MLC compliance audits, PSC readiness assessment, and deficiency rectification.
Learn moreEnsure Your Fleet's IHM Compliance
With the Hong Kong Convention now in force and the EU SRR already mandating IHM for EU port calls, having a properly developed and maintained Inventory of Hazardous Materials is essential for uninterrupted commercial operations.