Inventory of Hazardous Materials (IHM) Both the HKC and EU-SRR require an Inventory of Hazardous Materials (IHM) to be present on a ship.
These hazardous materials are known to represent a possible danger to people and the environment. To ensure a safe and environmentally sound handling of these materials, a detailed documentation of the materials in the ship’s structure and equipment, and in stores, is important.
As required by the EU-SRR, from 31 December 2018, new EU/EEA flagged ships of 500gt and above, and from 31 December 2020, all existing EU/EEA flagged and non-EU flagged ships calling at EU ports and anchorages are required to have a certified IHM on board. The IHM is required to be verified by the flag state or by a recognized organization (RO) authorized by the flag state.
The verified IHM should be accompanied by an Inventory Certificate (for EU/EEA flagged vessels) or a Statement of Compliance (SoC) for flying the flag of a third country (non-EU/EEA flag). The HKC has not yet entered into force, but IMO Resolution MEPC.269(68) provides guidelines and a standard format for the development of the IHM. Additionally, EMSA has issued a best practice guidance, a non-binding document, for the development and maintenance of the IHM in accordance with the EU-SRR.
- Overview of IHM Essentially, an 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. IHM Part I is applicable to all ships and shall be kept up-to-date during the operational life of the ship, while IHM Parts II & III are only required to be prepared when it is decided that the ship will be sent for recycling.
For new vessels, compliance should be relatively easy, as an IHM Part I can be developed by the shipbuilder at the design and construction stage based on suppliers’ declarations of the hazardous material content of their products. For existing ships, it may be necessary for a qualified service provider (a hazardous material or ‘hazmat’ expert) to attend the ship and prepare a report, based on a document analysis and an on-board investigation through sampling and visual checks. These reports are subject to review and approval by the flag state or ‘Recognized Organization’ (RO), which is usually the classification society acting on behalf of the flag state. This is followed up by an initial survey and verification on board, after which, if everything is in order, the IHM certificate or Statement of Compliance (SoC) can be issued. The whole process may take up to three months or longer, depending on the ship’s size/ construction and the review process. In preparation of an IHM, the standard format according to the IMO guidelines can be used. Note, however, that EU legislation adds two additional items on top of the HKC requirements to the list of controlled hazardous materials: Perfluoro octane Sulfonic Acid (PFOS) in Annex I and Brominated Flame Retardant (HBCDD) in Annex II. As such, if an IHM is developed to cover EU-SRR requirements, then it is recommended to include a reference stating this
