WHAT IS IHM (Inventory of Hazardous Material)?

IHM is a list that provides ship-specific information on the actual hazardous materials present on board, their location, and approximate quantities onboard vessels.

The purpose of an IHM survey is to provide ship owners, managing agents, crews, engineers, and workers with a management report of all the hazardous materials which, are on-board the vessel.

The main materials that the IHM survey covers:

  • Asbestos
  • PCB’s
  • TBT’s
  • ODS.
  • PCT
  • PBB
  • lead in paint.

The IHM has the following parts:

  • PART I: Materials contained in ship structure or equipment
  • PART II: Operationally generated wastes, and
  • PART III: Stores

The IHM Part I shall be prepared and certified for new ships and ships in operation and shall be maintained and kept up to date during the operational life of the ship, while the IHM Part II & III are only required to be prepared when the ship is decided to be sent for recycling. For the preparation of IHM Part I, hazardous materials set out in appendix 1 and 2 of the HKC or Annex I and II of the EU SRR shall be investigated.
The picture below shows part I, part II and part III.

IHM Part I for new ships should be developed at the design and construction stage based on suppliers’ declarations on the hazardous material content of the products. The determination of hazardous materials present on board existing ships should, as far as practicable, be conducted as prescribed for new ships. Alternatively, in the case where documentation is not available, samples shall be taken from the ships to investigate the hazardous materials.
For new ships, all the hazardous materials listed in Appendix 1 & 2 or Annex I & II shall be investigated, while for ships in operation Appendix 1 / Annex I is a must, and Appendix 2 / Annex II is to be investigated as far as practicable.

There are two main legislations with respect to ship recycling in the market, one is IMO Hong Kong Convention (HKC) SR/CONF/45 and the other one is the EU Ship Recycling Regulation (EU SRR) EC No 1257/2013. HKC has in total of 6 guidelines and MEPC.269(68) is the guidelines for the development of the inventory of hazardous materials (IHM) under IMO.

The Hong Kong Convention:

It will enter into force 24 months after the date on which the following conditions are met:

  1. Signed by at least 15 states;
  2. The combined merchant fleets of the signatory states are not less than 40% of the GT of the world’s merchant shipping,
  3. The combined maximum annual ship recycling volume of the signatory states, during the preceding 10 years, is not less than 3% of the GT of the combined merchant shipping of the same states.

The entry into force conditions of HKC is not met yet (Aug 2020) and its compliance is on a voluntary basis.
HKC will apply to ships, operating in the marine environment, which is equal to or above 500 GT. Navy ships and domestic ships are excluded from the scope.

According to the EU Ship Recycling Regulations:

  1. New ships flying a flag of an EU member state, shall be delivered with a valid IHM which is certified;
  2. End-of-life ships going for recycling shall have a valid IHM certified and shall be sent to one of the recycling facilities in the EU List of approved ship recycling facilities.
  3. Existing ships flying the flag of an EU member state and third-party ships visiting EU ports and anchorages, from 31 December 2020, shall have a valid IHM on-board, which is certified.

“New ship” means a ship for which either:

  • the building contract is placed on or after the date of application of this Regulation;
  • in the absence of a building contract, the keel is laid or the ship is at a similar stage of construction six months after the date of application of this Regulation or thereafter; or
  • the delivery takes place thirty months after the date of application of this Regulation or thereafter.