The IHM (Inventory of Hazardous Materials) is to locate, identify and quantify hazardous materials on ships) . It is divided into three main sections:

1. Materials found in the ship’s structure or equipment

2. Operationally generated wastes

3. Stores

Part I of the IHM must be prepared and certified for both new and existing ships, and it must be maintained and updated throughout the ship’s operational life. Parts II and III, however, are only required when the ship is being prepared for recycling (on her last voyage). To create Part I, hazardous materials listed in Appendix 1 and 2 of the HKC or Annex I and II of the EU SRR must be identified.

For new-build ships , IHM Part I should be developed during the design and construction phases, using suppliers' declarations on the hazardous material content of the products. For existing ships, the identification of hazardous materials should follow the same process, where possible. In cases where documentation is unavailable, samples should be taken from the ship to investigate the hazardous materials.

For new-build ships, all hazardous materials listed in Appendix 1 & 2 or Annex I & II must be examined. For ships in operation, Appendix 1 / Annex I is mandatory, while Appendix 2 / Annex II should be investigated as much as possible.

Starting from 1st April 2024 and for all ships under Liberian Flag, IHM Report will be submitted to Liberian Administration for review and approval, subsequently to issue the ICIHM (SoC) to vessels regardless of any Class Society registration.

For new-build ships, the shipyard is responsible for preparing the IHM. The preparation is based on documentation provided by suppliers or manufacturers, which includes Material Declarations (MDs) and Suppliers Declaration of Conformity (SDOCs) in the up-to-date form basis MEPC 379(80) and EU SRR.

For ships in operation, the shipowner is responsible for preparing the IHM and ensure compliance with the HKC and EU SRR.

a) IHM Part I Preparation by Certified IHM service supplier

The steps involved in preparing the IHM are as follows:

• Collect relevant information about the ship.
• Assess the collected data.
• Develop a Visual and Sampling Check Plan (VSCP).
• Conduct on-board visual and sampling checks.
• Send samples for laboratory analysis and prepare the IHM and IHM inspection report.

For compliance with the EU SRR for EU/EEA flagged vessels, PFOS must be investigated, and HBCDD should be examined as far as practicable.

This entire process requires close coordination between several parties and typically takes up to one month to finalize the IHM inspection report. Early planning is therefore highly recommended.

Once the IHM and IHM inspection report are complete, the shipowner must submit the IHM report to Class / flag for approval and verification.

The IHM preparation must be conducted by qualified HazMat experts or companies approved by Class/ Flag.

b) IHM Part I Certification by Class/ Flag

• Class/Flag surveyor will review and approve the IHM report.
• Once approved, the shipowner must request an IHM initial survey to be conducted on board the ship by a Class/flag surveyor.
• After successful completion of the IHM initial survey, the surveyor will issue an IHM certificate or statement of compliance, valid for a maximum of 5 years, aligned with the ship’s main class renewal date.

Therefore, the shipowner should complete the steps outlined in section a) first and contact Class/ flag to prepare a proposal for IHM certification.

It is the owner's responsibility to keep the Inventory of Hazardous Materials Part I up to date. An IHM maintenance procedure should be put in place, which includes designating a specific person and maintaining records of all changes.

Once any machinery, equipment, component is added, removed, or replaced, or when the hull coating is renewed, the MD/SDoC forms supplied by the vendors must be correctly archived, and Part I of the IHM must be updated. During the IHM renewal survey, surveyors will examine the updated IHM along with the maintenance records.

For detailed requirements, refer to subsections 4.1.2 to 4.1.4 of the IHM Guidelines (Resolution MEPC.379(80)) and Article 5 in EU SRR 1257/2013.

Shipowners may have already implemented procedures in line with the HKC. It is advisable that they review these procedures and upgrade them to meet the standards of the EU SRR.

IHM renewal survey is required for every five years after the IHM initial survey.

The requirements are as below:

• Ship’s existing IHM certificate and IHM Part I;
• The updated IHM (Part I), reflecting any change, replacement or significant repair of structure, equipment, systems, fittings, arrangements and materials since last survey;
• Ship’s IHM Part I maintenance record, MDs and SDoCs reflecting the ship’s hazardous materials management since last IHM survey;

IHM Part II & Part III are not required during the ship’s operational life. They are only prepared when the ship is ready for recycling.

• Before the Final Voyage to a Recycling Yard – Shipowners must complete IHM Part II & III and submit them for approval.
• Before the Final Survey – The ship undergoes a final inspection to verify IHM completeness before being decommissioned.

If asbestos is found on a ship, immediate action is required to ensure compliance with international regulations, maintain crew safety, and avoid penalties.

Shipowner shall notify the flag state, and flag state would either decide to issue an exemption certificate or would give a time frame to the shipowner to remove the asbestos according to MSC/Circ.1045. The final decision rests with the flag, including the needs of having Asbestos Management Plan (AMP) on board the ship when asbestos cannot be immediately removed .

Regulatory Compliance for Asbestos on Ships

Prohibited on New Ships:

Asbestos has been banned on new ships since 2002 (SOLAS Regulation II-1/3-5).

Ships built before 1 July 2002 may have legally installed asbestos.

Strict Bans & Removal Requirements:

Since 1 January 2011, no asbestos-containing materials (ACMs) are allowed on board, even for repairs or replacements.