An IHM, or Inventory of Hazardous Materials , is an inventory that enlist hazardous substances present on board the ship, including it identification, quantity, & location.

This compliance with regulations is crucial for both safety and legal reasons. Ship owners today have no other choice but to proactively address IHM implementation and maintenance to ensure they meet international regulations in a globalized world.

IHM was originally introduced to improve the handling and disposal of hazardous substances during ethical recycling of ships. However, since the presence of these hazardous and potentially life threatening materials poses a threat to the crew and marine life during the ship’s operation, nowadays the IHM is a crucial and mandated step.

Ship owners risk facing significant liabilities if information of the inventory of these hazardous materials, including the types, quantities, and locations are not always up to date.

According to the section 5.3 of the Hong Kong Convention & Section 5.6 of European Ship Recycling Regulation, the IHM document shall be properly maintained and updated throughout the operational life of the ship.

International IHM Regulations

There are two regulations that govern the requirements for inventory of hazardous materials:

Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC), which will enter into force in 26th June 2025.

The EU Regulation on Ship Recycling (EU) No. 1257/2013 (EU SRR), which is in force since 31 December 2020.

All ships exceeding 500 gross tons must possess a valid and certified IHM when entering EU ports or anchorages. Non-EU flagged vessels can comply with the HKC's IHM regulations to obtain EU SRR certification.

Steps for developing the IHM

With the upcoming enforcement of the Hong Kong Convention (HKC) and existing EU Ship Recycling Regulation (EU SRR), IHM (Inventory of Hazardous Materials) is mandatory for ships of 500 GT and above. Under HKC, all ships visiting ports of signatory states must maintain a certified IHM, listing hazardous materials on board.

Collect Information

Gather relevant ship documents and historical data for a comprehensive understanding.
Analyze Data

Evaluate the collected data to identify potential hazardous material locations
Visual and Sampling Check Plan (VSCP)

Develop a detailed plan for visual inspections and sampling
Onboard Visual and Sampling Check

Perform inspections and collect samples based on the VSCP.
Send Samples to Certified Laboratory

Submit samples for analysis at a certified laboratory and prepare the IHM and inspection report.
Submit Report to Class/Flag

Submit the IHM report to the classification society or flag administration and obtain the Statement of Compliance (SoC)
Maintenance

Regularly update the IHM and conduct periodic surveys to ensure ongoing compliance

The IHM consists of three parts:

Part I- Material contained in Equipment and Structure

Part II- Operationally Generated Waste (for last voyage)

Part III- Stores. (for last voyage)

IHM Part I is prepared during the ship's construction or while it's operational. IMO guideline (Res.MEPC 379 (80) - Paragraph 5.2.1) requires ship owners to designate a person to keep the inventory updated. This person can be employed onshore or on the vessel. It is important to remember the IHM document must always be present on the ship during the ship’s service.

IHM Parts II and III should be prepared by the ship owner when the vessel is scheduled for recycling. To minimize risks from errors due to inexperience or overzealousness, it's advisable to hire hazmat experts for this task.

IHM is a regulatory requirement.

By the IMO Guidelines for IHM Development (Res. MEPC 379 (80) - Paragraph 5.2.2), it is mandatory to establish a system for the continual update of the inventory.

IHM Maintenance is important in PCS

A detailed inspection may be carried out by the relevant authority involved in PSD activities if there is no procedure implemented on board the ship for IHM Maintenance (Refer to Regulation (EU) No. 1257/2013, Article 11).

As a ship owner, how do I maintain the IHM?

The IHM must be maintained and updated for as long as the ship is in service.

Once the Initial Hazardous Materials (IHM) Part 1 and Statement of Compliance (SoC) are completed, ongoing maintenance is crucial. This involves collecting and reviewing Material Declarations (MDs) and Supplier Declarations of Conformity (SDoCs) from all suppliers. A Designated Person (DP), a qualified Hazmat expert, must be appointed. The IHM must adhere to Hong Kong Convention (HKC) and EU Ship Recycling Regulation (EU-SRR). Understanding IMO and European guidelines like EMSA and ECSA is essential for establishing effective inventory maintenance.

While third-party hazmat experts are ideal due to their experience, qualified shipowners or managers can also handle IHM maintenance. Third-party experts will record changes during conversions or repairs, updating the IHM report for new installations or structural modifications. They also provide necessary documents for surveys or ship sales. Sea Sentinels collaborates with qualified IHM experts to create a tailored maintenance system, ensuring clear communication and procedures for IHM compliance throughout the ship's lifespan.

Our in-house team of Hazmat Experts will be using state of art cloud-based Software to keep all your vessels IHM updated throughout the lifecycle of the ship.

Sea Sentinels partners with experts to ensure effective IHM compliance throughout the vessel's life.

Our Package

IHM Manual
IHM Record Book
IHM Training Programme

We can take responsibility of yearly IHM

Looking at the requirements and the efforts it will take on a year-on-year basis, Sea Sentinels have put together a team who can take over the maintenance function and supplier liaison.

Inventory of Hazardous Materials (IHM)

Certified by all major IACS Members & Liberian Registry