INVENTORY OF HAZARDOUS MATERIALS (IHM)
The “Inventory of Hazardous Materials” – formerly referred to at IMO and at LR as the Green Passport –
is an inventory of materials present in a ship’s structure, systems and fitted equipment that may be
hazardous to human health and the environment. The IHM must be maintained throughout the life of the
ship.
Why “Inventory of Hazardous Materials (IHM)” is important/ required or What are hidden benefits of IHM?
As explained above, Inventory provides ship-specific information on the actual hazardous materials
present on board during the Shipbuilding process as well as operations.
The Basic purpose/ Hidden Benefits of IHM are as mentioned below:
- To protect health and safety and to prevent environmental pollution at ship recycling facilities. The information contained in IHM will be used by the ship recycling/ breaking facilities to decide how to manage the types and amounts of Hazardous materials identified in the Inventory of Hazardous Materials.
- The IHM is required for identification of suitable ship recycler/ breaker by owners.
- It can be used for identifying risks during ship operations as it provides crew (of repair) with useful information like Location, Amount, Procedure of Handling, etc. of Hazardous materials thereby contributing to incident and accident preparedness and response.
- It can also be used for identifying risks during conversion/ breaking yards about hazardous materials onboard, contributing to incident and accident preparedness and response.
Legislation: IMO Hong Kong Convention (HKC)
➢ Adopted by IMO in May 2009
➢ Entry into force: 24 months after ratification by 15 States, representing 40% of world merchant
shipping by gross tonnage
➢ Requires an IHM Certificate outlining specific potential hazardous materials on ships and stating
that vessel recycling should: ‘not pose any unnecessary risk to human health and safety, or to the
environment’
➢ Ratified so far by 10 nations – Norway, France, Belgium, Denmark, Panama, Congo, Turkey,
Netherland, Republic of Serbia and Japan.
➢ Main items to be listed (Asbestos, PCB (Printed Circuit Breakers), ODS (Ozone Depleting
Substances), TBT (Tributyltin)) from Appendix 1 of the Hong Kong Convention, and other materials
from Appendix 2 (heavy metals & radioactive Substance).
EU Ship Recycling Regulations (EU SRR): 31 December 2020:
Requires IHM for all vessels above 500 GT calling European ports from December 31st Dec 2020, as well
as for European vessels being recycled from 2016.
Note: IHM is a must by 31st Dec 2020 for all vessels (500GT & above) registered in EU and for all other
flag vessels calling EU.
Additionally identifies 2 hazardous materials to be checked PFOS (Perfluorooctane Sulfonic Acid) – for
existing ships & HBCDD (hexabromocyclododecane) – for newbuilt ships, apart from items in Appendix 1
and Appendix 2 of the Hong Kong Convention.
The IHM consists of three parts:
Once the legislation has entered into force/ become applicable:
- Each new ship and existing ships shall have on board an IHM Part I, which should be maintained
during the ship’s operational life. - Once the decision to recycle a ship has been taken, Part II of the Inventory should be developed
before the final survey, taking into account that a ship destined to be recycled shall conduct
operations in the period prior to entering the Ship Recycling Facility in a manner that minimizes the
amount of cargo residues, fuel oil and wastes remaining on board, the quantity of the operationally
generated wastes should be estimated and their approximate quantities and locations should be
listed in Part II of the Inventory.
Part II of the IHM: Any wastes listed in Table C (Potentially hazardous items) of Attachment 1 to the IMO
Convention which are to be delivered with the ship should be estimated, and their approximate quantities
and locations should be listed in Part II of the IHM.
Part III of the IHM contains three different sections:
➢ Stores
➢ Liquids and gases sealed in the ship’s machinery and equipment; and
➢ Regular consumable goods.
Any stores which are to be delivered with the ship and are required to be listed in Part III of the inventory
should be listed in terms of the unit (e.g. capacity of cans and cylinders), quantity and location on board.
IHM part I hazards are split into table A and B (HKC) or Annex I or II (EU SRR).
Examples of Hazardous materials {Table A (HKC) / Annex I (EU SRR)}:
Table A – Materials listed in appendix 1 of the Annex to the Convention
Examples of Hazardous materials {Table B (HKC) / Annex II (EU SRR)}:
IHM: certification at Yard:
➢ Shipbuilder compiles IHM based on Material Declarations (MD) and Supplier Declarations of
Conformity (SDoC)
➢ Site surveyors review paperwork/ undertake onboard checks
➢ Site surveyors approve IHM and issue Statement of Compliance (SOC)
➢ SoC issued with a 5-year validity.
➢ Shipowner responsible for maintaining the IHM
IHM: certification of an existing ship (The whole process may take 3-4 months).
Process flow chart:
➢ Collection of required information and documents by Shipping Company/ Owner & submitting to
appointed Hazardous Materials Expert (HME).
➢ Preparation of Visual Sample Check Plan (VSCP) by HME.
➢ HME to visit vessel & carry out Onboard survey, collect samples and submit it to Accredited lab.
➢ Analysis of samples by accredited lab.
➢ HME to prepare IHM report based on lab results & submit it to Shipping Company/ Owner.
➢ Shipping Company/ Owner to submit IHM report to Class.
➢ Visit by class surveyor onboard for survey, verification and certification.
➢ SoC issued with a 5-year validity.
➢ Shipowner maintains the IHM
Collection of necessary information (Step 1):
The Shipowner (Owners representative with HM expert certification and class approval) should identify, research, request and procure all reasonably available documentation regarding the ship.
Information that will be useful includes maintenance, conversion and repair documents; certificates, manuals, ship’s plans, drawings and technical specifications; product information data sheets (such as Material Declarations); and hazardous material inventories or recycling information from sister ships.
Potential sources of information could include previous shipowners, the shipbuilder, historical
societies, classification society records and ship recycling facilities with experience working with similar
ships.
Assessment of collected information (Step 2):
The information collected in step 1 above should be assessed. The results of the assessment should
be reflected in the visual/ sampling check plan.
Preparation of visual/sampling check plan (Step 3):
To specify the materials listed in Appendix 1 of Attachment 1, a visual/sampling check plan should be
prepared taking into account the collated information and any appropriate expertise.
On board visual/ sampling check (Step 4):
The onboard visual/ sampling check should be carried out in accordance with the visual/ sampling check plan. When a sampling check is carried out, samples should be taken, and the sample points should be clearly marked on the ship plan and the sample results should be referenced. Materials of the same kind may be sampled in a representative manner.
Preparation of Part I of the Inventory and related documentation (Step 5)
If any equipment, system and/ or area is classed as either “containing hazardous material” or “potentially containing hazardous material”, their approximate quantity and location should be listed in Part I of the Inventory. These two categories should be indicated separately in the “Remarks” column of the Inventory
Diagram of the location of hazardous materials on board a ship (Step 6):
Preparation of a diagram showing the location of the materials is recommended in order to help ship recycling facilities gain a visual understanding of the Inventory.
Testing or Plan assessment by RO’s (Step 7)
Maintaining and updating Part I of the Inventory during operations annually (Step 8)
Chief Engineer is normally responsible designated person onboard, who is in-charge of maintaining and
updating the Inventory of Hazardous Material with the IMO guidelines. As soon as any changes occur
during vessel’s operations such as below.
- Renewal of spare parts list – that could potentially contain hazardous materials (PCHM)
- Structural conversions or repairs
- Dry dock
- Machinery or equipment is added
- Hull painting
Survey and Certification
The Hong Kong Convention and the EU Regulation require the survey and certification of the IHM.
Shipowners are advised to be prepared for these procedures, particularly the final survey, which may begin to be implemented by stakeholders and States prior to entry into force of the IMO Convention.
The survey and certification process throughout the life of a ship will occur as follows:
A. Initial Survey:
- The initial survey takes place prior to the ship being put into service for newbuilds, or prior to the issuing of the International Certificate on Inventory of Hazardous Materials for existing ships. After the initial survey, the Statement of Compliance (SOC) on Inventory of Hazardous Materials can be issued.
- EU SRR requires ships flying the flag of a third country, such as Hong Kong registered ships, calling at a port or anchorage of a Member State of EU shall have on board a Statement of Compliance (SoC), together with the Inventory of Hazardous Materials (IHM) from 31 December 2020.
- Article 12(6) of the Regulation (EU) 1257/2013: “The statement of compliance shall be issued after verification of the inventory of hazardous materials by the relevant authorities of the third country whose flag the ship is flying, or an organization authorized by them, in accordance with the national requirements”
- Vessels flying the flags of Panama, Marshall Islands, Liberia, and Malta must carry a Statement of Compliance issued directly by the flag.
B. Renewal Survey:
- The renewal survey takes place at intervals specified by the flag Administration, but not exceeding five years. The renewal survey verifies that Part I of the IHM complies with the requirements of the IMO Convention, and in effect ensures that any changes that have occurred since the previous survey have been properly recorded
- The validity of the Inventory Certificate (IC) or the ready for recycling certificate (RfRC) or the statement of compliance (SoC) should also be confirmed by verifying that the certificate is properly completed and signed, that surveys (as per Administration requirements) have been performed, and that the identification/ verification number on the Inventory of Hazardous Materials corresponds to that shown on the certificate(s).
C. Additional Survey:
- The additional survey is optional and may be made at the request of the shipowner. It can either be general or partial depending on what the shipowner wishes to verify with respect to the inventory. The additional survey can be used to ensure that changes to the IHM due to repairs or refitting are verified as soon as they have taken place, rather than waiting for the renewal survey.
D. Final Survey:
- The final survey takes place prior to the ship being taken out of service and before the beginning of recycling. The final survey verifies the compliance of the completed IHM, including Parts II and III; that the Ship Recycling Plan properly reflects the information contained in the IHM; and that the ship recycling facility holds a valid authorization in accordance with the IMO Convention.
How should the IHM be maintained:
Part I of the IHM should be maintained throughout the life of the ship, and it is recommended that companies put in place measures to ensure that new installations of equipment, repairs and refitting are accompanied by a Material Declaration (MD) and the Supplier’s Declaration of Conformity (SDoC), as provided by the suppliers of parts and equipment delivered.
Where machinery or equipment is added then the inventory should be updated according to the requirements for new ships, though such updating is not necessary where identical parts or coatings are installed or applied. Such maintenance will ensure that a comprehensive IHM can be provided at future surveys. This will help to avoid the need for further investigation and minimize potential delays due to querying of the inventory by Port State Control officers.
What information will be required from ship owners or managers to prepare an IHM:
Mandatory:
➢ Ship’s Particulars
➢ General Arrangement Plan
➢ Machinery Arrangement Plan
➢ Fire and Life Saving Plan
➢ Fire Protection Plan
➢ Accommodation Plan
➢ Insulation Plan
➢ Piping Insulation
➢ IAFS Certificate
➢ IOPP Certificate (together with supplement page)
➢ IAPP Certificate (together with supplement page)
➢ Spare Parts and Tools List
➢ Type of Fuels, Lubes, Greases, Chemicals and Freon
➢ Asbestos Free Declarations from builders or shipyards
➢ Battery Log (list of batteries onboard)
➢ Repair and modification history.
Preferably:
➢ Capacity Plan
➢ Ozone depleting Substances Log
➢ Manufacturers’ Manuals for selected machinery
➢ Material Declarations (MD) for PCHM
➢ Suppliers Declarations of Compliance (SDOC) for PCHM
➢ Paint Scheme on Deck, other areas and Ballast tanks