Inventory of Hazardous Materials

Completing an Inventory of Hazardous Materials (IHM), is only the beginning of compliance. It is the ship owner's responsibility to ensure continuous conformity of the Inventory.

If you have completed the Inventory of Hazardous Material (IHM) process for your vessel, congratulations you have completed an important step to future proof your vessel's compliance to the following regulations:

  1. Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009)
  2. EU Ship Recycling regulations (SRR)

To ensure you remain compliant to the regulations, you need to know the following FAQs:

This is still not a primary focus area for shipping companies as many are still scrambling to complete the initial IHM. This is bit surprising as it is one of the key elements of the EUSRR Of those who have commenced are either doing it a) internally – using their own internal resources or b) Outsourcing the processes to specialist companies using software or manual systems.

The EU SRR’s EMSA IHM guidance suggests using a software tool to support both the IHM development and maintenance process as well as the management of all the relevant documents, information and data. Varuna Sentinels smart software VSIMS ( Varuna Sentinels IHM Maintenance Server) can fulfil this purpose.

Client interested in demo of this software and learning about fully managed IHM Maintenance should email at

After completion of IHM survey, obtaining SOC from Class Society will be mandatory to remain compliant. Any Class Society that has the Flag State approval may issue the SoC.

5 years. To renew, you will be required to provide your most recent IHM report and evidence of documentation for IHM maintenance.

It is the shipowner's responsibility for the maintenance of Part 1 of the IHM process during the lifetime of the vessel. Continuity and conformity of the information should be confirmed, especially if the flag, owner or operator of the ship changes.

As soon as any changes occur during vessel operations such as below, you are required to update Part 1 of IHM.

  • Renewal of spare parts – that could potentially contain hazardous materials (PCHM)
  • Structural conversions or repairs
  • Dry dock
  • Machinery or equipment is added
  • Hull painting

No, but you must have knowledge of indicative listing of hazardous materials in line with European Maritime Safety Agency (EMSA) Guidelines & MEPC 269(68). It is advisable that experienced personnel drive the process.

Yes, for the IHM maintenance shipowner should collect MDs and SDoCs for all the purchased items that are falling into the scope of IHM Part I (only for items that may possibly contain Hazardous Materials)

Varuna Sentinels follows what is written in the Hong Kong Convention (HKC) and EU Ship Recycling Regulation (EU SRR). HKC Reg 5.3 says that “Part I of the Inventory of Hazardous Materials shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing Hazardous Materials listed in Appendix 2 and relevant changes in ship structure and equipment, taking into account the guidelines developed by the Organization”. It refers to the MEPC IHM Guidelines. And MEPC IHM Guidelines 4.1.4 say “The checking of materials as provided in paragraphs 4.1.2 and 4.1.3 above should be based on the Material Declaration furnished by the suppliers in the shipbuilding supply chain”.

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;

As per the EUSRR a vessel must have a valid SoC prior entering any port or anchorage of the EU. The owner is advised to get the renewal survey done well in time similar as is done for its trading and Classification Certificates.

Hong Kong Convention Regulation 11.8 reads as follows: “If a ship at the time when a certificate expires is not in a port in which it is to be surveyed, the Administration may extend the period of validity of the certificate but this extension shall be granted only for the purpose of allowing the ship to complete its voyage to the port in which it is to be surveyed and then only in cases where it appears proper and reasonable to do so. No certificate shall be extended for a period longer than three months, and a ship to which an extension is granted shall not, on its arrival in the port in which it is to be surveyed, be entitled by virtue of such extension to leave that port without having a new certificate. When the renewal survey is completed, the new certificate shall be valid to a date not exceeding five years from the date of expiry of the existing certificate before the extension was granted.

IHM Part II operationally generated wastes and IHM Part III stores shall be prepared by the shipowner once the decision is given to send the ship for recycling. The IHM Part II and III can be prepared by the crew or if shipowner prefers a hazmat expert can also prepare it.

For IHM Part II & III preparation, please refer to MEPC.269(68) IHM Guidelines as below:

a) Refer to 4.4 & 4.5 in Annex 17, page 8 for IHM part II & part III development requirements;

b) Refer to Table C and Table D in Annex 17, page 14 & 15 for the potentially hazardous materials;

c) Refer to the IHM Part II & III example table in Annex 17, page 18-21;

d) Additionally, IHM Part II & III investigation report with supporting documents, such as inventories, recordings, log books, site pictures, etc. attached as the appendices should be provided to Class for approval.

It is a list of ship recycling facilities which meet the EU SRR requirements. Starting 2018-12-31 ships, flying the flag of an EU/EEA Member State, shall be recycled only in the listed facilities. The list can be found here.

For ships built before 1 July 2002

Ships built before 1 July 2002 may contain asbestos, but it should be managed properly - further guidance is available in MSC/Circ.1045 Guidelines for Maintenance and Monitoring of On-Board Materials Containing Asbestos.

For ships built between 1 July 2002 and 1 January 2011

For all ships, new installation of materials which contain asbestos shall be prohibited except for:

  • vanes used in rotary vane compressors and rotary vane vacuum pumps;
  • watertight joints and linings used for the circulation of fluids when, at high temperature (in excess of 350ºC) or pressure (in excess of 7 x 106 Pa), there is a risk of fire, corrosion or toxicity; and
  • supple and flexible thermal insulation assemblies used for temperatures above 1000ºC.

For ships built after 1 January 2011

The 2009 Amendments to SOLAS (resolution MSC.282(86)), further amended the text to prohibit all new installation of asbestos on board ships. These came into force on 1 January 2011;

IMO MSC.1/Circ.1374, Article 13 reads as follows:

“When asbestos is detected on board, in contravention of SOLAS regulation II-1/3-5, action should be taken to have it removed. The removal – assigned to professional asbestos removal companies – should take place within a time frame of 3 years from the date when the contravention is found and should be conducted in close consultation with and, where applicable, under the supervision of the flag State concerned. In such cases, a suitable exemption certificate should be issued by the flag State.”

If Asbestos is detected on board, it may affect Safety Construction Certificate of the ship according to SOLAS requirement. 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. Flag has the final say.

Here are some practical pointers when it comes to IHM maintenance of the Inventory list.

IHM review report: Review current approved IHM report. In particular, take note of the list of PCHM in the report.

IHM hazard : Understand what can be potential hazardous materials onboard. These information are commonly available in Visual Sampling Check Plan (VSCP), location diagram & approved IHM report.

IHM procurement : Identify purchase orders that could contain potential hazardous materials. In particular, purchase orders related to:

  • 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

In our experience, work relevant to insulation, gasket and break lining could contain hazardous materials.

IHM data collection : Begin the data collection process for purchase orders with potential hazardous materials. This can be done by sending Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) templates to your suppliers (Tier 1 suppliers).

IHM analyse: Analyse the MD and SDoC, and update Part 1 of IHM if hazardous materials are found.

IHM deliver : Send the updated Inventory to Class.

It is the Tier 1 supplier's duty to provide MD and SDoC. The Tier 1 suppliers may request from their own suppliers (Tier 2 suppliers) for relevant information if they cannot develop the MD based on the information available. Thus, the collection of data on hazardous materials may involve the entire supply chain. The information data flow is illustrated below:

This will clean up the current ambiguity in the manufacturing processes wherein the manufacturer now has to certify his product as conforming to the regulations. Thus, he can be held legally accountable for his products at a future date also. Hence the production stage itself will ensure compliant products leading to compliant ships.

Circular Maritime Economy (CME)

What does circularity mean?

Within the concept of sustainability, circularity is the preferred way of looking at how different industries and societies can approach their economic impact. Historically, we have had a throwaway approach, where material was produced, used and thrown away. Now, it’s already commonplace to speak about the recycling economy – introducing product back into production. This is far better than the linear model, but what is preferred is that even though we will always have a flow of new materials, there should be a circular economy where items are produced, used, recycled and produced again. That way we avoid disposing items into the environment. This is going to take time but moving in that direction is what is expected from sustainable businesses to look for in the future. Read More

We can divide the maritime business into four parts:

  • Leisure (this includes the cruise business, for example)
  • Harvesting of raw materials (oil and gas, offshore mining, fishing)
  • Logistics (shipping of food, energy, containers, bulk material)
  • Infrastructure (ferries, local shipping and defence)

All of them face a ‘license to operate’ issue because people do not like to have polluters in their space or emissions in their air and water. So, all maritime businesses face requirements from regulators. There are global actors like the Hong Kong convention and the IMO, and then you have local actors like the European Union and even more local, such as cities. Politicians too, are interested in this. Even so because the general public is interested in it.

In short, all segments of the maritime economy are facing pressure from both regulators and end consumers to be more environmentally friendly.

We have to start from a lifecycle approach. In corporate-speak, lifecycle typically means the middle of life, but the framework of a lifecycle is the beginning of life, middle of life, and end of life.

In the beginning of life, when we are developing these assets and operations, we usually say ‘built to last', but we prefer ‘designed to last'. This is to say that the assets will not wear out quickly – they can be used for a long time and then circled into something else in the manufacturing process. Then, we have to look at how we bring to the operations something that is conditioned and refurbished. The assembly and integration aspects are the last part of the beginning of the lifecycle stage.

The middle of the lifecycle stage includes the operation. Here we need to introduce a service-based model rather than a product-based model. This means we are less oriented towards asset ownership and more towards performance. This stage includes repair and maintenance work and long-term maintenance support. We should ask, at this point, if there are any opportunities for upgrades or ways in which we can improve the performance of the assets. Extending the lifetime increases the material effectiveness. We typically speak about energy effectiveness but increasing the material effectiveness means that we use fewer raw materials because we are extending the life of existing materials.

Then, finally comes the end of life part which comprises the decommissioning, scrapping and considering what can be recycled or upcycled back to the raw material process.

It is not just the regulations that is going to drive the change in the industry. It is also the connected stakeholders eg, banks, insurance companies, shippers, charterers, NGOs, investment funds, individual investors who will want to see their related assets demonstrably clean and clear in following the regulations and not just relegate it as a paper exercise.

The stakeholder perceptions will decide who takes the commercial lead.

We are doing a fairly good job bringing assets back to the material flow so that they can be used elsewhere. Today, most ship materials are reused. A lot of that is steel, but there are also interior materials and system components that can be reused. But the biggest win we have is the lifetime extension. We are extending the asset lifetime and through that, we will need less new material.

There’s a new regulation called the Energy Efficient Existing Ship Index (EEXSI) coming in, which will impact all ships currently in operation. It requires a minimum energy efficiency level per capacity mile. One way to tackle this is to convert ships by lengthening or by whatever means, making them larger and improving some of the systems so we can increase the capacity. This way we could cut down the total emissions of the maritime industry and at the same time use less materials.

There is a business case in this idea of lengthening. If you have a revenue potential of 100 percent, you enlarge your capacity by 50 percent, thereby making your earning potential 150 instead of 100 percent. With these lifetime extensions, you're actually not taking any huge risk because you’re making a decision today that can start paying back tomorrow.

There’s also the ‘license to operate' issue. If you don't start to do the right things, it might be that you are pushed out not by your existing competitors, but by somebody else who will disrupt your business and say, well, instead of dealing with sea logistics, I will choose a local manufacturer, so I do not need to transport goods so far from the customer.

There is no silver bullet, we need to have multiple solutions. And this would be one more solution in the portfolio, meaning that there's more activity for those ships in operation. Rather than only focusing on the new builds, which is mostly a conversation about what will happen in the future, with this kind of thinking, we can already start taking action today.

Other industries and companies are already promoting circularity. We have promised to support the cruise industry in developing and promoting its own circularity.

After the financial crisis, we stopped talking about total lifecycle environmental impact, but now is the time to bring that back on the agenda. We need to start asking ‘what is the total footprint of this activity’?

Circularity could be a way the maritime business could leave a positive 'handprint'.

VS believes in staying a step ahead, using data and record collection in the simplest and most economical way possible without any disruption to the day to day managerial operations.

The VS software (VSIMS) not only collects the MDs and SDoCs when items are delivered on board but it also tracks their location onboard till they are finally off landed and providing a clear audit trail of the 15 elements of the hazardous materials identified in the regulations.

At any time a clear snapshot of the vessel can be provided showing how they came on board, how they moved and their current location on board. A historical data will also be maintained showing how and with whom they were off landed thus providing a circular record with a cradle to grave approach.

This visibility into your hazardous materials will support your fleet's recycling, sales, and logistical decisions and save costs