The Inventory of Hazardous Materials (IHM) is a crucial document for all ships, playing a vital role in ensuring maritime safety and environmental protection. This comprehensive guide addresses the most frequently asked questions about IHM, providing ship owners, operators, and industry professionals with essential information, updated for 2024 to reflect the latest regulatory changes.
What is an Inventory of Hazardous Materials (IHM)?
An IHM is a structured report that lists the type, location, and approximate quantity of hazardous materials on board a ship. It’s a crucial tool for ensuring the safe and environmentally sound recycling of ships.
Who is responsible for commissioning the IHM report?
In most cases, the ship owner is responsible for commissioning the Inventory of Hazardous Materials. However, recycling yards or managing agents may act on behalf of the owner.
Is the IHM required only for older, previously constructed ships?
No, this is incorrect. All ships, whether previously constructed or newly completed, must have an IHM report. This requirement applies to ships of 500 GT and above.
How often does the IHM need to be maintained or reviewed?
The IHM needs to be reviewed annually for the production of a Statement of Compliance. A full new report is required every five years. Additionally, the IHM should be updated whenever there are significant changes to the ship’s structure or equipment.
What are the main substances reported in an IHM?
The IHM covers a wide range of hazardous materials, including:
- Asbestos
- Polychlorinated biphenyls (PCBs)
- Ozone-depleting substances (ODS)
- Anti-fouling systems containing organotin compounds (TBTs)
- Heavy metals (such as lead, mercury, cadmium, and hexavalent chromium)
- Radioactive substances
- Certain flame retardants
- Other hazardous materials listed in the guidelines
What are the latest regulatory updates regarding IHM?
The most significant recent development is the entry into force of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (Hong Kong Convention). Key points include:
- Entry into force date: 26 June 2025
- Compliance deadline: 26 June 2030
- Applies to: All ships of 500 GT and above engaged in international voyages
- Requirements: Valid IHM certificate or statement of compliance on board
What happens if my ship doesn’t comply with the IHM requirements by the deadline?
Non-compliance after the June 2030 deadline can result in:
- Penalties
- Detentions
- Denied entry to ports of countries that have ratified the Hong Kong Convention
- Potential commercial disadvantages
Am I at risk if an IHM indicates I have hazards on board?
Not necessarily. The presence of hazardous materials doesn’t automatically create an immediate risk. The contractor producing the inventory will advise you on any urgent requirements to comply with health and safety regulations. If the identified materials are managed correctly, the risk associated with exposure is typically low and controllable.
Where are IHM surveys carried out?
IHM surveys can be conducted at the ship owner’s convenience. They can be done on:
- An active vessel
- A vessel primed for decommissioning
- A vessel within dock
How much do IHM surveys cost?
The cost varies depending on the type of survey:
- Basic survey (suitable for new built active ships): Less extensive and less costly
- Full depth survey (for vessels nearing the end of their service): More intrusive, comprehensive, and expensive
How long does an IHM survey take?
The duration depends on the type of vessel and the nature of the inventory:
- Basic survey: Typically one to two weeks
- Full depth survey: Can take several weeks to months for larger vessels
What steps should ship owners take to prepare for the 2030 compliance deadline?
- Commission an initial IHM survey if not already done
- Develop a timeline for compliance, including regular updates and the five-year renewal
- Implement a hazardous materials management plan
- Train crew on IHM maintenance and the importance of compliance
- Plan for any necessary remediation or removal of hazardous materials
- Stay informed about any updates to regulations or guidelines
Need expert assistance with your IHM compliance? Contact our team for comprehensive support in navigating these regulatory requirements.
