Recent detentions by Port State Control serve as a stark reminder that hazardous materials management is an ongoing obligation.
In recent weeks, two vessels registered under the flag of the Marshall Islands were detained due to Inventory of Hazardous Materials (IHM) Statement of Compliance was either expired or inaccurate, a costly oversight that could have been avoided.
Following the incidents, the RMI Maritime Administrator issued Marine Safety Advisory No. 04-26, urging all operators trading to EU and UK ports to immediately check their IHM documentation is in order. It’s a timely reminder that compliance in this area requires constant vigilance.
Understanding the EU Ship Recycling Regulation
The EU Ship Recycling Regulation (1257/2013) came into force to ensure ships are recycled in an environmentally sound and safe manner. A key requirement of the regulation is that all vessels calling at EU ports must carry a valid Inventory of Hazardous Materials, essentially a comprehensive record of all hazardous materials used in the ship’s structure and equipment.
The regulation applies to:
- Ships flying the flag of an EU Member State
- Ships calling at EU ports or anchorages (regardless of flag)
What is an Inventory of Hazardous Materials (IHM)?
The IHM is a detailed document that identifies and records the location and approximate quantities of hazardous materials on board a vessel. It consists of three parts:
- Part I: Materials contained in the ship’s structure and equipment (mandatory for all vessels)
- Part II: Operationally generated wastes
- Part III: Stores
The IHM must cover materials such as asbestos, polychlorinated biphenyls (PCBs), ozone-depleting substances, heavy metals (lead, mercury, cadmium, hexavalent chromium), flame retardants, and certain other chemicals listed in the regulation.
Vessels must undergo initial surveys and renewal surveys (at least every five years) to maintain their Statement of Compliance and, critically, the IHM must be updated whenever modifications are made to the ship’s structure or equipment.
A Wake-Up Call for the Industry
Kevan O’Neill, Principal Consultant at Lucion, says the recent detentions should serve as a wake-up call for shipowners and technical managers.
“For many shipowners, the IHM was initially developed to meet a compliance deadline, but compliance is not a one-off exercise, it’s an ongoing obligation.” Kevan explains.
“Any structural modification, equipment replacement, or change in installed systems can trigger the need to update the IHM. When this process isn’t embedded into day-to-day technical management, gaps quickly emerge.”
The consequences are significant. “Detentions are costly, both financially and reputationally,” Kevan notes. “They disrupt operations, impact charter commitments, and signal weak compliance oversight to regulators, charterers, and insurers.”
Port State Control is Getting Tougher
Inspection regimes are evolving. Port State Control inspectors are going beyond checking that an IHM certificate exists, scrutinising the surveys and documentation.
Kevan points out what inspectors are now focusing on: “Port State Control inspections are increasingly focused on documentary accuracy and consistency.
Inspectors are checking that the Statement of Compliance is valid and within date, that the IHM reflects the vessel’s current configuration, that supporting documentation aligns with purchases and retrofits, and that Part I is actively maintained.”
The regulatory landscape isn’t becoming lighter, and enforcement is only increasing. The key to avoiding detention and operational disruption is embedding IHM maintenance into routine technical management processes.
“The safest position is proactive compliance, not reactive correction,” says Kevan. “If you’re unsure whether your fleet’s IHM maintenance process would stand up to inspection today, it may be time for a review.”
Get Your IHM In Order
As specialists in hazardous materials management, our dedicated Marine and Offshore Team regularly support shipowners and technical managers across the maritime sector with:
- Developing compliant IHMs from the outset – ensuring your initial survey captures everything accurately
- Reviewing and validating existing inventories – identifying gaps before inspectors do
- Supporting maintenance procedures – keeping IHMs live and audit-ready as your vessels evolve
The RMI Maritime Administrator has made it clear that if an initial or renewal survey is required, operators should act immediately. Don’t wait for a detention notice to discover your documentation isn’t in order.
With approval from major IACS Classification Societies including Lloyds Register, Bureau Veritas and American Bureau of Shipping (ABS), and DNV GL certified Marine HazMat Experts, Lucion ensure you maintain compliance and business continuity.
