IHM and ship recycling

IHM Part I certification

IHM Part I reports, which are prepared according to the MEPC.269(68) 2011 Guidelines for the Development of the Inventory of Hazardous Materials, shall be certified by the flag states or by recognized organizations (ROs).

The EU SRR requires investigation of 15 hazardous substances, listed in Annexes I and II to the regulation, while HKC requires 13. In the table below, you can see the details of the Annexes and Appendices as well as the details of the IHM.

IHM Part I preparation for new ships

For new building ships, the ship yard is responsible for the IHM Part I preparation. IHM preparation for new ships is based on documentation which is provided by the suppliers in the form of Material Declarations (MDs) and Suppliers Declaration of Conformity (SDOC). MD and SDoCs should be provided for all machinery, equipment, materials and coatings installed on board a vessel. The MD and SDoC contain information on whether hazardous materials, as listed in Annexes I and II of the EU SRR and/or Appendixes 1 and 2 of the HKC, are present in the specified products.

New ships flying the flag of an EU/EEA/UK are required to have on board an IHM Certificate issued on behalf of the flag, starting from 31 December 2018.

IHM Part I preparation for ships in operation

The ship owner is responsible for the preparation of the IHM Part I for ships in operation. IHM reports are prepared by hazmat experts, based on document analysis and on-board investigation through sampling and visual checks.

For ships in operation flying the flag of an EU/EEA/UK, the IHM Certificate issued on behalf of the flag is required starting from 31 December 2020.

For ships in operation flying the flag of a third country (non-EU/EEA/UK flag) but visiting EU/EEA/UK ports or anchorages, the IHM Statement of Compliance (SoC) is required starting from 31 December 2020.

EU/EEA member states’ port authorities will be authorized to control ships in order to verify whether they have a valid IHM Certificate or SoC, or a Ready for Recycling Certificate (RfRC), on board.

Scope of IHM Part I

IHM Part I shall list all machinery, equipment, materials and coatings on board which are installed as fixed items. Fixed means the conditions that equipment or materials are securely fitted with the ship, such as by welding or with bolts, riveted or cemented, and used at their position, including electrical cables and gaskets.

For loosely fitted equipment, such as fire extinguishers, distress flares, and lifebuoys, there is no need to list this in IHM Part I. Such equipment which remains on board when the ship is recycled should be listed in IHM Part III.

Those batteries containing lead acid or other hazardous materials that are fixed in place should be listed in IHM Part I. Batteries that are loosely fitted, which includes consumer batteries and batteries in stores, should be listed in IHM Part III.

There are also some exemptions stated in MEPC 269(68) on materials not required to be listed in the IHM. For those Materials, even if the MD states hazardous Materials, they don’t have to be listed in the IHM, but still you can list them if you like.

If an MD states a hazardous material listed in Annex II, which is in the pure metal/steel structure, that product is not required to be listed in the IHM. (Materials listed in Annex II that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery)

If an MD states a hazardous material listed in Annex II in the printed circuit board (PCB) of an electrical and electronic equipment, that product is not required to be listed in the IHM. (Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.)

In general, products listed in Table D is not required to be listed in IHM Part I. Those shall be listed in IHM Part III, which should be prepared prior the decision for recycling of the vessel.

Note:  Table D does not include ship-specific equipment integral to ship operations, which has to be listed in IHM Part I.